Wandsworth Planning Policy Consultations: Update
The Planning Committee has submitted responses to drafts of two Supplementary Planning Documents (SPDs) issued by the Council. The first relates to Planning Obligations, the second to Trees and Development. Our colleagues in the Open Spaces Committee have also submitted comments, and in addition comments on a third draft SPD, on Biodiversity.
The Planning Obligations draft SPD covers ‘s106 agreements’, legal agreements between planning authorities to mitigate the impact of a development on the local community and infrastructure by securing obligations such as financial contributions or the provision of infrastructure like affordable housing, transport, and community facilities. In the current case the draft covers all the policies in the Local Plan, except housing, which will be dealt with separately, once the current review of the Local Plan is completed.
Our response to the draft is as follows
The Battersea Society welcomes the revised SPD on Planning Obligations. With its direct links to Local Plan policies and the S106/CIL obligations which might be applied in relation to different types and scale of development, it is much clearer than the 2020 version .
However an opportunity has been lost in the current draft to tie potential support from new development to the objectives of the recently published Growth Strategy for the borough We feel it would be worth refining the draft SPD to reflect more closely the three headlines objectives in the Growth Strategy of People First, Placemaking and Inclusive Growth.
Much of the draft SPD reflects the statutory framework and the London Plan framework. In particular it provides clear guidelines for support of major infrastructure and service facilities to complement new development and reduce its impact on existing communities. However as drafted it lacks bite in relation to the softer issues of community support infrastructure. The London Plan lists community infrastructure as covering health provision, education, community, play, youth, recreation, sports, faith, and emergency facilities and it would be helpful to include this list in the preface to section 7 as the framework for planning obligation support for local communities. To meet the Council's objectives in the growth strategy for sustaining sociable communities that maximise well being and quality of life, planning obligations offer the opportunity to support the subtler elements of placemaking. Relatively small injections of s106 support, which may involve partnership with developers and private and voluntary service providers, can hugely increase a sense of local pride and belonging. The type of facility which this might cover includes libraries, public toilets, benches and sitting areas, community pharmacies and greater access to swimming pools and gyms. This may appear over-detailed but would complement the specific guidance in some other sections including for example Arts and Culture.
The Trees and Development SPD is intended to provide guidance for developers to assist them in managing and protecting trees during development. It aims to maximise the delivery and protection of trees during the planning process, in order to improve the environment, biodiversity, health and built environment throughout the borough.
Our response to the darft is as follows
Our colleagues in the Open Spaces Committee have responded in detail but we wanted to add a concern about the way the SPD is drafted. The document is intended for both professionals and householders, and it needs to be much clearer to ensure that policy is understood and complied with. But the draft is hopelessly poorly structured: it is hugely repetitive, and the attempt to structure the bulk of the document into the Pre-Application and Application Stages simply doesn't work.
A flow chart of things to be done in the pre-app stage includes things to be done in the application, the construction and the post-construction stages. Tree surveys, topographical surveys, Arboricultural Impact Assessments and Management Plans get covered in several places. Householder applications get a bare mention in the General Guidance and then are dealt with under Application Stage. A section on Legal Context is followed by a separate one later on TPOs and then another one as an Appendix (with no cross references).
We also note that the draft is substantially based around the application of British Standards, many of which are due to be revised, which will affect the longevity of the document. We suggest that it should be substantially re-written, and shortened, before it can become acceptable.