R19.0177 - Islington Council

 
R19.0177 - Islington Council
R19.0177

Planning Policy Team
Freepost RTXU-ETKU-KECB                              Our reference: LDF19/LDD22/LP03/HA01
Planning Policy                                                         Date: 18 October 2019
Islington Council
Town Hall, Upper Street
London N1 2UD

By email: planningpolicy@islington.gov.uk

Dear Sir/Madam,

Statement of general conformity with the London Plan (Planning and Compulsory
Purchase Act 2004, Section 24(4)(a) (as amended);
Greater London Authority Acts 1999 and 2007;
Town and Country Planning (Local Development) (England) Regulations 2012

RE: Islington Local Plan – Strategic and development management policies, Site
Allocations and Bunhill and Clerkenwell AAP Regulation 19 consultation

Thank you for consulting the Mayor of London on the Islington Strategic and development
management policies, Bunhill and Clerkenwell area action plan and Site Allocations Local
Plan Regulation 19 documents. As you are aware, all Development Plan Documents in
London must be in general conformity with the London Plan under section 24 (1)(b) of the
Planning and Compulsory Purchase Act 2004. The Mayor has afforded me delegated
authority to make detailed comments which are set out below. Transport for London (TfL)
have provided comments, which I endorse, and which are attached at Annex 1.
The Mayor provided comments on the earlier Regulation 18 consultation documents on 21
January 2019 (Ref: LDF19/LDD22/HA01) and 24 January 2019 (Ref:
LDF19/LDD22/LP02/CG01). This letter follows on from that earlier advice and sets out
where you should make further amendments to be more in line with the emerging draft new
London Plan.

The draft new London Plan
As you are aware, the Mayor published his draft London Plan for consultation on 1st
December 2017. The Consolidated Suggested Changes version of the draft London Plan was
published on 16th July 2019. Publication of the new London Plan is anticipated in Winter
2019/20, at which point it will form part of Islington’s Development Plan and contain the
most up-to-date policies.
Given the anticipated timetable for the Examination and adoption of Islington’s Local Plan it
will need to be in general conformity with the new London Plan. Islington will have to
R19.0177 - Islington Council
consider any changes included in the Mayor’s Intend to publish version of the new London
Plan which will be published following receipt of the Examination Panel Report.

General
The Mayor welcomes the seven principle objectives that underpin the strategic approach
outlined in the Draft Local Plan. The strategy to deliver growth over the plan period follows
a very clear and rational process which is set out early on. The Mayor is pleased that much
of the advice contained in his earlier response to the emerging Local Plan has been
positively incorporated into this Regulation 19 version. Figure 1.2, for example, sets out
very clearly the geographic context of Islington’s relationship with the Central Activities
Zone (CAZ) and the Elizabeth Line and Figure 2.1 builds on the context by setting out
Islington’s eight spatial strategy areas where most of the borough’s planned growth will be
concentrated and delivered over the plan period. These areas include, Archway, Finsbury
Park, Nags Head and Upper Holloway, Highbury Corner and Holloway Road, Angel, King’s
Cross Pentonville Road, Vale Royal Locally Significant Industrial Site and Bunhill and
Clerkenwell. The Bunhill and Clerkenwell Area Action Plan is further divided into six
character areas for which the approach to growth is differentiated appropriately.
The Mayor especially welcomes Islington’s ambitious declaration at paragraph 1.57 to
become net zero carbon by 2030, which sets the standard for London as a whole and will
make a significant contribution in meeting the Mayor’s target for London to become a zero
carbon city by 2050.
The Mayor welcomes the overall approach to growth and development in Islington’s Draft
Local Plan and considers that on the whole the plan is positive and, as drafted, is in general
conformity with the London Plan.
The Mayor’s response that follows includes recommendations and other representations to
clarify and improve upon some policy areas and to ensure the document is more aligned
with the draft new London Plan.

Strategic and development management policies
Housing delivery
The Mayor welcomes Islington’s recognition and commitment to exceeding its new London
Plan housing target of 775 new homes a year as a minimum up to 2028/29 and the positive
intention to achieve this by ensuring that proposals for housing developments optimise the
use of land and buildings.
Beyond 2029 Islington’s intention is to roll forward the annual housing target of 775 units
in the unlikely event that their Local Plan and/or the London Plan housing targets have not
been revised and updated. While Islington’s approach is acceptable officers draw attention
to the draft new London Plan (consolidated changes) paragraph 4.1.8D which now states
that if a target is required beyond 2029 boroughs should base it on findings from the 2017
London SHLAA in consultation with the GLA and should take account of additional capacity
that may result from any committed transport infrastructure improvements and roll forward
the housing capacity assumptions for small sites.
It is Islington’s intention to apply the Draft New London Plan threshold approach to
affordable housing, but through the setting of a locally evidenced higher threshold level of
45% affordable housing and through the imposition of requirements for review mechanisms
R19.0177 - Islington Council
for those proposals delivering less than 50% affordable housing. The Mayor welcomes this
approach and recognises that the higher threshold is underpinned by local up-to-date
evidence contained within Islington’s Draft Local Plan Viability Study (2018).
As noted in our original response to Islington’s draft Local Plan, the approach to affordable
housing delivery is more rigorous than that set out in Draft New London Plan Policy H6 as it
limits the application of the Viability Tested Route to those development proposals where
there are exceptional circumstances only. This approach is in line with Draft New London
Plan Policy DF1 and the revised National Planning Policy Framework / Planning Practice
Guidance which limits site specific viability to exceptional circumstances where there are
genuine barriers to delivery. The approach is considered to be consistent and in line with the
draft new London Plan. However, Islington should monitor market conditions to ensure the
continued delivery of housing and commercial development.
On reviewing the draft Local Plan approach to affordable housing the Mayor strongly
encourages Islington to base affordable housing requirements on gross residential
development as set out in draft new London Plan Policy H6, as opposed to net additional
housing as currently worded in the draft Local Plan in Policy H3, in order to optimise
affordable housing delivery.
Paragraph 3.29 of the draft Local Plan seeks to protect against the loss of existing
affordable housing and this is welcome. It should be noted, however, that Policy H10BA of
the draft new London Plan makes it a requirement that all schemes involving the demolition
and replacement of affordable housing must follow the Viability Tested Route and should
seek to provide an uplift in affordable housing. This should be reflected in Islington’s Local
Plan.
The Mayor welcomes Islington’s intention at paragraph 3.65 to ensure the integration of
affordable housing so that it is tenure-blind and builds on the principles laid out in the
Mayor’s Good Growth Policy GG1 and paragraph 3.4.5B of the draft new London Plan with
the ambition of building stronger and more inclusive communities.

