Further to your response to question 2019/8973, the first paragraph of your answer related to the current Policy 3.4 which includes a density matrix but did not answer the question on Policy D6 which requested why Policy D6 does not give guidance to applicants for the appropriate densities for development proposals at given localities and therefore does not meet the requirements of NPPF para 16 and 122. 16. Plans should: d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals; 122. Planning policies and decisions should support development that makes efficient use of land, taking into account: c) the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use; d) the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change; and The second part of the first paragraph provided a history of planning officers’ failure to implement the provisions of the density matrix. This suggests that planning officers were ignoring the policy to meet housing targets, not that the Policy 3.4 was flawed. The result of officers ignoring the policy is the visible increase in local congestion due to over-development, overcrowding and inadequate public transport to support the approved high densities of which supporting evidence is available. With the replacement Policy D6, if there is no defined relationship, or methodology, what way is there of preventing public transport under or over capacity or traffic congestion as residents in high density developments (localities) revert to cars due to unavailable public transport capacities?
In contrast, my draft London Plan provides clear policy to ensure boroughs plan for the delivery of infrastructure necessary to support new housing and ensures that the scale of a development does not exceed current or future planned supporting infrastructure. Policy D1A Infrastructure requirements for sustainable densities is clear that ‘where there is currently insufficient capacity of existing infrastructure to support proposed densities (including the impact of cumulative development), boroughs should work with applicants and infrastructure providers to ensure that sufficient capacity will exist at the appropriate time’. It is also clear that where a ‘borough considers the planned infrastructure capacity will be exceeded, additional infrastructure proportionate to the development should be delivered through the development’.
My officers in the London Plan team would be happy to discuss the SRQ density matrix and its application, and the draft Plan’s approach to density with you.