Questions from Local Plan virtual events

A full report of the events and the comments made during the workshops will be published in due course, alongside all the comments we receive on the Pre-Publication Draft Local Plan.

Questions from the events

These are some of the commonly asked questions/areas of interest that were raised or officers took away from the events, with details of initial officer responses.

What happens if there is a change of leadership at the local election?

Any new administration would review the draft Local Plan. In Richmond, the parties have worked informally on a cross-party basis in developing the draft Plan. Local Plans are always prepared over a long time period, where there can be changes. The wider context for some aspects of the plan will still be the same, even if the political context changes, for example the requirements of national policy and the London Plan 2021, which we are working within.

How will the Community Infrastructure Levy (CIL) money be spent? How can the community feed into this process?

An annual Infrastructure Funding Statement now sets out what infrastructure will or may be funded from CIL. As part of the emerging new Local Plan, we will update the existing Infrastructure Delivery Plan, which will include updated recommendations on what funding streams may be used to fund infrastructure items. More about CIL.

A percentage of CIL funding is spent locally, through the Community Fund, which is allocated to spend on local priorities which address the demand that development places on an area. The launch of the fifth round of the Community Fund is expected to be in the autumn of 2022.

How do we work with other teams, particularly the Council’s policy team on climate change?

We work with many other teams who provide feedback and help us shape the emerging plan at several stages. The draft Local Plan reflects our priorities set out in other strategies, including the Climate Emergency Strategy.

How much of a priority is increase of housing supply?

Housing provision, particularly affordable housing, is a big priority that is already reflected in the adopted Local Plan (2018) and by the London Plan in terms of looking to increase delivery of affordable homes. We already know there is a lot of support for affordable housing, particularly of the right type such as for affordable rent. Small sites development is not easy but is a vital way to unlock development potential across the borough and may help deliver more homes. We welcome feedback on this.

Key housing policies in the draft plan:

• Site allocations including several brought forward from the current local plan and the Twickenham area action plan, including 8 new potential sites
• Policy 11 (affordable housing) states that all new development should provide at least 50% affordable housing. We are trying to make it even clearer what is expected of new development, and to enable us to be robust and challenge viability
• Policy 16 (small sites) highlights the importance of small sites intensification
• Policy 49 also includes a new route to make it easier for affordable housing to be brought forward on redundant social infrastructure sites

Given the challenges with the climate crisis, how much do you support householders to improve energy efficiency and renewable energy, particularly in conservation areas?

In an area with so many conversation areas and heritage buildings like Richmond borough, this is certainly a tricky balance and needs to be reviewed on a case-by-case basis. Policy 29 in the draft Local Plan on designated heritage assets sets out at part F that sympathetic measures to make energy and carbon savings in historic and listed buildings are encouraged, by adopting a ‘whole house approach’ and understanding all the factors that affect energy use.

However, it is clear that any potential damages to the structure or heritage value, or impacting the setting of, historic buildings have to be avoided. Each proposal will be assessed on a case-by-case basis, and depending on the significance of an asset, different levels of change may be appropriate in different types of buildings.

How are insulation requirements taken into account in design. Where is that required?

In a general sense, the draft Local Plan considers energy, as good insulation will help towards lowering a home’s operational energy. Many new development proposals will need to submit an Energy Strategy as set out in Policy 4 to demonstrate how emissions savings have been maximised. Policy 6 on Sustainable construction standards sets out that new developments will be required to achieve the highest standards of sustainable design and construction. Part B of Policy 6 requires compliance with relevant fabric energy efficiency targets, which are considered essential in reducing carbon emissions.

The Local Plan therefore adopts a ’fabric first’ approach to building design, aimed at minimising the need for energy consumption through methods such as the use of super-high insulation, maximising air-tightness, optimising solar gain and natural ventilation etc.

In addition, Policy 3, part D also sets out that we will work with partners and local communities to improve the energy efficiency of the existing building stock and wider public realm, with a particular focus on increasing energy efficiency of homes and businesses, especially improved insulation in lofts, walls and floors. The Local Plan requirements will be applicable to future planning applications, once it is adopted.

There will also be work by architects/developers, and other related areas such as review and updates of the national Building Regulations, and other actions around climate change that will relate to insulation.

Can you outline plans to improve road and cycling safety, and how much influence does the Council have to make sure roads managed by Transport for London are pothole free?

Improvements can be delivered through new development, and there is an emphasis on active travel and making walking and cycling the first choice for shorter journeys particularly in the area strategies for each part of the borough. The Local Plan reflects the Active Travel Strategy. In terms of specific improvement schemes and other projects, it is the Highways team and/or Transport for London (TfL) who are responsible. In those situations, we would work with them as needed to deal with any issues.

