General and background

    Q1a. Who are OPDC? Why were OPDC set up?

    The Mayor of London set up the Old Oak and Park Royal Development Corporation (OPDC) on 1 April 2015. OPDC is the Local Planning Authority and regeneration agency for the Old Oak and Park Royal area. Old Oak and Park Royal is set to become one of the most connected areas of London, with the new High Speed 2 (HS2) and Elizabeth line station currently being built. OPDC is tasked with planning for new homes, jobs and opportunities for people and businesses in this dynamic part of west London.

    Q1b. What is a Local Plan?

    A Local Plan is a planning policy document prepared by a local planning authority. It sets out a vision and framework for the future development of an area. Local Plans are used to guide decisions on planning applications that are submitted by developers. 

    OPDC is responsible for preparing the Local Plan for the Old Oak and Park Royal area. OPDC’s Local Plan guides good growth over the next 20 years to help create healthy streets, new public spaces, high-quality and affordable homes and connected places to live and work.

    Q1c. What stage is OPDC’s Local Plan at?

    OPDC’s Local Plan has reached the Examination stage which is the final part of the process before a plan can be adopted. At this stage, an independent Planning Inspector scrutinises the plan. The Planning Inspector for our Local Plan is Paul Clark (MA MRTPI MCMI) and the examination of our Plan is still ongoing. 

    The Planning Inspector has requested we make some changes to it as part of the examination process. Following close collaboration with landowners and the community, as well as holding online public engagement sessions last year, we’ve prepared the proposed changes (known in planning terms as Main Modifications) to our draft Local Plan and we are consulting on these changes now. We have also prepared additional (Minor) modifications as well, that are also being published.

     All the key milestones in developing our Local Plan are explained and shown below.


    • February – March 2016 - We published the first draft of the Local Plan and all of its supporting studies. This version of the draft Local Plan included different options for how we could plan for development in the OPDC area. Everyone was given a chance to comment on these options (known as a Regulation 18 consultation). We considered all of the consultation responses and started to prepare updates to the draft Local Plan. 
    •  June – September 2017 - We published a revised draft of the Local Plan and all of its supporting studies. This version included OPDC’s preferred approach on a number of issues (i.e. housing, transport, open space etc.) Again, everyone was given a chance to comment (known as a Regulation 19 consultation) and we considered all of the consultation responses. 
    •  June – July 2018 - A number of changes were made to the draft Local Plan as a result of the first Regulation 19 consultation. We published an amended version of the document to give everyone opportunity to comment on these changes. Again, we considered all of the consultation responses.
    •  October 2018 -We submitted all of the Local Plan documents and the supporting studies for Independent Examination. This is a process in which an independent Planning Inspector scrutinises the Plan. The Inspector started this examination in November 2018. 
    •  April – July 2019 - The Planning Inspector held public hearings to discuss questions that have been raised about the Plan. OPDC, landowners and members of the public were invited to speak and answer questions at these meetings.
    •  October 2019 - The Planning Inspector published Interim Findings on issues that had come up in the public meetings and in written responses. The Inspector found the majority of the Plan to be sound but requested the removal of two key sites in Old Oak North. 
    •  2020 - We prepared modifications (changes) to the Plan to address the Inspector’s requests and updated the supporting studies. We also contacted and spoke to key organisations, or individuals who may be affected by the changes before running a series of engagement events with the wider public. 
    •  2021 - OPDC Planning Committee, followed by Board, met and agreed with a majority that the modifications should be submitted to the Planning Inspector. The Inspector has agreed that these can be made available for public consultation. We are consulting on these proposed modifications now.

    When the current consultation closes:


    OPDC and the Planning Inspector will review all of the consultation responses, respond to comments and may recommend further modifications. 

    • The Inspector will decide if more public hearings are required to discuss people’s comments and if so, these will be arranged. 
    • The Inspector will then write his final report on the Local Plan, taking into account the consultation responses. He will set out if he considers the Local Plan to be sound and direct any further changes he deems necessary to make the Local Plan sound. 
    • Should the Plan be deemed sound, OPDC will adopt the Local Plan.  


    Q1d. How have you engaged with stakeholders and the local community throughout the Local Plan process?

