STRUCTURE OF THE NEW SOUTHWARK PLAN (NSP) AND HOW TO MAKE REPRESENTATIONS

NEW SOUTHWARK PLAN (NSP) STRUCTURE

The NSP comprisesof the followingdocuments:

  • The Planis the main document at 342 pages.
  • You can download a copy here: New Southwark Plan: Proposed Submission Version(pdf, 27.2mb)
  • 11 Schedules and maps - theseidentify all thepoliciesthat are mentioned in the Plan and appear on the main NSP policies map.
  • Policies map schedules(pdf, 352kb)
  • Policies map updates(pdf, 22.8mb)
  • The schedule titles and where they are referenced in the Plan are listed in the pdf shown here:
  • 6 Annexes - these are collated in a separate document.
  • Annex 1 to 6(pdf, 8.2mb)
  • The titles of the 6 Annexes are shown in this pdf:

In addition to the NSP documentsthere are 'supporting' documents.These are not part of the NSP itself but an important part of the Council’s evidence base for justifying its plan.

  • Appendices:There are 4 appendices:
  • B Consultation plan
  • C Consultation report
  • D Integrated Impact Assessment of the plan
  • E Habitats Regulations Assessment

It is very useful to look at Appendix C ‘Consultation Report on the Preferred Option’. This shows what comments were made on the previous NSP version and how the Council responded to them.See if anything was said about the policy numbers or site numbers that you are going to comment on.

A printed version of all these documents is supposed to be available at public libraries, but we know this was not the case for at least one (Dulwich Library) last week. If you find it is not available in your local library please let us know. You can ask for a copy of some of the documents to pick up at the Council Offices at Tooley St.To arrange this please email:

NEW SOUTHWARK PLAN POLICIES & NEIGHBOURHOODS

  • The Plan is in two main parts:
  • policies pages 13-93
  • neighbourhoods (headed Area Visions & Site Allocations) pages 94-342
  • The Contents Page 3-7 lists all the policies and the neighbourhoods. A copy of this is available here:

POLICIES

The policies are of three types:

  • Implementation policies: pages 13-15.
  • Strategic policies (SP1-SP6): pages 16-20
  • Development Management policies (P1-P69) pages 21 – 93
  • Each of these has a set of bullet points setting out the policy, followed by text giving the reasons for the policy.

So far, we are aware that representations are being considered on the following topics:

  • Housing - protecting existing homes, provision of affordable and social housing, rented housing, family homes, and student housing.
  • Local economy - loss of industrial land, supporting high streets, creative industries, enterprises and small businesses including retail.
  • Environment - extent of tall buildings, conservation areas & protection of heritage, open & green spaces, provisions for flooding, air quality, avoiding fuel poverty.
  • Health & wellbeing - including examining the new policies for 'social regeneration’.
  • People & groups - impact on and provision for existing residents & neighbourhoods, families & children, young people, older people, disabled people, mental health, gypsies & travellers.
  • Generic topics – equalities, consultation, monitoring.

NEIGHBOURHOODS pages 94 - 342

The NSP calls this section ‘Area Visions and Site Allocations’. There are 15 neighbourhoods each with a section of their own. These are listed in the Contents page. We have created separate pdfs for each and these are available here:

  • Each neighbourhood section consists of:
  • A map showing development sites, green spaces, cycle tracks, shopping frontages. These are also listed in the schedules (see also above under Schedules & Maps). But there are several other important parts of the plan in the schedules which are not shown on these neighbourhood maps, but only on the borough digital map and in the schedules. All land not shown in the neighbourhood maps is also available only in the borough digital map.

It is worth checking the facts on the schedules and maps for your own neighbourhood, in case you need to correct facts or seek changes in your representations.

  • An Area Vision statement.
  • Development sites each with an NSP number, which is the key reference for all comments on a site. These have two text sections ‘Site Vision’ and ‘Design and Accessibility Guidance’. These are the texts you need to examine in detail and see how you could suggest redrafting them to meet your objections and to make the proposed plan sound.
  • Southwark Planning Network is preparing evidence on the loss of industrial land across the borough so please note carefully which sites in your neighbourhood are losing industrial land and how much, and include that in your comments.

PREPARING REPRESENTATIONS

Comments are called ‘representations’. They have to be submitted in a particular form. This is available on-line here: a separate on-line form has to be completed for comments on differentpolicies and sites, and not everyone finds on-line comments easy. You can also submit yourcomments by email to We are preparing a template table as a guide for this. We will send this to all on the SPN mailing list, put it on the website, and it will be available at the workshops.

It will include your personal details and some other logistics. But the key part is that the representation on each policy and site must include the following information:

  • The NSP reference number. This will be the policy number or the site number, section heading, and the page number.
  • Why you think the NSP is not sound or legal. See note below.
  • What changes you suggest to make it sound or legal.