The Mayor welcomes Islington’s requirement that 35% of new student accommodation is to
be affordable and that achieving this will ensure the threshold for the fast track route is met
in accordance with the latest consolidated version of draft new London Plan Policy H17A4.
Boroughs are encouraged to maximise the delivery of affordable student accommodation
and Islington should recognise that this might be jeopardised through the prioritisation of
bursaries over and above affordable accommodation.

Gypsy and traveller accommodation
The Mayor welcomes that Islington is using the new definition for gypsies and travellers as
set out in Policy H16 of the draft new London Plan. Islington has conducted a needs
assessment which indicates a need for 10 new pitches over the plan period: 8 by 2025 and
another 2, required by 2035. While it is noted that the draft Site Allocations do not identify
suitable sites for accommodating this need over the plan period, Islington is encouraged to
review its own estate and work with neighbouring boroughs and should note that Mayoral
funding is available through the Homes for Londoners Affordable Homes Programme for the
provision of new pitches, on a single or multi-borough basis as set out in paragraph 4.16.8
of the draft new London Plan.
Office and Industrial
Local Plan evidence establishes a need for 400,000m2 of office space over the plan period,
coupled with the need to accommodate a further 50,500 new jobs. Draft Local Plan Policy
B2 directs office use to the CAZ, the Bunhill and Clerkenwell area, Spatial Strategy areas
within the CAZ and Priority Employment Locations and not to the borough’s industrial
areas. This approach is in line with draft new London Plan Policies E1 and SD4 and is
welcomed by the Mayor.
Islington’s intention to protect its designated industrial land, especially its largest remaining
industrial reserve at Vale Royal/ Brewery Road is welcome and aligns with draft new London
Plan Policy E4. Part of Islington falls within the Central Services Area and as such it is
recognised that industrial sites can provide essential services to the CAZ as required by draft
new London Plan policy SD4M. Of particular importance is the need to provide ‘last mile’
distribution/logistics, ‘just-in-time’ servicing, waste management and recycling as well as
land to support transport functions. In light of this Islington should realise that it is
important that B2 and B8 uses are prioritised over B1(c) uses to support these types of
essential activity in accordance with paragraph 6.4.7 of the draft new London Plan. The
draft new London Plan is clear that new office development should only be located in town
centres, the CAZ and within established office clusters outside of these areas in accordance
with draft new London Plan Policy E1.
While the Mayor supports the new Locally Significant Industrial Sites designations and the
greater protection of industrial capacity at Melody Lane, North Road, Offord Road,
Pemberton Gardens and Station Road. It is understood that these sites were originally
designated as Employment Growth Areas in the current Local Plan but so were others.
Islington should clearly set out, with supporting evidence, the rational for selecting these
sites as set out in draft new London Plan Policy E6.
Islington should consider extending it approach to affordable workspace to B1(c) uses to
recognise the breadth of businesses and industries across the borough.

Tall buildings
The Mayor welcomes Islington’s approach to tall buildings by setting out a clear definition
and through the identification of specific locations where tall buildings, over 30m in height
might be suitable, subject to other Local Plan requirements. This approach is aligned with
draft new London Plan Policy D8 and is underpinned by Islington’s Tall Buildings Study
2018.
A single image which combines both Figure 8.2 Strategic and local views and Figure 8.3
Locations suitable (in principle) for tall buildings over 30m would be useful and is
recommended to illustrate that locations for tall buildings have been strategically chosen in
order to avoid impacts on strategic and local views and that where there are clear overlaps,
maximum heights set out in Table 8.1 will ensure that impacts are avoided.
Site Allocations
The indicative capacity figures for each broad spatial area are included in Table 2.2 and this
is welcome.

There is a typo in paragraph 1.30 which states that ‘over the 15-year period from 2021/22
to 2035/36, Islington’s total housing requirement will be 11,625 units per annum…’.

Where sites are identified as being within a protected viewing corridor, it would be useful
and welcomed for Islington to set maximum height limits for those particular sites affected
by this designation, with detailed height assessment made at application stage.

The Mayor welcomes recognition of the borough’s cultural assets and the protection of
these uses through site allocations for sites such as AUS11Proposed Collins Theatre and
NH9 Islington Arts Factory. This approach is in line with the approach set out in Policy HC5
of the draft new London Plan.