    We have carried out a comprehensive consultation and engagement process during the development of the Local Plan, since 2016. You can find out more detail in the Statement of Consultation. This process comprised of three formal consultation periods totalling 25 weeks:

    • February 2016: Consultation on the first draft (Regulation 18) Local Plan
    • June 2017: Consultation on the second draft (first Regulation 19 version) Local Plan
    • June 2018: Consultation on the third draft (second Regulation 19 version) Local Plan

    These events comprised 28 public events and a variety of online and offline activities including: 

    • Drop-in sessions, workshops and presentation events;
    • Attendance at various stakeholder consultation events;
    • Public notices in local newspapers;
    • A bespoke consultation web platform, website updates and Twitter sessions;
    • Distribution of hardcopy leaflets and letters to over 40,000 residents and businesses;
    • Provision of documents for viewing and download on OPDC’s website; and
    • Provision of hard copy documents at accessible local locations and on request.

    These activities resulted in a high response rate for each of the following formal consultation periods: 

    • Regulation 18: 2,640 responses comprising over 7,000 comments;
    • First Regulation 19: 119 responses comprising over 2,800 comments; and
    • Second Regulation 19: 90 responses comprising over 1,600 comments.

    Since August 2020 we held one-to-one briefings with local authorities, stakeholders and landowners and, in the main, secured in-principle support for our new plans.  

    We also ran a community engagement programme in November 2020 which included presenting at residents’ meetings, an extensive social media campaign, two online webinars attended by over 70 residents and producing an information leaflet sent to local residents and published on our webpages. During the engagement process we received and directly responded to over 60 questions and comments.  

Consultation

    Q2a. What is the current consultation about?

    The Planning Inspector has requested we make some changes to our draft Local Plan as part of the examination process. Following close collaboration with landowners and the community, as well as holding online public engagement sessions last year, we’ve prepared the proposed changes (known in planning terms as Main Modifications) to our draft Local Plan and we are consulting on these changes now. We have also prepared additional (Minor) modifications as well, which are also being published as part of the consultation.

     The focus is on the new changes rather than the whole Local Plan document because we carried out a comprehensive consultation and engagement process before reaching this stage. You can find out more detail in the Statement of Consultation. The Planning Inspector will be considering comments on the proposed changes in relation to ‘legal compliance’ and ‘soundness’.

     Legal compliance relates to whether the Local Plan meets legal requirements including the duty to cooperate with relevant organisations.

     Soundness comprises 4 components:

     (a) Being positively prepared – seeking to meet the area’s, and potentially neighbouring areas’, needs

     (b) Being justified – being based on research having considered other reasonable alternatives

     (c) Being effective – being able to be delivered over the plan period

     (d) Being consistent with national policy – meeting the requirements of the National Planning Policy Framework

     If you submitted comments on previous versions of the Local Plan (during the Regulation 18 and Regulation 19 consultation stages), the Inspector will be aware of the comments and will have been considering them as part of the examination. Therefore, this consultation is inviting comments on the recent changes that we’ve made.

    Q2b. What are Main Modifications?

    Main Modifications are changes which will affect the overall ‘soundness’ of the Local Plan and will ultimately enable the Local Plan to be adopted.

    Soundness is defined in the National Planning Policy Framework (NPPF). It relates to the criteria summarised below:

    (a) Being positively prepared – seeking to meet the area’s, and potentially neighbouring areas’, needs

    (b) Being justified – being based on research having considered other reasonable alternatives

    (c) Being effective – being able to be delivered over the plan period

    (d) Being consistent with national policy – meeting the requirements of the National Planning Policy Framework

    A schedule of the Main Modifications is included in the consultation documents.

    Q2c. What are Minor Modifications?

    Local planning authorities can choose to make Minor Modifications to the plan before it is adopted. Minor Modifications are changes that do not materially affect the plan’s policies and are usually made to respond directly to requests from the Inspector.

    Local Planning Authorities may include the Minor Modifications documents as part of the consultations that take place at this stage.

     A schedule of the Minor Modifications is included in the consultation documents.

    Q2d. If the scope of the current stage of consultation is limited, then why should I bother responding?

    OPDC and the Planning Inspector will review all of the consultation responses, respond to comments and this may lead to the recommendation of further modifications. The Inspector will decide if more public hearings are required to discuss people’s comments and if so, these will be arranged, and the Inspector can invite members of the public to speak at these sessions. 

     The Inspector will then write his final report on the Local Plan taking into account the consultation responses. He will set out if he considers the Local Plan to be sound and direct any further changes that he deems necessary to make the Local Plan sound.

    Q2e. How and when can I comment on the Local Plan?

