Minutes:
The panel were reminded of the initial consultation process, highlighting changes made to the draft local plan since the panel last reviewed it. Responses to the consultation, which ran from February to April, included statutory consultees, three petitions, and face-to-face engagement events. Key concerns raised in the consultation were related to the spatial strategy, housing delivery, infrastructure, and tall buildings.
National and Regional Context
The Head of Planning Policy noted the passage of time since the current plan was adopted and that the new plan, covering 2021 to 2041, must consider updates to the National Planning Policy Framework and multiple versions of the London Plan since the current plan was adopted (further proposed reforms were covered later in the presentation by the Chief Planning Officer).
Key Changes to the Draft Plan
Several changes were made in response to stakeholder feedback, including new policies on inclusive design; safety, security and resilience to hazards; and basement development. Updates were made to housing policies and clarifications on affordable housing, large-scale purpose-built shared accommodation, and heritage policies. Amendments were also made to the transport, green infrastructure, and employment policies, reflecting feedback from consultees.
Site Allocations
Chapter 11 of the local plan, which addresses site allocations, was discussed. The plan identified 41 potential sites for development, with 42 sites submitted through the call for sites process. A total of 98 sites were considered, with some being excluded due to policy conflicts or size. The plan allocated sufficient land to meet housing needs, with 17,000 homes identified, slightly exceeding the target for flexibility.
Key Risks
Risks highlighted included meeting London Plan targets, infrastructure delivery, and the implications of changes to the National Planning Policy Framework. Parking provisions and potential challenges from the Mayor of London were also noted as key concerns.
Chief Planning Officer made the following presentation.
Overview of Planning Reform
The Chief Planning Officer opened the session by highlighting the ongoing uncertainty in the planning sector, referencing recent policy announcements and proposals. A ministerial statement from the Deputy Prime Minister emphasised that planning remained a local activity, but decisions must focus on delivering housing and infrastructure needs, rather than debating the necessity of such developments.
Draft Planning and Infrastructure Bill
A new draft Bill was expected in the next session of Parliament.
Key proposals included:
· Local authorities potentially setting their own planning fees.
· Reforms to the compulsory purchase order compensation scheme.
· Streamlining infrastructure delivery.
· Support for nature recovery in development funding.
· A new approach to strategic planning outside mayoral areas, including urban regeneration projects.
· Extension of the deadline for local plan submissions from June 2025 to December 2026, with Harrow aiming for submission before June 2025.
Draft National Planning Policy Framework (NPPF) Updates
The deadline for comments on the draft NPPF closed on 24 September 2024.
Proposed changes included:
· Reinstatement of mandatory housing targets.
· Introduction of a new "Grey Belt" designation within the Green Belt.
· A sequential test for Green Belt reviews prioritising brownfield land, then Grey Belt, and finally higher-performing Green Belt areas.
· New rules for Green Belt land release, such as requiring 50% affordable housing and infrastructure provision.
Harrow was awaiting the final version of the NPPF and its potential impact on the local plan.
Additional NPPF Amendments
· Changes to design policies remove references to local character and beauty.
· Expansion of the definition of previously developed land to include hard standings and greenhouses.
· Support for mixed tenure development and identification of sites for gigafactories and digital infrastructure.
· Emphasis on renewable energy generation and vision-led transport planning.
Intervention and Transitional Arrangements
Plans at the Regulation 19 stage may need to revise their targets if they differed by more than 200 homes per annum from the new housing need figures. The government had offered financial support to help authorities make necessary adjustments.
Harrow Local Plan Housing Targets
Harrow's housing targets had evolved from 356 dwellings per annum in 2013 to 802 dwellings per annum under the 2021 London Plan. If a new local plan was not adopted by March 2026, housing targets could rise to 2,137 dwellings per annum.
The absence of a five-year housing land supply would result in a presumption in favour of sustainable development, potentially leading to speculative applications.
