The consultation undertaken by the Old Oak and Park Royal Development Corporation on its Post Submission Modified Draft Local Plan finished on July 5th. We prepared a second set of detailed representations, which were submitted to the OPDC.
The Development Corporaation now reviews all the submissions made, and prepares reponsed to these before passing them on to Planning Inspector Paul Clark. The Inspector;s final report on the Draft Plan is not expected for several months.
Our comments were summarised below in our representations. We are aware that Hammersmith & Fulham Council, the Friends of Wormwood Scrubs, Friends of Little Scrubs, and the Hammersmith Society sent in responses making many of the same points.
• We consider the consultation material, including online sessions and the sub-site set up by OPDC to be inadequate for reasons explained below. The magnitude of the changed spatial and transport elements of the Draft Plan was seriously understated by OPDC.
• Anyone reading the Table of Modifications alone might well not even notice the fundamental changes relating to Old Oak North, Scrubs Lane, Channel Gate and transport infrastructure.
• Unmodified parts of the Plan continue to make exaggerated and unevidenced claims for the ‘connectivity’ of ‘Places’ at Old Oak and the impact that the OOC rail interchange will have on the wider area of West London.
• This impact will emerge only after 2030 by which time this PSMDLP will need to have been reviewed once if not twice.
• Levels of uncertainty on funding for infrastructure remain very high. For the next 10 years until OOC station is in operation, OPDC and Mayoral ambitions for the area should be scaled back – particularly at a time of major change resulting from the pandemic.
• With a high probability of no new Overground stations and no new east-west road connection between East Acton and North Hammersmith, the whole coherence of the 19.2 version of the Draft Local Plan is undermined.
• We are not persuaded by the content of the BNP Paribas Strategic Site Allocations Viability Study (see Annex C).
• Entirely new proposals for concentrations of very high density and high rise housing are introduced as modifications to a Local Plan already 3 years into its examination stage.
• Proposals for a ‘major Old Oak town centre’ are unclear and incoherent.
• Lack of adequate new public transport improvements means that proposals at Channel Gate and Scrubs Lane will not conform with 2021 London Plan policy.
• There is no evidence that the Duty of Co-operation with neighbouring Boroughs has continued to be met since September 2018, and some evidence to the contrary.
Our full ‘Part 2’ response is too large a file to be added here as a download. But please email inf@stqw,org if you would like a copy. See also our earlier post for Part 1 of our representations.
We will continue to arge that OPDC should make a fresh start on what is a ‘modified’ Draft Local Plan which no longer sets out a coherent set of future proposals for the Old Oak area. .