Hounslow Local Plan Examination Submission on Behalf of the Rutland Group (No.342) Session 1a re Legal, Procedural and Strategy Question 1a Rutland in their representation on the Submission Draft LP have demonstrated that the Draft Plan is not legally compliant in that it is not in general conformity with the London Plan (Further Alterations, 2014)(FALP). Rutland have demonstrated furthermore that the Plan is not sound in that it is not based on a strategy which seeks to meet objectively assessed (by the Mayor of London in the London Plan) development and infrastructure requirements i.e. it is not positively prepared. For two additional reasons Rutland consider that it is unsound to put off the planning of development in the West Area: 1. Advice in NPPF is very clear (paras 14 and 21) that change, even rapid change, during the life of a local plan is normal and must be provided for in the plan. It is not appropriate to defer consideration of the planning of a large part of the Borough to a later plan. 2. There is no certainty or even probability that the Report of the Davies Commission, which is quoted by the Council as their reason for delay, will resolve the matter of additional runway capacity in the South East: firstly the Commission is only an advisory body (the Report of itself will not therefore resolve the runway issue) and secondly there is a very long history of governments putting off decisions on what is a politically very sensitive issue. Given that the Council is determined to defer consideration of development in the West of the Borough until another plan, it is important to consider the nature of that plan. The Inspector poses question 1a: “Would both the above Plans require or include the early partial review of the Local Plan and relevant policies?” In relation to the proposed plan for the West Area Rutland is firmly of the view that it should have the status of a local plan; this might be a review of the local plan, for the following reasons: 1. NPPF makes it clear that Green Belts should only be established or their boundaries altered in local plans (para 83). The Council has committed to a review of the Green Belt in the proposed West Area Plan. 2. The Council is relying on the West Area for some 4500 additional homes in order to meet the objectively assessed requirement for housing in the Plan period (Housing Topic Paper). Meeting the objectively assessed requirement has to be demonstrated in the local plan, which would need to be altered in the light of the housing capacity revealed in the West Area Plan. 3. The Council needs to identify sites for 90,000 sq.m. of offices in order to meet the requirement identified in the Employment Land Review. Given the employment development targets for the Heathrow Area of Opportunity (an area which is likely (currently no boundaries defined) to coincide largely with the West Area within Hounslow) and the fact that an office location identified in the Local Plan (Bedfont Lakes) as a potential source of additional land for offices lies within the West Area, it is highly likely that achievement of the required amount of office floorspace will depend on development capacity identified in the West Area. That achievement will need to be demonstrated in the Local Plan which will need appropriate amendment. Rutland are of the view that the proposed plan for the West Area requires or should include the early partial review of the Local Plan and relevant policies. Question 1c Rutland have provided evidence in their Representations that, in relation to the West Area and in the context of the development targets in Further Alterations to the London Plan and of the growth to which the Local Plan is committed, the Council has not undertaken a comparative assessment of development sites and potential, but has set out the constraints to development; this has the effect of prejudging any evaluation of development potential that may be undertaken for the proposed West Area Plan. Rutland are of the view that the vision for the West Area is inconsistent with the growth aims of the Local Plan and the Heathrow Opportunity Area. Question 1d Given that the proposals for the West Area leave so much to be resolved in the future West Area Plan (review of the Green Belt, identification of sites or capacity for housing and employment development) the vision for the West Area in the Submission Draft Local Plan is correspondingly defective and would need to be subject to review as part of the West of Borough Plan. Question 1f The potential scale of change in the West Area (review of the Green Belt, identification of sites or capacity for housing and employment development) is such that further assessment as set out in the Inspector’s matters and issues at paras 1.10-1.13 is bound to be required.