Industrial Uses
Boroughs in the ‘retain capacity’ category as set out in Table 6.2 of the draft new London
Plan should seek to intensify industrial floorspace capacity following the general principle of
no net loss across designated SIL and LSIS. Islington is also located in the Central Services
Area which means that there should be a focus on the provision of essential services to the
CAZ and in particular, sustainable ‘last mile’ distribution/logistics, ‘just in time’ servicing,
waste management and recycling and land to support transport functions and therefore B2
and B8 uses should be prioritised in line with draft new London Plan policy SD4M.
It is clear that the proposed allocations within the Vale Royal/Brewery Road LSIS are for the
retention and intensification of industrial uses which is supported by the Mayor and is
closely aligned with draft new London Plan Policies E4 and E6.
Office floorspace should be directed to Islington’s town centres and the CAZ, in line with
London Plan policy E1. Islington could consider whether any development pressure in the
LSIS merits preparing a masterplan to ensure the retention, intensification and increase in
industrial floorspace in line draft new London Plan E7.
A number of the sites identified in the site allocations are home to industrial uses and an
approach to their future intensification should be applied in a consistent and methodical
manner and in accordance with the draft new London Plan. It should be noted that between
2001 and 2015 more than 1,300 hectares of industrial land was released to other uses, well
in excess of previously established London Plan monitoring benchmarks. In 2015, 36% of
industrial land in London was located on non-designated sites which contributes
significantly to the effective functioning of London’s economy as a whole. While a number
of the borough’s site allocations have an element of industrial uses the sites that they lie
within are not designated as such.
Islington’s intention to protect the industrial uses on many of these non-designated sites is
welcomed and the Mayor would support consideration for their designation as locally
significant industrial sites where this was justified and followed a methodical and consistent
approach.
Bunhill and Clerkenwell AAP
Figure 1.1 is welcome, which sets out clearly, the extent of the AAP boundary and so too is
Figure 1.2 which sets the context of the AAP area in relation to the CAZ, City Fringe OA and
the Elizabeth Line.
The AAP sets out early on its key ambition for the provision of office floorspace in draft
Policy BC1, which reflects Policy E1 of the draft new London Plan and prioritises office
development in the CAZ. The approach is one which is also in line with draft new London
Plan Policy E8 which promotes office development in the City Fringe/Tech City cluster,
recognising it as one of London’s nationally-significant office locations.
Culture, retail and leisure uses are Islington’s second level priority for the area and as such
this is in line with the approach set out in the draft new London Plan Policy SD4 which
promotes the unique roles of the CAZ which are listed under paragraph 2.4.4 of the draft
new London Plan and includes arts, culture, leisure and entertainment among many others.
The AAP responds positively to the opening of the Elizabeth Line station at Farringdon and
plans for significantly greater levels of pedestrian movement with measures to facilitate ease
of movement and modal interchange are welcome.
Where industrial uses exist on non-designated industrial sites, like BC36 London
Metropolitan Archives and Finsbury Business Centre, for example, the approach should be
to follow the guidance set out in draft new London Plan Policy E7D and the policy should
be amended accordingly, and further clarity provided where the term ‘business use’ has
been included in the text to differentiate between industrial and non-industrial uses.
I hope these comments inform the development of the Islington Local Plan. If you have any
specific questions regarding the comments in this letter please do not hesitate to contact
Hassan Ahmed on 020 7983 4000 or at hassan.ahmed@london.gov.uk.

Yours sincerely

Juliemma McLoughlin
Chief Planner

Cc     Jennette Arnold, London Assembly Constituency Member
       Andrew Boff, Chair of London Assembly Planning Committee
       National Planning Casework Unit, MHCLG
       Lucinda Turner, TfL
In summary, we previously raised these specific key concerns:

   •   embedding Healthy Streets and the Mayor’s Transport Strategy (MTS)
       mode shift targets for Islington
   •   referring explicitly to improving bus priority and journey times
   •   specific details about a number of Site Allocations, such as delivery
       timescales, red line boundaries and Crossrail 2 safeguarding information
   •   the policy on ‘shared space’
   •   how to refer readers to TfL’s online guidance for planning applicants and
       our TfL Streets toolkit
   •   technical requirements for disabled car parking; cycle parking; Travel
       Plans; and Pedestrian Environment Review System (PERS) analysis in
       Transport Assessments (TAs)

The vast majority of these concerns have now been addressed. However, some do
remain that we would like to clarify, summarised in the tables below, including on
disabled persons parking, car clubs and electric vehicle charging points. In particular,
we remain concerned about the effective reduction in cycle parking standards
relative to the London Plan through the use of Gross Internal Area (GIA). It is likely
that a solution to this can be easily and quickly found through further discussions,
which we would welcome.

In two tables appended to this letter, I have summarised TfL’s outstanding concerns
in detail, and all of our previous comments and redrafting requests, alongside
relevant page numbers and feedback on whether TfL is happy with changes made
between the Regulation 18 and 19 drafts.

For ease of reference, the tables are shown in priority order, with unresolved
concerns at the top. Where significant textual changes or further clarification are still
requested by TfL, font in the tables is coloured red.

We look forward to continuing our work together as you proceed towards
examination and adoption of these policy documents.

We would welcome the opportunity to meet with you as soon as possible for further
collaborative discussions, and ideally to agree together how TfL’s outstanding
transport concerns can be urgently resolved.

Thanks and kind regards,

Gavin McLaughlin | Principal Planner
TfL City Planning
Email: gavinmclaughlin@tfl.gov.uk

                                            8
Cycle                 Minimum cycle parking standards listed in Appendix 4 should also set out requirements for short-stay cycle parking.         N, 296
parking               Guidelines for the location of short stay parking are detailed in the accompanying text, however are not specified in the
standards   256       minimum cycle standards. If minimum cycle parking standards are amended into a minimum floorspace requirement,
(Appendix             rather than spaces per sqm, these should be equivalent to the draft London Plan standards and separated into long and
4)                    short stay minimum parking requirements.
                      We welcome innovative approaches to secure sufficient quantities of cycle parking that are of high-quality. In
                      particularly, we welcome efforts to secure sufficient space for cycle parking, which is essential for achieving good
                      quality facilities. We would welcome further discussion on how the spatial equivalents were calculated and how
                      this relates to the London Cycling Design Standards (LCDS), and the possibility of some provision using two-tier
                      stackers that are of high-build quality and are easy to use (which require less space).

                      We appreciate that part of this approach is to use Gross Internal Area (GIA) rather than Gross External Area (GEA)
                      as used in the London Plan. However, as GIA is less than GEA, this amounts to a reduction in provision, which we
                      cannot support. The standards in the London Plan have been calculated on the basis of demand as it relates to
                      GEA. For example, the office standards cater for a 19 per cent mode share, assuming as 14 employees per square
                      metre (GEA).

