HST010 342 Rutland Group Statement Session 1a

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.