Next Steps
The Local Plan was set to be presented to:
· Overview and Scrutiny Committee on 9 October 2024.
· Cabinet on 15 October 2024.
· Special Full Council on 23 October 2024, seeking approval to publish the Regulation 19 version of the Plan for consultation in November and December.
· The target is to submit the Local Plan for examination by mid-2025.
The following questions were asked and answered.
The Panel enquired about the impact of national policy changes on the management of town centres, referring to the diminished scope to manage specific uses (Page 16 of the report). The Head of Planning Policy explained that this was due to the introduction of new permitted development rights, such as changes from office to residential, and the new E-use class, which reduced the council's ability to regulate changes in town centre use.
The Panel raised concerns about the potential implications of the draft NPPF on housing targets, specifically whether the borough would be required to accommodate 2,137 homes per year if the new standard methodology was adopted. The Chief Planning Officer clarified that the NPPF was still in draft form, and the final version could significantly alter housing targets. However, it was too early to assume what the final requirements would be.
The Panel questioned why none of the indicators were red despite the uncertainty surrounding government policy regarding the traffic light system used for risks (Pages 38-40). The Chief Planning Officer explained that red was reserved for known risks, while amber reflects uncertainty. Until final government decisions were made, it remained appropriate to use amber.
The Panel asked how many of the 41 sites listed were carried forward from 2013. The Head of Planning Policy advised that a reasonable number of the sites were carried forward, with some still having active interest from developers, which influenced the likelihood of development.
The Panel enquired about the progress made since January 2024 concerning the infrastructure concerns raised by residents during consultation, as well as ongoing discussions on infrastructure needs. They sought more detailed information on how these had been addressed. The Head of Planning Policy advisedthat an initial scoping report for the Infrastructure Delivery Plan had been carried out last year, highlighting key infrastructure considerations. Since then, they had developed a more detailed understanding of the necessary infrastructure to support the proposed site allocations. Ongoing consultations with organisations like the NHS had led to identifying specific site requirements, such as the potential inclusion of health facilities on certain sites.
The Panel then asked for clarification on why 11 sites were not included in the spatial strategy, and if the reasons were due to policy, controversy, or political direction. Officers clarified that these sites were primarily located in the Greenbelt, and their exclusion was due to inconsistency with both national policy and the London Plan regarding Greenbelt land.
The Panel also questioned whether the council could exclude certain allocated sites without a specific planning reason and whether more direct consultation with residents would be possible, especially for areas heavily affected by development. Officers advised against localised consultations for site allocations, citing the costs and lack of necessity given that the sites were suggestions for future development, not planning applications. A broad consultation approach would continue, similar to earlier phases.
The Panel raised concerns about the potential cost implications of new national policies affecting the local plan.
The Panel asked about protections for offices and employment areas in relation to build-to-rent proposals. The Head of Planning Policy explained they tried to protect offices where possible but were limited by permitted development rights.
The Panel queried about self-build sites, stating the issue was raised regularly, but designations were unclear. Officers replied that sites not allocated for self-build could still include self-build elements.
The Panel asked about suitable sites for co-living developments. The Head of Planning Policy stated that co-living was not prioritised as there was a greater need for family-sized dwellings.
The Panel questioned space standards for HMOs and their focus on areas with high public transport access, possibly at the expense of smaller family homes. Officers confirmed that HMO policy in the current plan was permissive, and whilst the proposed policy in the draft plan proposed a focus on high-access areas, homes below 130 square meters would generally be protected from conversion in order to protect smaller family size housing.
Resolved to RECOMMEND: to Cabinet
That
(1) the draft Regulation 19 new Harrow Local Plan and supporting documents be commended to full Council for approval to undertake the second round of consultation (Regulation 19 consultation).
RESOLVED: That
(2) the draft Regulation 19 new Harrow Local Plan and supporting documents included in the appendices to the report, be noted;
(3) the update provided in relation to the local plan process, next steps, and recent Government consultations, be noted.
Supporting documents: