Your answer to Question 2019/8974 relating to the Policy D6 using a “design-led-approach” does not provide a detailed methodology to evaluate “Site Context” or a methodology to evaluate the “Capacity of Supporting Infrastructure” or a methodology to evaluate the “Planned Connectivity by Walking, Cycling and Public Transport Availability”. These contributing factors are vague and subjective parameter descriptions which would be extremely difficult to define whether a proposal was acceptable or unacceptable as there are no conclusive definitions of the parameters contributing to this “Design-led-approach” criterion or for the analysis of these factors which could indicate whether a proposal was acceptable or otherwise for a specific development proposal at a specific location.
The NPPF para 122 requires Development Plans to take account of the availability and capacity of infrastructure and services and at para 16 d) requires Development Plans should contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.
Policy D6 does not meet these requirements.
If it is necessary to produce a detailed supplementary planning guidance to accompany the Plan to provide additional detail on how to effectively optimise the capacity of sites by following the design-led approach, then this is proof that the Policy D6 as stated is inadequate for applicants to establish a suitable proposal of appropriate housing and residential densities for a locality.
How does an applicant establish an appropriate suitable density for a proposed development at a given locality?
And how can community groups assess the acceptability of such proposals?
As with the previous Mayor’s Plan, my policy requires development proposals to take account of a range of contextual factors to arrive at an appropriate density. I consider the policy to be clear and comprehensible for both professionals and community groups. However, it is inevitable that there will be an element of subjectivity for decision-makers when balancing a range of relevant strategic and local policy considerations.
Given the vast diversity of built form, accessibility and infrastructure capacities across London it is impractical for a regional strategic policy to establish the appropriate density of any given development site using a precise set of metrics.
My draft Plan provides more opportunities for community groups to shape the development process as it advocates for boroughs to establish the optimum development capacity of allocated development sites in their local plans.