Key active travel policies in the draft plan:

• Policy 1 (living locally) 20-minute neighbourhoods, enhance opportunities for walking and cycling safely
• Policy 34 (green and blue infrastructure) walking and cycling routes to and through the green infrastructure network
• Policy 46 (sustainable travel choices) a high quality walking and cycling environment

How does the draft Plan intend to create safe spaces at night?

This is something we will be reviewing. Policy 28 looks for the design of new development to minimise opportunities for crime and antisocial behaviour, including looking at natural surveillance and orientation of buildings as well as uses. Policies around the town and local centres also consider the public realm and managing impacts such as safety measures (Policies 17, 18 and 19). Policy 43 on floodlighting and other external artificial lighting refers to the positive benefit for safety of movement.

There are also plans to consider a night-time strategy in Richmond that looks holistically at issues such as transport, design of places at night, licencing and opening times, and improving safety lighting.

How can planning control design quality?

We have several methods to shape the kinds of planning applications we receive. This includes a requirement for a design and access statement that looks at site constraints and context. Developers must also show the design is in keeping with the various guidance documents that we have produced, such as the detailed advice contained within the Urban Design Study (2021) and where applicable in conservation area appraisals.

There is also the National Design Guide, which sets out the characteristics of well-designed places and demonstrates what good design means in practice. Before larger-scale proposals are submitted to us, we use the Richmond Design Review Panel, which is an independent body comprising of architects, urban designers, landscape architects, engineers, transport planners, heritage experts and other design related professionals. The panel will review proposals and provide feedback with a view to raising the architectural quality of proposals.

Policy 44 in the draft Local Plan is all about the design process. It encourages for example design codes for larger sites. Proposals will also need to be sufficiently detailed to keep quality and delivery to London Plan standards.

Does the living locally policy consider childcare provision or other services, and how will polices interact with things that are more statutory?

It is appropriate to think about childcare provision, especially within the context of the post-pandemic recovery and working from home. This also connects to our Education and Training Policy 50, and we are collaborating with Achieving for Children (who provide children’s services in the borough). Use-class changes from central government might allow for more flexibility on uses, but also make it harder to protect them and give us less control as a Council. Our job as planners is to monitor these issues in real life and make sure policies reflect changing need.

What plans do you have to provide safe and integrated communities? Are there aspirations for community buildings?

Community buildings and other specific building types would be required at certain levels of development or densities. Details are in Policy 49 of the draft Local Plan on Social and Community Infrastructure. Community buildings and other services can be encouraged, and some site allocations suggest community uses, but these are not directly provided by the
Plan, and delivery of such infrastructure is often dependent on other service providers outside of the Council, who we work in partnership with.

What about providing defibrillator phone boxes?

There can be some creative uses of these small spaces to preserve the iconic phone boxes, particularly for community benefits, and we expect there would be support for this medical use - we understand there is already a community defibrillator in a phone box near Barnes Green. Some phone boxes may be statutorily listed and within designated Conservation Areas, and therefore planning permission may be needed for a change of use and any alterations that consist of development.

There may need to be consideration of impacts on amenity and the surrounding highways. Therefore assessments would be made on a case by case basis.

How much power does the Local Plan have to manage larger developments that would overwhelm local services in terms of population numbers?

The existing Local Plan requires the potential impacts on infrastructure from development proposals for 10 or more residential units to be assessed, to demonstrate that there is sufficient capacity within the existing infrastructure to accommodate the needs arising from the new development.

We recognise new development is likely to put an additional burden on existing facilities particularly on education and health infrastructure. This is also set out in the draft Plan at Policy 49 part F. It may be that mitigation measures can be put in place, either through financial contributions or where appropriate securing on-site provision of community facilities.

In terms of the overall impact of what is envisaged in the draft Local Plan, we will also be preparing this year an update to the Council’s current Infrastructure Delivery Plan, which identifies future infrastructure and service needs for the borough.

For larger developments, is there any way that provision of on-site space for e.g. doctors, schools, older people’s facilities can be made affordable, as I understand that some developers make the rental off-putting and after some time are allowed to convert the space to a residential unit?

We would not want to see vacant community spaces, although sometimes needs or opportunities can change. Any community benefits that are necessary as part of the development should be secured through a planning permission and/or a planning obligation.

It may be possible to include details around the rent and terms to ensure a unit can be occupied, for example we may seek full fit out of premises (beyond shell and core) to ensure it is fit for purpose. If a future change of use is proposed, we would look at the details including the marketing that has been undertaken satisfactorily, and Appendix 2 of the draft Local Plan sets out the details that should be provided.

Is there scope in the Local Plan to talk about pedestrianisation/bus only areas of the borough?

Yes, although these types of schemes would be led by the Highways teams. The place-based strategies in the draft Plan suggest some opportunities to improve the pedestrian experience and provide space for dwelling, hospitality or events, and we welcome your comments.

Useful links

• Mayor of London’s Cultural Infrastructure Map
• Culture Rich 2021-2031