Richmond Council’s Air Quality Action Plan
We have commented on Richmond Council’s Action Plan to improve air quality in the Borough. You can see the comments we made here Air Quality Action Plan Richmond consultation response .doc final
Air quality is a major concern in the London Borough of Richmond upon Thanes (LBRuT) as set out in our response:
- 75% of LBRuT sites monitored exceed the UK annual mean Air Quality (AQ) objective of 40μg/m3 for NO2
- 13.2% of residents are exposed to ˃ 40μg/m3 NO2 where they live, risking their health
- 5 sites exceed the 1h AQ objective (60μg/m3), risking the health of passers-by, shoppers, workers, etc., as well as that of residents
- Modelled PM10 concentration exceeds annual mean objective on major transit roads and in town centres, risking the health of all frequenting or residing in those areas
- LBRuT residents are more likely to die prematurely from pollution than people living in England outside the London Region.
- The Air Quality Action Plan (AQAP) states that a 73% reduction in NO2 is required in the worse affected areas, e.g. George Street, to reduce concentration to an acceptable level of 40μg/m3
We are also looking at the Mayor of London’s consultation on the London Environment, in particular the Chapter on air quality. Comments are due by 17th November. We are looking too at Hounslow Council’s Air Quality Action Plan on which comments are due by 17th December.
Richmond Council’s Local Plan
We attended the public examination of the Local Plan when the new policy on basements was discussed. We hope that the new policy will be adopted so that stronger controls are in place on these developments.
Richmond Council has published the final report of its Scrutiny Panel review of its review of basements. You can see the report here: Basement scrutiny report final
Richmond Council’s new Local Plan will be examined in public by the Planning Inspectorate. One of the issues chosen for examination is the policy on basements. You can see details of the review timetable here: http://www.richmond.gov.uk/local_plan_examination
Richmond Council’s Local Plan
We have made no further comments on the draft Local Plan but did take part, by invitation, in the Council’s Scrutiny Panel review of policies on basement developments, our main area of comments on the draft Plan.The strength of policies to protect adjacent properties where a basement is proposed was the main area of concern discussed, raised by us and others. Council officers explained what they had done to strengthen policies in the new draft Local Plan after reviewing actions by other Councils on basement policies and assembling the evidence relevant to Richmond which is needed to support the strengthening of policy. The evidence will be published shortly. The Council is also considering Article 4 Directions so that all basement developments would in future require planning approval (some are currently permitted development).
The draft Local Plan will be submitted to the Secretary of State in the Spring/Summer 2017 for independent appraisal by the Planning Inspectorate and final adoption in early 2018.
Richmond Council’s Local Plan
Richmond Council’s draft Local Plan has now been published for consultation. This is the last iteration of the Plan before submission to the Planning Inspectorate for independent review and sign-off.The consultation runs until 15 February. We will be taking a look at the latest draft. Comments at this stage are restricted to legal and procedural compliance, soundness and the duty to consult.
Noise Generating and Noise Sensitive Developments
We have submitted comments on this very important Supplementary Planning Document on controlling noise in the Borough and are very grateful to Peter Willan for pulling the response together using his detailed knowledge of the subject. The response is jointly submitted by the Kew Society, the Richmond Society, the Friends of Richmond Green and the Richmond Heathrow Campaign. Response on Emerging SPD 11 NOv 2016 Final (1)
We will be following up with Richmond Council on some of the suggestions we have made.
Electric Vehicles Recharging Strategy 2016-2026
We have commented to support Richmond Council’s policy on increasing the uptake of electric vehicles through more charging points. We noted that Richmond Council favour charging points near retail centres to raise awareness but have asked that care be taken around small retail centres such as Kew Village where loss of parking spaces could impact footfall in the shops and other outlets. We have suggested Kew Retail Park as a suitable location in addition to those suggested by the Council. (It was hard to see in the map on-line how far this had been considered by the Council as a location in Kew). We also asked for clarification of the planning application process when charging sites are proposed.
In addition to the benefits of more take up of electric cars in terms of much needed improvements in air quality, we have pointed out the benefits for noise reduction too.
Pre-publication Local Plan
Richmond Council have now published all the comments made on their pre-publication Local Plan on their website. We await the next stage of consultation on the complete draft Plan this Winter..
We have made a number of comments on the latest phase of Richmond Council’s pre-publication Local Plan, focusing particularly on the need for a clearer policy on basement development. This is an area many other local London Councils are looking at. You can see the consultation at this address, including a summary of the comments we made previously on the Scoping phase: http://www.richmond.gov.uk/local_plan_pre-publication.
Our latest comments are here: Local Plan pre-publication consultation comments August 2016
The nest phase of the Local Plan consultation will be this Winter.
Policy on Basements
Richmond Council begin the consultation on their Local Plan tomorrow, 8th July, until 19th August. We will be looking carefully at the draft, including what might be proposed on modifications to policies on basements.
The new Scrutiny Panel on this topic is expected to be established shortly and we have fed in our concerns to the scrutiny team through Councillor Gareth Evans, the new Chair of the Scrutiny Committee.
We are in discussion with Richmond Council over the review they are undertaking on basements policy through their new Scrutiny Committee on this topic. Concerns over basements have been raised across London as ever larger basements have been built. The main concerns we have identified so far are that, despite the recent improvements in basement policy made by Richmond Council, a number of gaps seem to remain. We think these are:
(i) a Structural Impact Assessment is only required in relation to nationally listed buildings, so has limited value in protecting buildings and homes;
(ii) party wall agreements are of limited value since they do not cover properties further away which may be affected by excavation;
(iii) underground water stream diversion as a result of basement construction does not seem to be covered;
(iv) there appears to be no requirement for the developer/owner to take out insurance which would cover nearby buildings for damage as a result of the basement work.
We will continue our dialogue with Richmond Council to check that these are the key outstanding issues and identify how they might be addressed. We are also asking for information on the process the Scrutiny Committee will adopt, including whether we can submit comments, and the timing for its report.
Local Plan consultation
We have submitted comments on Richmond Council’s approach to their review of their Local Plan. You can see what we said here: Richmond Planning review comments
We will be looking at the proposed revisions in the consultations which will be coming forward over the coming year. This is an important process shaping planning policies for our Borough.
Richmond Council has started a public consultation on its planning policies, currently asking for views on their general approach ahead of detailed consultation on the wording of their updated plan. We are working on our comments. You can see the consultation here. The Local Plan is an important document framing the way in which the Council deals with planning applications and therefore our grounds for commenting on applications in the area.
Affordable Housing Policy
We have previously commented, together with the Richmond Society, on the Council’s draft policy on affordable housing, since adopted. We support the policy aims but are concerned that in practice, there seem to be real obstacles to making the policy a reality.