    The public consultation runs from 17 May until midnight 5 July 2021. We want the consultation to be inclusive, accessible and useable, so there are a range of ways to find out more, get involved and provide comments. You can send comments in the following ways:

    Online consultation platform: You can access this online consultation platform any time across the seven-week consultation, view the proposed changes to our draft Local Plan, register for events, watch videos of the consultation events if you weren’t able to attend and submit feedback via a feedback form. 

    On the feedback form you should make reference to the modification your comments refers to and whether it relates to the Local Plan being legally compliant and /or relates to one of the four tests of soundness set out in the National Planning Policy Framework. You can find a summary of these under FAQ Q2a.

    Email: localplan@opdc.london.gov.uk

    Post: OPDC, City Hall, The Queen’s Walk, London SE1 2AA 

    Phone:   020 7983 6520

    Q2f. How will you conduct public consultation? Will there be public events?

    We are making use of best practice and innovative online engagement platforms and techniques, while also supporting those who don’t have access to the internet, ensuring that everyone in the community has the opportunity to engage in the process and provide feedback. Full details can be found in our Consultation Plan and are summarised below:

    Online consultation events

    We are holding online events that are open to everyone and we would like to invite you to attend. At the events, our Planning Policy Officers will hold short presentations and be available to answer your questions. Details of these events are set out below.

    DateTimeSubject
    Wednesday 26 May
    12:00 – 13:30
    Introduction to consultation & summary of all sites
    Monday 7 June
    14:30 – 16:00
    General summary & Scrubs Lane
    Thursday 10 June
    17:30 – 19:00
    General summary & Channel Gate
    Thursday 17 June
    18:00 – 19:30
    General summary, North Acton & Old Oak Common Station
    Saturday 19 June
    10:00 – 11:30
    General summary & Old Oak North


    The events will be held on Zoom. Please register for one or more of the above events here. If you are unable to attend the events they will be recorded and published online. 

    Online consultation platform - OPDC Have Your Say!

    You can access this platform any time across the seven-week consultation, view the proposed changes to our draft Local Plan, register for events, watch videos of the consultation events if you weren’t able to attend and submit feedback. 

    Towards the end of our consultation period, if government guidance allows, we hope to hold some outdoor, in-person consultation events. We will only hold in-person events if it is safe to do so and will ensure that these are well-publicised nearer the time.

    Q2g. Are the documents available in other formats?

    We appreciate that not everyone prefers, or is able to use, the internet for public consultation, so paper copies of the draft Local Plan and proposed changes, as well as supporting information and paper feedback forms are available at the following locations: 

    • City Hall, Queens Walk, London SE1 2AA
    • Harlesden Library, Craven Park Road NW10 8SE
    • The Collective, Nash House, Old Oak Lane, London NW10 6FF 

    You can also request printed copies of the consultation materials or ask the team questions by:

    • Email:  localplan@opdc.london.gov.uk
    • Post: OPDC, City Hall, The Queen’s Walk, London SE1 2AA
    • Phone: 020 7983 6520

    We offer translations, Braille or audio format for all of our materials upon request.

    Q2h. What are the next steps with the Local Plan?

    The examination programme is in the control of the Planning Inspector, but it is likely to comprise of the following:

    • OPDC and the Inspector will review representations made as part of the main modifications consultation, respond to comments and may recommend any further modifications. The Inspector will decide if further public hearings are required and if so, hearings will be held. 
    • The Inspector will then write his final report, setting out if he considers the Local Plan to be sound and directing any further changes he deems necessary to make the Local Plan sound. 
    • Should the Plan be deemed sound, OPDC will adopt the Local Plan  

     Officers envisage that the draft Local Plan is likely to be considered for adoption in autumn/winter 2021.

    Q2i. Is this the last chance to comment on the Local Plan?

    This is down to the Planning Inspector. If the Inspector decides to carry out public hearings, people will be invited to attend and provide comments. Following the adoption of this Local Plan, OPDC will be reviewing the Local Plan and you will be able to comment as part of future public consultations.

    Q2j. Given that the current stage of consultation is limited, what opportunities are there to be more involved in a future Local Plan?

    Local Plans can be reviewed after they have been adopted. Current guidance requires Local Planning Authorities to do this at least every five years. OPDC will take a proactive and flexible approach to reviewing the Local Plan. As part of this, communities, businesses and organisations can put forward their ideas and comments. 

     The review process will be managed and reported through our annual Planning Authority Monitoring Reports.

Understanding the changes

    Q3a. Why have you modified the draft Local Plan?