                      We therefore request either the standards to switch to GEA, or an increase in the standards to supporting the
                      same mode share using GIA. We would be happy to discuss how best to approach this.

                      We also strongly welcome the allocation of minimum space requirements for accessible cycles in both supporting
                      text and top row of Table A4.1, stating that ‘20% of cycle parking spaces in any new development should be
                      accessible, of which 25% must be designated for non-standard cycles and 75% for ambulant disabled cyclists’ (p.
                      298).
                      It is also important to clarify that Islington’s Local Plan should refer to TfL’s design guidance documents and standards   N, 294-295
                      for all of the Transport for London Road Network, as well as specific local authority guidance, such as Islington’s
                      Streetbook SPD. To ensure references are kept up to date, please use more generic language such as ‘TfL’s latest
Appendix
            253-255   online guidance’ or ‘guidance at the TfL website.’ The thresholds for Transport Assessments and Travel Plans in Table
3
                      A3.1 are acceptable in principle to TfL. However, Travel Plans and Delivery and Servicing Plans will change in 2019,
                      much like Transport Assessments. Our pre-application services are changing now as they do not currently reflect Vision
                      Zero and the Healthy Streets Approach.

                                                                        10
The section on ‘Full Travel Plans / Local Level Travel Plans’ including Table A3.2 should therefore be removed. If the
                       Council is genuinely dedicating resource to monitoring and enforcing travel plans, and can provide evidence of them
                       achieving positive results, we would welcome further discussions. Whilst we support Travel Plans in principle, they do
                       not currently appear to be acting as ‘the key management tool for implementing any transport solutions highlighted by
                       the Transport Assessment’ or ‘primary tools for mitigating negative transport impacts of development proposals’
                       based on our own experiences and recent investigations. The Local Plan should acknowledge that Travel Plans require
                       improvement and refer applicants to our website for further guidance next year.
                       Thanks for using more generic language ‘Up-to-date TfL online guidance’. However please change the URL cited
                       by footnote for both Transport Assessments and Travel Plans to https://tfl.gov.uk/info-for/urban-planning-and-
                       construction/guidance-for-applicants

                       We take it from the retention of Table A3.2 on Travel Plans following our previous comments that the Council is
                       genuinely dedicating resource to monitoring and enforcing travel plans at the moment, and will continue to do so
                       in future. We therefore request no further amendments to the draft policy. We also request contact details for a
                       relevant officer from within the Council to attend our up-coming TfL Travel Plan guidance Working Group,
                       Chaired by Anthony Mcnamara of WestTrans. The group will help us update our website with shorter, better
                       travel planning guidance for boroughs and planning applicants.
                       Section 7.32 – This section references the shared space policy and then moves on in quick succession to describe               Y, 243
                       walking and cycling surfaces (shared use). It is recognised that the technical terminology is ambiguous and not helpful.
                       However, the user dynamics and issues for shared spaces where motor vehicles are expected, versus shared use
Policy T2   210        footways where pedestrians and cyclists will only be present, are fundamentally different. We would therefore
                       recommend separating policy lines on shared use footways (informed by DfT guidance: LTN 1/12), from that of shared
                       space (formerly covered by LTN 1/11 and awaiting an update). It is worth noting that the DfT are working with
                       Transport Scotland to develop their guidance on shared space and this is expected towards the end of 2019.
                       It appears this section has now been removed. Please can you confirm this? Thanks.
                       Policy T2 C and Section 7.12– We understand your concerns regarding the use of ‘shared space’ as a design approach.            Y/N, 235
                       However, we believe your policy to resist the use of ‘shared space’ is unnecessarily strong and could prevent delivery of
                       cycling and walking improvements in some tight spaces, where a more pragmatic approach is often required. The
Policy T2   203- 204   Department for Transport (DfT) recently clarified their original call for a pause to level surface schemes by stating that:
                       “The pause does not apply to streets within new residential areas, or the redesign of existing residential streets with very
                       low levels of traffic, such as appropriately designed mews and cul-de-sacs, which take into account the relevant aspects of
                       the National Planning Policy Framework and associated guidance” (DfT, MHCLG, 28 September 2018). The current policy

                                                                          11
does not identify the specific features of ‘shared space’ that are deemed to be problematic or consider the context as
                        part of the design approach. The main concerns of ‘shared space’ layouts are approaches that do not provide a kerb
                        upstand. Policy T2 C and supporting text in section 7.12 should therefore clarify that provision of level surface schemes
                        in situations that have a high movement function will not be supported. We would also suggest a softening of the
                        policy line for new developments and residential streets where traffic flows and speeds will be very low or where there
                        is limited space. It is worth noting that the DfT are working with Transport Scotland to develop their guidance on
                        shared space and this is expected towards the end of 2019. Compromises may need to be made in some contexts,
                        especially if the alternative could be simply not delivering cycle improvements or parking. Road Safety Audits should
                        be carried out wherever there is a permanent change to the highway network, which will help improve safety for all
                        users and mitigate the risks of road danger.
                        The policy wording at T2 sub-section C has improved significantly following our previous comments. Thank you.
                        However, for clarity, we suggest one final minor amendment: ‘The use of shared space to jointly meet the needs of
                        motorised traffic, walking and cycling will be resisted where it involves a single uniformly flat surface.’
                        Policy T2 E (ii) should also state that cycle storage and parking should also be highly visible in addition to safe and     N, 236
Policy T2   203
                        convenient.
                        We again request the wording ‘highly visible’ so the policy wording should be amended to: ‘Cyclist entrances to
                        buildings, cycle stores and parking must be highly visible, safe and convenient for all…’
                        Policy T2 E could include policy lines on supporting cycle hire development where extra demand exists. Additional text      N, 236
Policy T2   205         could also state that increased provision of cycle hire could support greater densities across the borough. Text should
                        also clarify that new cycle hire provision should be in addition to and not in lieu of cycle parking.
                        No reference to the TfL Cycle Hire network has been added. Please consider adding a sub-section, as follows: ’E.
                        (v) supporting the maintenance and expansion of the TfL Cycle Hire network, at a level proportionate to the size of the
                        development’ This would align with the critique of dockless bikes sometimes causing street clutter at Paragraph
                        7.20.
                        Section 7.2 - Proposals for new development should be supported by a Transport Assessment, developed using the              N, 234
                        latest TfL Best Practice Guidance. Applications for large developments with significant transport impacts should also
Policy T1   200 - 201   be accompanied by a Travel Plan, Construction Logistics Plan, Delivery and Servicing Plan, and Parking Design and
                        Management Plan in accordance with TfL guidance. The Council and TfL will define whether transport impacts are
                        significant or not.
                        No outstanding comments or issues except to request that this URL is used for all links to TfL guidance on TAs,
                        Travel Plans, etc: https://tfl.gov.uk/info-for/urban-planning-and-construction/guidance-for-applicants

