/ Local Plan Partial Review
Publication Policies
Consultation Response Form
February 2017

This consultation is open for 6 weeks from

Thursday 2 February to 11:59 pm on Thursday 16 March 2017

The Council prefers to receive your consultation responses on-line,

however, you may also respond by email or post using the details below.

On-line (preferred) /
or via
Email /
Please state ‘Consultation Response – Local Plan Partial Review Publication Policies’ in the subject line
Post / Planning Policy Team
Planning and Borough Development
Royal Borough of Kensington and Chelsea
Kensington Town Hall
Hornton Street
London W8 7NX

Consultation responses, will be made public as part of subsequent stages of the Local Plan Partial Review. Please clearly identify any information provided which is commercially sensitive and/or you would like to be kept confidential.

Following this ‘Publication Policies’ consultation, the next stage of the Local Plan Partial Review involves ‘Submission’ of the documents by the Council to the Planning Inspectorate which acts on behalf of the Secretary of State to undertake an independent examination of the policies.

There will not normally be a subsequent opportunity to make further representations based on the original representation at this ‘Publication Policies’ stage. After this ‘Publication Policies’ stage, further submissions will only be at the request of the Inspector, based on the matters he/she identifies for examination.

Where there are groups who share a common view on how they wish to see a plan modified, the Planning Inspectorate advises it would be very helpful for that group to send a single representation which represents the view, rather than for a large number of individuals to send in separate representations which repeat the same points. In such cases the group should indicate how many people it is representing and how the representation has been authorised.

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Advice on the ‘tests of soundness’

This ‘Publication Policies’ stage of the Local Plan Partial Review is largely concerned with whether the policies satisfy the “tests of soundness”.

To be “sound” the contents of a Local Plan should be positively prepared, justified, effective and consistent with national policy, as set out in paragraph 182 of the National Planning Policy Framework (NPPF):

“Positively prepared”means that the Local Plan needs to:

  • be prepared based on a strategy which seeks to meet objectivelyassessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

“Justified”means that the Local Plan must be:

  • the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence

“Effective”means that the Local Plan must be:

  • deliverable over its period and based on effective joint working on cross-boundary strategic priorities

“Consistent with National Policy”means that the Local Plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework

It must also be legally compliantwhich means that the Local Plan has been prepared in accordance with legal and procedural requirements.

The Planning Inspectorate advises that if you think the content of the plan is not sound because it does not include a policy where it should do, you should go through the following steps before making representations:

  • Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan)? If so it does not need to be included?
  • Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan?
  • If the policy is not covered elsewhere, in what way is the plan unsound without the policy?
  • If the plan is unsound without the policy, what should the policy say?

Advice on legal compliance

The Planning Inspectorate advises you should consider the following before making a representation on legal compliance:

  • The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed. The LDS is effectively a programme of work prepared by the Council, setting out the Local Development Documents (LDDs) it proposes to produce. It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination. If the plan is not in the current LDS it should not have been published for representations. The LDS should be on the LPA’s website and available at its main offices.
  • The process of community involvement for the plan in question should be in general accordance with the Council’s Statement of Community Involvement (SCI) (where one exists). The SCI sets out the Council’s strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications.
  • The plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations). On publication, the LPA must publish the documents prescribed in the Regulations, and make them available at its principal offices and on its website. The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified.
  • The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan. This should identify the process by which the Sustainability Appraisal has been carried out, and the baseline information used to inform the process and the outcomes of that process. Sustainability Appraisal is a tool for appraising policies to ensure they reflect social, environmental, and economic factors.
  • In London, the plan should be in general conformity with the London Plan (the Spatial Development Strategy).

Advice on the Duty to Cooperate

The Planning Inspectorate advises you should consider the following before making a representation on the Duty to Cooperate:

  • The Duty to Cooperate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance. Councils will be expected to provide evidence of how they have complied with any requirements arising from the Duty.
  • The Planning and Compulsory Purchase Act 2004 establishes that non-compliance with the Duty to Cooperate cannot be rectified after the submission of the plan. Therefore the Inspector has no power to recommend modifications in this regard. Where the Duty has not been complied with, the Inspector has no choice but to recommend non-adoption of the plan.

The Council advises that the Duty to Cooperate relates only to the following organisations:

  • Environment Agency
  • Historic England
  • Natural England
  • Mayor of London/ Homes and Communities Agency (HCA)
  • Civil Aviation Authority (CAA)
  • West London Clinical Commissioning Group (WL CCG)
  • NHS England
  • Office of Rail Regulation (ORR)
  • Transport for London (TfL)
  • Integrated Transport Authorities
  • Highway Authorities
  • Marine Management Organisation (MMO)
  • London Enterprise Panel (LEP) / London Economic Action Partnership (LEAP)
  • Local Nature Partnership
  • Neighbouring and other Local Planning Authorities (LPAs)

Chapter 3: Building on Success: Our Vision and Strategic Objectives

3.1 Vision

CV1 Vision for the Royal Borough: Building on Success

Question CV1

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

3.2 Strategic Objectives

CO1 Keeping Life Local

Question CO1

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CO2 Fostering Vitality

Question CO2

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CO3 Better Travel Choices

Question CO3

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CO4 An Engaging Public Realm

Question CO4

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CO5 Renewing the Legacy

Question CO5

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CO6 Diversity of Housing

Question CO6

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CO7 Respecting Environmental Limits

Question CO7

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

Chapter 4: Delivering Success: Our Spatial Strategy

4.2 Broad Quanta of Development

CP1 Core Policy: Quanta of Development

Question CP1

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

4.5 Place shaping

CP2 Places

Question CP2

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

Chapter 5: Kensal

Kensal Place

CV5 Vision for Kensal

Question CV5

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CA1 Kensal Canalside Opportunity Area

Question CA1

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CA2 Barlby-Treverton

Question CA2

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this?

(Please be as precise as possible, with reference to paragraph and policy numbers)

Chapter 6: Golborne

Golborne Place

CV6 Vision for Golborne

Question CV6

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CA3 Wornington Green

Question CA3

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CA4 Land adjacent to Trellick Tower

Question CA4

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

Chapter 7: Latimer

Latimer Place

CV7 Vision for Latimer

Question CV7

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CA5 Silchester Estates

Question CA5

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

Chapter 8: Earl’s Court

Earl’s Court Place

CV8 Earl’s Court

Question CV8

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CA6 Earl’s Court Exhibition Centre

Question CA6

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CA7 Warwick Road Sites

Question CA7

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CA8 Warwick Road Estate

Question CA8

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

Chapter 9: Lots Road and World’s End

Lots Road and World’s End Place

CV9 Vision for Lots Road/World’s End

Question CV9

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)

CA9 Lots Road Power Station

Question CA9

Do you consider this policy to be…

Sound / Unsound
Positively prepared? / /
Justified? / /
Effective? / /
Consistent with national policy? / /
Yes / No
Legally compliant? / /
In accordance with the Duty to Cooperate? / /

What are your reasons for this? What changes would you like made to address this? (Please be as precise as possible, with reference to paragraph and policy numbers)