b) be prepared positively, in a way that is aspirational but deliverable; c) be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees; d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;
Would you agree that Policy D6 does not meet NPPF Para 16 b) as without clarification the policy is not deliverable, as well as para 16 c) as the policy is not shaped by effective engagement between Plan Makers and Communities (communities have no methodology or grounds to challenge proposals)?
Also, would you agree that it does not meet para 16 d), as the policy is ambiguous in that there is no specific quantifiable measure of acceptability, and therefore it is not evident how a decision maker (or applicant) should react to a development proposal?
I am confident my entire Plan meets the requirements of 2018 NPPF Paragraph 16. However, my Plan has been examined against the 2012 NPPF, which expresses these requirements differently.
Regarding Para 16 Part b), I consider the policy is deliverable without further clarification. I have committed to providing supplementary planning guidance to enable robust and consistent application of the policy. Furthermore, the guidance will enhance the accessibility of the policy for non-experts.
In response to Part c), the policy is informed by a substantial body of evidence that I referenced in my written statement in support of the policy for the purpose of the London Plan examination. Furthermore, the policy was developed through a consultative process with a wide range of stakeholders, including community groups, in particular during the formal London Plan consultation in late 2017.
Finally, in relation to Part d), the policy is unambiguous. Determining an appropriate density is a complex and sensitive process. There is no alternative strategic policy that would be effective in determining the optimum density of individual development sites with the use of quantifiable matrix-like tools. Such tools may be seductive for their apparent objectivity and simplicity. However, these tools are ultimately meretricious and would produce undesirable planning outcomes, or simply not be followed, as is the outcome of the density matrix in the majority of cases seen by the GLA.