                                                                          12
The Mayor’s Transport Strategy (MTS) target for 80% of all journeys to be made by on foot, cycle and public transport           N, 233
                   by 2041 should be included up front and referenced in appropriate policies, such as Policy T1D. The Mayor recognises
Policy T1    200   Islington’s potential to achieve higher mode share targets. In order for the whole of London to achieve the strategic
                   mode share target, Islington will need 83 per cent mode of residents’ journeys to be on foot, cycle and public transport
                   mode in 2021 and 89 per cent in 2041. This could be referenced in section 7.1 or 7.6.
                   It is difficult to see how citing the exact numbers as recommended above would worsen the policy document
                   given that the qualitative principles expressed throughout it elsewhere clearly target very similar outcomes for
                   Islington. We therefore again request for the MTS targets to be added to the T1 supporting text.
                   Section 2.49 states that ‘Four sites within Angel Town Centre are safeguarded to protect land needed to build and               Y, 39
                   operate Crossrail 2, including land for the Crossrail 2 station itself. These sites are shown in Figure 2.5.’ It is suggested   N, 40
                   that the text is amended to state: ‘A number of sites within Angel Town Centre are safeguarded to protect land needed
Policy SP4   27
                   to build and operate Crossrail 2, including land for the Crossrail 2 station itself. These sites are included within the Site
                   Allocations shown on Figure 2.5.’ This section also states that Crossrail 2 ‘will not be delivered until the end of the plan
                   period at the earliest’. We suggest this is rephrased, as: ‘Crossrail 2 is due to open in the 2030s’.
                   Paragraph 2.52 still states that Crossrail 2 ‘will not be delivered until the end of the plan period at the earliest’. We
                   therefore again suggest this is rephrased, as: ‘Crossrail 2 is due to open in the 2030s’.
Chapter 2:         Paragraph 2.3 acknowledges that parts of Islington not covered by a spatial strategy area will still experience                 N, 23
Area               development and change over the plan period. Reference could be made here to joint working between the London
             13
Spatial            Boroughs of Islington and Hackney in the east of Islington, adjacent to Dalston, given the significant growth and
Strategies         change which Dalston will be subject to over the next 10-15 years, including the planned Crossrail 2 station at Dalston.
                   Paragraph 2.4, now on page 23, remains negatively worded despite now acknowledging the need for joint
                   working with Hackney in relation to Dalston town centre and other areas. Specifically, TfL requests this
                   amendment:
                   ‘Some parts of Islington, particularly those areas adjacent to the borough boundary, may experience change by virtue of
                   significant development in other boroughs. Islington is committed to working with other boroughs and relevant
                   stakeholders to deliver such development while preventing/mitigating impacts for both Islington residents and businesses
                   and other Londoners and the rest of London. Of particular relevance is joint working with the London Boroughs of Hackney
                   (with regard to Dalston Town Centre, Finsbury Park Town Centre and the City Fringe/Shoreditch area), Camden (with
                   regard to King’s Cross) and Haringey (with regard to Finsbury Park Town Centre).’
                   Reference to the Healthy Streets Wheel (in Appendix C) in section 7.8 will help explain the Healthy Streets Approach            N, 235
Policy T1    202
                   (NB Approach should be capitalised).

                                                                       13
Please use a capital ‘A’ for approach and cross-reference the Healthy Streets wheel diagram as previously
                   requested.
                   Policy T2B should include reference to appropriate design guidance such as the London Cycling Design Standards             Y/N, 235
Policy T2    203
                   (LCDS) and Healthy Streets Approach.
                   It would be appreciated if TfL could be explicitly referenced in the policy wording so: ‘relevant guidance and/or best
                   practice standards, especially by TfL’ or ‘relevant TfL guidance and/or best practice standards’
                   We agree with the statement in Policy H1 C that ‘high quality new homes are integral to achieving the aim of making the    N, 63
                   most efficient use and land and improving quality of life of residents.’ We would welcome acknowledgement that
Policy H1    45    Crossrail 2 offers a significant opportunity to unlock development capacity by the provision of a Crossrail 2 station at
                   Angel, which will improve transport connectivity and capacity; this would fit well within the supporting text for Policy
                   H1 C.
                   Not a significant strategic concern outstanding for TfL in relation to this Reg 19 draft.
                   G - Improvements to Archway station are supported, including entrance level accessibility improvements and provision       N, 53
Policy SP7   38
                   of active frontages if viable, but this would have to be done using funding from third party sources.
                   I don’t see what appropriate language the Council could add to this planning policy to make clear funding should
                   come from third party sources rather than TfL.
                   Policy SP8 B - Opportunities to improve/redevelop on top of Highbury & Islington station possibly could be considered      N, 58
                   in the long term as long as this has no adverse impact on the operation and aesthetics of the station. However, it is
Policy SP8   42
                   important to note that this has been explored several times previously by Network Rail (who own most of the street
                   level infrastructure) but dismissed because of poor commercial viability.
                   As above. Unclear what should have been changed specifically to address this comment.
Vision and         Objective 3 – section 1.35 should specifically reference Vision Zero to strengthen objective 3 -Safety – Creating a safe   Y, 12
             6
Objectives         and cohesive borough for all.
Policy SP2   15    F – Reference to improving bus journey time and bus priority should specifically be made in this policy.                   Y, 27
Policy SP4   26    Reference to improving bus journey time and bus priority should specifically be made in this policy.                       Y, 39
                   Policy SP4 – This policy should acknowledge the opportunity to unlock development capacity in Angel Town Centre            Y, 39
                   through improved transport connectivity and capacity brought by a new Crossrail 2 station at Angel. TfL would support
Policy SP4   26
                   the development of a spatial approach, optimising the transport investment and capacity improvements brought by
                   Crossrail 2 to promote mixed use developments and reduce the need for local travel.
                   K – This policy supports the development of Crossrail 2 with a station at Angel, and this is welcomed. It is stated that   Y, 39
Policy SP4   26
                   ‘The Crossrail 2 work sites identified on Figure 2.5 are safeguarded’. However, the key to Figure 2.5 does not identify