    We have made Main Modifications (or changes) to the Local Plan as part of the process to get our draft Local Plan adopted. As part of this process, our draft Local Plan is going through an examination, conducted by the Planning Inspectorate on behalf of the Secretary of State for Housing, Communities and Local Government. 

    The Main Modifications made to our Local Plan result from requests or directions made by the Planning Inspector during the course of the examination. They are to ensure that our draft Local Plan is sound and can be adopted, providing a framework for the regeneration of the Old Oak and Park Royal area over the next 20 years. The Table of Main Modifications can be viewed within the Consultation Documents tab.

    We have also made other Minor Modifications that do not materially affect the plan’s policies. The Table of Minor Modifications can be viewed within the Consultation Documents tab.

    Q3b.Where can I access all of the Examination documents?

    We have an online examination library which includes all documents and formal correspondence between OPDC and the Planning Inspector. You can access it here.

    Q3c. Is it normal for examinations to take a long time?

    Yes. Local Plan examinations frequently take a long time. This is particularly the case for the OPDC area as it is a complex location for a new Local Planning Authority with many opportunities and challenges in creating a planning framework to deliver a new part of London and an enhanced dynamic industrial area.

    Q3d. What are the modification categories?

    The modifications respond to particular requests or directions from our Planning Inspector. These fall within five broad categories: 

    1. Modifications to address the Inspector’s Interim Findings for Old Oak North and to ensure general conformity with the Mayor’s London Plan in respect of OPDC’s housing targets. 
    2. Other modifications required to ensure general conformity with the Mayor’s London Plan reflecting its publication in March 2021. These include updates to how student housing is counted towards housing targets and reflect changes made to London Plan on the provision of industrial floorspace. 
    3. Modifications to ensure that the draft Local Plan is aligned with the Government’s changes to the Use Class Order introduced in September 2020.
    4. Modifications requested by the Planning Inspector during the examination in public, prior to the issuing of the Interim Findings in September 2019. 
    5. Modifications made to the draft Local Plan, following its final public consultation but prior to submission of the draft Local Plan to the Planning Inspectorate in October 2018.

    Q3e. What are Main Modifications?

    Main Modifications are changes which will affect the overall ‘soundness’ of the Local Plan and will ultimately enable the Local Plan to be adopted.

    Soundness is defined in the National Planning Policy Framework (NPPF). It relates to the criteria summarised below:

    (a) Being positively prepared – seeking to meet the area’s, and potentially neighbouring areas’, needs

    (b) Being justified – being based on research having considered other reasonable alternatives

    (c) Being effective – being able to be delivered over the plan period

    (d) Being consistent with national policy – meeting the requirements of the National Planning Policy Framework

    A schedule of the Main Modifications is included in the consultation documents.

    Q3f. What are Minor Modifications?

    Local planning authorities can choose to make Minor Modifications to the plan before it is adopted. Minor Modifications are changes that do not materially affect the plan’s policies and are usually made to respond directly to requests from the Inspector.

     Local Planning Authorities may include the Minor Modifications documents as part of the consultations that take place at this stage.  A schedule of the Minor Modifications is included in the consultation documents.

    Q3g. What is ‘general conformity’ and why do you need to be in general conformity with the London Plan?

    General conformity is a test that the Planning Inspector must be satisfied of to approve the Local Plan. In broad terms, it is a test that a Local Plan is generally aligned with key policies within the Mayor’s London Plan. This is to ensure that local authorities within London are supporting the Mayor in meeting strategic priorities for Londoners, such as meeting housing and jobs targets, delivering affordable housing at the appropriate level and of the appropriate types, supporting Mayoral environmental sustainability targets and protecting industrial land. 

    Whether or not you are in general conformity is usually confirmed through a letter provided by the Greater London Authority (GLA), setting out if you are or if you are not, and on which grounds. 

    The GLA and Transport for London (TfL) have signed Statements of Common Ground with OPDC confirming that the modified Local Plan is in general conformity with the London Plan

    This confirms that the GLA considers our modified plan to meet Mayoral housing targets for the OPDC area – a target to deliver 13,670 homes between 2019-29 and a target to deliver 25,500 homes over the total development period.

    Q3h. What does soundness mean?

    Soundness is a series of tests that Local Plans must meet. Soundness is defined in the National Planning Policy Framework (NPPF). It relates to the criteria summarised below:

    (a) Being positively prepared – seeking to meet the area’s, and potentially neighbouring areas’, needs

    (b) Being justified – being based on research having considered other reasonable alternatives

    (c) Being effective – being able to be delivered over the plan period

    (d) Being consistent with national policy – meeting the requirements of the National Planning Policy Framework

    A schedule of the Main Modifications is included in the consultation documents.

