R19.0177 - Islington Council
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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: email@example.com 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
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
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 firstname.lastname@example.org. 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: email@example.com 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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