                                                                      14
Crossrail 2 work sites. The Crossrail 2 safeguarded sites should clearly be identified and correctly referred to in the key
                  in Figure 2.5. This figure also appears to show all site allocations included in the Local Plan Site Allocations (Regulation
                  18 draft), including a number of site allocations based on both the 2015 Limits of Safeguarding and the worksite
                  allocations consulted on in the TfL Crossrail 2 2015 Consultation. It is suggested therefore that either the wording in
                  Policy SP4 K is amended to be clearer, to state that ‘Figure 2.5 shows all site allocations in Angel and Upper Street
                  including the TfL Crossrail 2 2015 Consultation work sites and the sites falling within the Crossrail 2 Safeguarding
                  Limits (March 2015)’; or that Figure 2.5 is amended to show solely the Areas of Surface Interest as set out in the 2015
                  Crossrail 2 Safeguarding Directions. Additionally, some of the Site Allocations shown on Figure 2.5 are difficult to pick
                  out, because they are overlain by other shading or layers (e.g. AUS12, AUS 6), and could usefully be made clearer.
                  Section 2.60 – TfL’s efforts to improve the road network in the area in the short to medium term are focused on the            Y, 44
                  developing Camden to Tottenham cycle route, which will also address other issues including pedestrian crossings and
Policy SP5   31   safety. In light of this, there are no current projects seeking to remove the Nag’s Head gyratory. We also have concerns
                  that wider street planting may not be suitable for Seven Sisters Road in the long term given engineering concerns and
                  the demand on pedestrian space.
                  Sub-section J of Policy SP5 now states the gyratory system ‘will be removed if feasible in the long term’
                  J- In Policy SP6 J, (and in 2.73 on page 36) it is stated that Finsbury Park is the busiest transport interchange in London    Y, 44
                  outside zone 1. However, we believe that Stratford is significantly busier. This reference should therefore be removed
Policy SP6   33
                  or clarified. Greater clarification for ‘enhancement/redevelopment of the station’ should be provided. A complete
                  redevelopment of Finsbury Park tube station is unrealistic given the engineering constraints.

                  Section 2.74 – As mentioned in the comment to Policy SP6 above, it is unclear what further improvements the council            Y, 49
Policy SP6   36   is envisaging. ‘The complete redevelopment’ referenced in section 2.74 is unrealistic given the engineering constraints.
                  This reference should therefore be removed or a more realistic option clarified.
                  Sub-section J of Policy SP6 now states Finsbury Park is ‘one of the busiest transport interchanges in London outside
                  Zone 1’ and improvements are more clearly defined as ‘further improvements to make the station fit for purpose; this
                  should include fully step-free access’ with ‘explore options for intensification of development above the station.’ Thank
                  you.
                  Policy SP8 should reference the proposed creation of a new entrance to Highbury & Islington station on the eastern             Y, 58
Policy SP8   42   side of Holloway Road, which would amongst other things provide step-free access to the deep level platforms. This is
                  mentioned in the Site Allocations document under HC1.

                                                                     15
Policy R1 L should be amended to read: “…The Council will work with partners to support and manage a thriving and           Y, 131
Policy R1   108
                      safe night time economy that is well-served by safe and convenient sustainable night-time transport.”
                      Note: now Policy R1 sub-section M
                      Section 7.4 – We support the cycling improvements discussed in this section, but recognition of the importance of bus       Y, 234
Policy T1   201
                      services as an accessible mode should also be reflected.
                      Section 7.7 – reference is made to the contribution of car-based on-demand mobility apps increasing the number of           Y, 234
Policy T1   201-202   motor vehicles on London’s roads, but wording should suggest how the rise of app-based on-demand mobility will be
                      controlled.
Policy T2   203       Policy T2 F (i) – We are supportive of the measures to improve bus priority over other vehicles.                            n/a
                      Add further policy guidelines in Policy T2 F to ensure public transport access, capacity and interchange improvements.      Y, 236
                      Another bullet could be added such as “Ensure network infrastructure and service improvements increase access
Policy T2   203-204
                      (including step free access), capacity and public transport interchange improvements to local bus, rail and tube
                      stations.”
Policy T2   204       Section 7.13 - Pedestrian crossings should also be designed in line with pedestrian desire lines                            Y, 237
                      Section 7.14 - Wording should clarify that cycle infrastructure should be segregated from the main carriageway in order     Y, 237
                      to prioritise road space for cyclists, in addition to the promotion of quieter and safer routes and to encourage more
Policy T2   204       people to cycle in the future. Care should be taken to ensure that any routes to be used by both cyclists and walkers are
                      fit for purpose and designed to appropriate standards as set out in design guidance including the London Cycling
                      Design Standards (LCDS) and Healthy Streets Approach.
                      Section 7.15 - Wording should also be provided given that the Mayor has announced that TfL will deliver the Camden to       Y, 237
                      Tottenham Hale cycle route. Text should also note that new developments should not preclude the delivery of cycle
                      infrastructure improvements, particularly along corridors identified as part of TfL’s Strategic Cycle Network. Stronger
                      Wording could be amended to:
                      “The council supports cycling infrastructure improvements that adhere to guiding principles and achieve the good
                      design outcomes set out in the London Cycling Design Standards. Transport for London’s Strategic Cycling Analysis
Policy T2   205
                      (SCA) 2017 has identified Kentish Town to Wood Green via Archway going up Junction Road, and Camden Town to
                      Tottenham Hale via Nag’s Head on Seven Sisters Road as two of their top priority cycling connection routes with the
                      greatest potential to serve people who currently cycle, and to enable more people to cycle in the borough. for shifting
                      journeys towards cycling. In January 2018 the Mayor of London announced the development of six new cycling routes,
                      one of them being Camden to Tottenham Hale. Islington will continue to collaborate with TfL to design and deliver this
                      new route and plan opportunities progress Kentish Town to Wood Green. Furthermore, new developments should not