So when you read the documents, think about what you might say in your comments under those headings and keep your notes in that form. It will make it easier then to prepare your actual draft.

When you have a draft it would be very helpful if you could email it to us so we can start collating with others, and also to give you any suggestions or relevant info we have gathered elsewhere.

TESTS OF SOUNDNESS & LEGAL COMPLIANCE

Soundness:

The page in the NSP which explains these tests is reproduced at the end of this note. There is also more guidance available here:

One way of thinking about this is to form your thoughts about the comments you want to make and then think about what the effect of the plan or policywould be if those changes are not made. Would it make the NSP not effective ie not achievewhat it is meant to achieve? How would your changes make it effective? Is the Plan not justifiedbecause it hasn’t explored alternative ways of achieving the objectives and there is in yourview a better way? This is especiallyrelevant to look at the site proposals as you will have an alternativein your mind which you should set out in redrafted text for the ‘site vision’ and ‘design and accessibility guidance’ boxes. The changes needed can range from a small tweak to a complete redraft. You can say their plan is not justified if they haven’t examined this better alternative.

Legal Compliance

The questions to be considered here are listed in the note at the end. There will be some representations on this and if you find any aspects that you think are not legally compliant, please let us know. The more representations there are on a similar point the better.

LIAISING WITH US

You can prepare your representations and submit them without being in contact with us as the SouthwarkPlanning Network (SPN). We are willing to give advice and suggestions about making the presentations as useful and effective as they can be. We are also aiming to link people who are focussing on the same issues, and spotting omissions and circulating information to enable others to see if they are interested in including them in their representations.

Please email your drafts and your questions to with the subject

NSP REPRESENTATIONS

Compiled by Eileen Conn, Peckham Vision

working with Southwark Planning Network, Community Southwark, Southwark Law Centre

© Peckham Vision 2018

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Extract from the NSP Submission Version pages 9 & 10

Consultation on the Proposed Submission Version

The Proposed Submission Version has been prepared for consultation until 12 February 2018. This is not an open consultation for discussion and comment. This is the council’s final document for consideration. There will then be an examination in public by a planning inspector. The inspector will prepare a report for the council and may require changes to be made to the plan for legal reasons. The final New Southwark Plan will then be adopted by the council. This is a decision taken by all councillors at the Council Assembly.

Unlike previous consultations, we are required to ask two specific questions which will give you an opportunity to comment on how the New Southwark Plan has been prepared, that its aims are achievable and that the plan is based on a robust evidence base. These questions are more commonly known as the ‘Test of Soundness.’ These are the same questions the independent Planning Inspector will be asking as part of the examination. You can comment on the Submission Version of the plan on our consultation hub page here. Or by emailing

1. Is the Local Plan Legal?

A plan is considered legal when it complies with section 20(5) (a) of the Planning and Compulsory Purchase Act 2004. You may wish to consider the following before making a representation on legal compliance:

  • Whether the Local Plan has regard to national policy and guidance issued by the Secretary of State
  • Whether the Local Plan has been prepared in‐line with our Local Development Scheme (LDS)
  • Whether community consultation has been carried out in accordance with our adopted Statement of Community Involvement
  • Whether an Integrated Impact Assessment assessingsocial, environmental and economic factors has been prepared and made public.
  • Whether the requirements of the Duty to Co‐operate have been met. The Localism Act, section 110, and the National Planning Policy Framework, paragraphs 178 to 181, creates a duty on all local planning authorities and other bodies to cooperate with each other to address strategic issues in the preparation of the Local Plan

2. Is the Local Plan ‘Sound’?

As part of the examination, the independent Planning Inspector is required to consider if the New Southwark Plan has been positively prepared, justified, and effective, and is consistent with national policy. You may wish to consider the following before making a representation on the Soundness of our plan:

• Positively Prepared: This means that we have objectively assessed the need for homes, jobs, services and infrastructure and these have been delivered sustainably. If you think that our assessments are not objective or do not take sufficient account of unmet needs in neighbouring authorities then your comments relate to whether our Local Plan has been positively prepared or not.

• Justified: This means that the Plan is based upon a robust and credible evidence base. If you think that the evidence doesn’t support the choice made in our Local Plan or there are realistic alternatives then your comments relate to whether it is justified.

• Effective: This means that the Plan is achievable. If you think that what we are proposing in the Local Plan will not happen as the required infrastructure cannot be provided, the groups who will deliver elements of it haven’t signed up to it or our Local Plan does not join up with the strategies of our neighbouring authorities, then your comments relate to whether our Local Plan is effective or not.

• Consistent with national policy: Do you consider that our Local Plan accords with the National Planning Policy Framework, the London Plan, other policies or includes clear and convincing reasons for doing something different? Alternatively, you may think that the Local Plan should depart from national policy due to an identified and justified local need.

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