                                                                        16
preclude the delivery of cycle infrastructure improvements, particularly along corridors identified as part of TfL’s
                   Strategic Cycle Network or which have the potential to feed this network.”
Policy T2    205   Section 7.16 - Wording should be expanded to ensure, safe, accessible and step free public transport interchange.           Y, 238
                   The last sentence in section 7.17 should state cycle parking provision and recognise that higher minimum standards          Y, 238
                   may be appropriate in parts of the borough and around larger developments that need to support current and future
Policy T2    205
                   levels of cycling. Wording for last sentence in section 7.17 should read ‘Cycle Parking provision (including visitor
                   parking) must meet or exceed the minimum cycle parking standards in Appendix 4’.
                   Policy T3D – an additional point should be added stating that essential operational parking should also not impede          Y, 239
Policy T3    206
                   pedestrian and cycle movements
                   Policy T3 F – Coach parking should also not be located directly outside the main entrance of developments and should        Y, 239
Policy T3    206
                   not be at the expense of space provided to active travel and buses.
Policy T4    209   Policy T4 A (i) should be expanded to “Is permeable and legible, designed in line with pedestrian and cycle desire lines”   Y, 242
Policy T4    209   Typo in section 7.29 “Development proposals must provide…”                                                                  Y, 243
                   Note: now para 7.32
                   Requirement for Construction Logistic Plans (CLP) should be mentioned in addition to the requirement for Delivery           Y, 246
                   Service Plans (DSP). For applications with significant transport impacts a two-stage CLP in TfL’s recommended format
Policy T5    211
                   is required. The Outline CLP should be provided prior to determination and the Detailed CLP should be secured by
                   condition and discharged prior to commencement.
                   This text seems to have been added at Paragraph 7.50, and Policy T5. The policy therefore now matches sub-
                   section F of Policy T7 (Deliveries, servicing and construction) of the draft London Plan, which is welcome.
                   Reference to the use of TRAVL (Trip Rate Assessment Valid for London) should be removed as this is out of date and          Y
Policy T5    212
                   not relevant to specific policy
                   Table 8.1 should note that Caledonian Road station is Grade II listed and would be unlikely to be able to support a large   N, 266
Policy DH3   225
                   - scale development above without demolition.
                   Whilst the specific edit requested above has not been made, the Council is clearly likely to consider the listed
                   status of the station carefully if a tall building is proposed based on other policies and text elsewhere in the plan
                   and other adopted local policy documents.
                   Stronger wording for on-street location of telecommunications boxes and other utilities equipment is required. Policy       N, 282
                   in ST3 A should be amended to include the following bullet points:
Policy ST3   240
                        • they will be frequently used for their primary purpose, communications, by a large number of people in order
                            to make best use of valuable public space

                                                                     17
•    they do not include advertising or lighting that would cause a detraction/danger to motorists, cyclists or
                                      pedestrians
                             As the above suggestion has not been taken on board, can the following text please be added to ST3 sub-section
                             C: ‘Applications for mobile phone network development must demonstrate that they have followed and are in accordance
                             with the Code of Best Practice on Mobile Network Development in England or subsequent similar guidance, and the latest
                             TfL Streets toolkit guidance.’

Table 2: Site Allocations

                                                                                                                                                      Resolved?,
              Reg 18
  Section                   Previous Track change/comment, now with further TfL feedback below                                                        Reg 19
              page Ref
                                                                                                                                                      page Ref
                            TfL is aware of Islington’s long-term aspiration to see a Piccadilly line station opening from the former York Road       Y, 22
                            Piccadilly line tube station and the complementary development of York Road Station, but this is not something
  KC4         12
                            that TfL are progressing at this time. We would therefore not support this and reference to this scheme should be
                            removed.
                            The text on ‘site designations and constraints’ for VR6 incorrectly indicates that the allocation is close to or within   Y, 36
  VR6         22
                            the Crossrail 2 safeguarding area. Text referring to the Crossrail 2 safeguarding area should be removed.
                            Transport investment and capacity improvements brought by Crossrail 2 should be optimised on this site. The               Y, 46
                            promotion of mixed use developments in areas of high Public Transport Access Levels (PTAL) would help reduce
  AUS2        30
                            the need for local travel. It is suggested that this is acknowledged in the ‘allocation and justification’ text for the
                            allocations close to Angel Station, including AUS2 (Pride Court, 80-82 White Lion Street).
                            An element of residential uses can support intensified business and town centre uses, and form part of a sustainable      Y, 48
                            and efficient land use mix in locations with high public transport accessibility. It is suggested that this is
  AUS3        31
                            acknowledged in the ‘allocation and justification’ text for the allocations close to Angel Station, including AUS3
                            (Electricity Substation, 84-89 White Lion Street).
                            The site allocation clearly specifies that liaison with Crossrail 2 is required at an early stage, which is welcome.
                            Mixed use development proposals including residential floorspace are already emerging in this area now, for
                            example P2019/2650/FUL for the neighbouring site 80-82 White Lion Street, which includes six new residential
                            units. No further comments at this stage.

                                                                                18
Transport investment and capacity improvements brought by Crossrail 2 should be optimised on this site. The               Y, 50
                promotion of mixed use developments in areas of high PTAL would help reduce the need for local travel. It is
AUS4    32
                suggested that this is acknowledged in the ‘allocation and justification’ text for the allocations close to Angel
                Station, including AUS4 (Land at 90-92 White Lion Street).
                As above.
                Transport investment and capacity improvements brought by Crossrail 2 should be optimised on this site. The               Y, 52
                promotion of mixed use developments in areas of high PTAL would help reduce the need for local travel. It is
AUS5    33
                suggested that this is acknowledged in the ‘allocation and justification’ text for the allocations close to Angel
                Station, including AUS5 (4 White Lion Street, BSG House).
                As above.
                Transport investment and capacity improvements brought by Crossrail 2 should be optimised on this site. The               Y, 56
                promotion of mixed use developments in areas of high PTAL would help reduce the need for local travel. It is
AUS7    36/37   suggested that this is acknowledged in the ‘allocation and justification’ text for the allocations close to Angel
                Station, including AUS7 (1-7 Torrens Street). It should also be noted that Old Angel station building contains
                essential power and other equipment which would presumably be very difficult and expensive to relocate.
                As above.
                It is stated that AUS16 (Angel Square) was identified through Crossrail 2 proposals for Angel. This site has not been     Y, 70
                identified by Crossrail 2. The site should therefore either be removed from the Site Allocations or the reference that
AUS16   48
                the site was identified by Crossrail 2 should be removed. The site does fall within the Crossrail 2 safeguarding limits
                (March 2015), as previously stated.
                Transport investment and capacity improvements brought by Crossrail 2 should be optimised on this site. The               Y, 70
                promotion of mixed use developments in areas of high PTAL would help reduce the need for local travel. It is
AUS16   48
                suggested that this is acknowledged in the ‘allocation and justification’ text for the allocations close to Angel
                Station, including AUS16 (Angel Square)
                As above.
                Transport investment and capacity improvements brought by Crossrail 2 should be optimised on this site. The               Y, 44
                promotion of mixed use developments in areas of high PTAL would help reduce the need for local travel. It is
AUS18   51/52
                suggested that this is acknowledged in the ‘allocation and justification’ text for the allocations close to Angel
                Station, including AUS18 (Royal Bank of Scotland).
                Note: this is now A1. Comments again as above.

                                                                    19
The text on ‘site designations and constraints’ for FP1 incorrectly indicates that the allocation is close to or within    Y, 97
FP1     75
                  the Crossrail 2 safeguarding area. Text referring to the Crossrail 2 safeguarding area should be removed.
                  The text on ‘site designations and constraints’ for FP2 incorrectly indicates that the allocation is close to or within    Y, 99
FP2     77
                  the Crossrail 2 safeguarding area. Text referring to the Crossrail 2 safeguarding area should be removed.
                  A complete redevelopment of Finsbury Park tube station is unrealistic given the engineering constraints. The text          Y, 101
FP3     78        on ‘site designations and constraints’ for FP3 incorrectly indicates that the allocation is close to or within the
                  Crossrail 2 safeguarding area. Text referring to the Crossrail 2 safeguarding area should be removed.

                  The site allocation now states that ‘Development above the railway station is a long term ambition’ which is
                  welcome. The Crossrail 2 safeguarding text has also been removed.

                  The text on ‘site designations and constraints’ for FP8 incorrectly indicates that the allocation is close to or within
FP8     84                                                                                                                                   Y, 108
                  the Crossrail 2 safeguarding area. Text referring to the Crossrail 2 safeguarding area should be removed.
                  The text on ‘site designations and constraints’ for FP9 incorrectly indicates that the allocation is close to or within
FP9     85                                                                                                                                   Y, 109
                  the Crossrail 2 safeguarding area. Text referring to the Crossrail 2 safeguarding area should be removed.
                  The text on ‘site designations and constraints’ for FP10 incorrectly indicates that the allocation is close to or within
FP10    87                                                                                                                                   Y, 111
                  the Crossrail 2 safeguarding area. Text referring to the Crossrail 2 safeguarding area should be removed.
                  Timescales seem optimistic for HC1, especially as discussions with the landowner have ceased in recent months. It
                                                                                                                                             Y, 137
HC1     109       should also be noted that the red line boundary does not encompass the old station building, which should be
                  amended.
                  Whilst it appears that the timescale has not been amended, we presume the Council has noted our previous
                  advice. The red line boundary also now includes the station building, which is welcome.
                  Opportunities to improve/redevelop on top of Highbury & Islington station possibly could be considered in the long
                                                                                                                                             Y, 140-141
                  term as long as this has no adverse impact on the operation and aesthetics of the station. However, it is important
HC3     117
                  to note that this has been explored several times previously by Network Rail (who own most of the street level
                  infrastructure) but dismissed because of poor commercial viability.
                  The timescale for this site allocation is 2031/32-2035/36 and the wording is clear that the station will be
                  retained, which is satisfactory.
                  It should be noted that Caledonian Road station is Grade II listed and would be unlikely to be able to support a large-    Y, 170-171
OIS21   138/139
                  scale development above without demolition.
                  This site allocation clearly specifies that the station is a Grade II listed building, which is welcome. Thank you.

                                                                       20
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