    Q3i. What’s the summary of the key changes?

    The key changes are in response to directions given by the Planning Inspector. The changes propose to protect Old Oak North for industrial employment uses and to release Channel Gate from industrial employment uses to deliver mixed-use housing-led development. Changes have also been made to the phasing and development capacity and land use of some other sites to ensure that these sites help to better meet housing needs during the next 20 years.

    Q3j. Are you proposing any changes to the transport connections?

    Yes. We have updated our transport connection plans in light of the changes in land uses to ensure the OPDC area still benefits from improved access to public transport and active travel networks. 

    In relation to streets, the previously proposed through-routes through Old Oak North are no longer being delivered. The delivery of an east-west road (Wormwood Scrubs Street) between Scrubs Lane and Ladbroke Grove has been brought into the Local Plan period. New streets are proposed within Channel Gate.

    In relation to railways, Old Oak Common Station will continue to be delivered alongside enhancements to North Acton Station and Willesden Junction Station. Hythe Road Overground Station is no longer being delivered and Old Oak Common Lane Station is proposed for delivery as a ‘potential’ new station as it’s not required to support development.

    In relation to buses, we’ve revised our Bus Strategy with Transport for London. This proposes bus connections to Old Oak Common Station, Park Royal, Old Oak Major Town centre, other town centres and to Kensal Canalside Opportunity Area.

    In relation to walking and cycling, we’re planning for new/improved routes within Old Oak North, a new eastern access to the Old Oak Common Station, new routes in Channel Gate and changes to how the central junction and roads could be improved in Park Royal.

    Q3k. Are you proposing any new green space?

    Yes. We’re still proposing that development provides 30% of its area as public open space. As part of this, we’re planning for the delivery of two 2-hectare Local Parks with one in Channel Gate and one next to Old Oak Common station, alongside a range of smaller open spaces, including improvements and expansions to existing open spaces. In addition to this, new housing will be delivered with both private open space and communal open space for each development.

    Q3l. What will be included in the Old Oak Major Town Centre?

    The Old Oak Major Town Centre will include a range of vibrant shops, cafés, restaurants, community and cultural facilities, workspaces and lively open spaces. It will be delivered in phases supporting both existing communities and new neighbourhoods as they are developed to ensure everyone has easy access to it.

    Q3m. Where are the key areas of change in the Local Plan?

    Much of the Local Plan stays the same, so our targets around sustainable travel, high quality design, environmental sustainability and affordable housing are all as they were in the previous Local Plan. The key areas of change respond to the Inspector’s Interim Findings and relate to sites we envisage our planned growth to occur on. These changes are focussed on four key geographic areas:  

    1. Old Oak North

    Previously the draft Local Plan identified Old Oak North as a place for a predominantly housing-led community. The Planning Inspector’s interim findings for Old Oak North found that housing was not viable and removed two key housing sites. In response to the interim findings, we are proposing to designate Old Oak North as industrial land (Strategic Industrial Location) for employment use only. The changes to the Plan also support industrial intensification, which means using land more efficiently so that more industrial business space can be delivered. Delivering more floorspace will create opportunities for existing businesses to stay and expand, but also for new jobs and businesses to locate in Old Oak North. There will also be other facilities to support the increased numbers of employees, businesses and their visitors, such as canal side open space and small cafes. Although the amount of non-residential floorspace has increased, jobs have decreased as more industrial floorspace is being delivered which typically delivers less jobs per square metre compared to office-based jobs.

    Old Oak NorthOriginal approachProposed Approach
    Land use
    Residential led, mixed use. Old Oak Major Town Centre
    Industrial uses, employment space and associated uses for employees/visitors like small shops and cafes
    Building heightsRange of building heights and an area where tall buildings are appropriate in principle

    Building heights and multi storey industrial buildings that support industrial intensification. 

    Area where tall buildings are appropriate 

    Homes  
    6,500 homes
    0 homes
    Jobs and non-residential floorspace

    3,600 jobs, 68,100sqm

    3,300 jobs, 212,600sqm

    Public realm
    • Two new local parks 
    • New lively attractive ground floor uses and spaces for people to enjoy
    • New Canalside open space
    • New lively attractive ground floor uses and spaces for people to enjoy
    Infrastructure
    • Provision for all transport modes (walking, cycling, buses, vehicles)
    • Two proposed new road connections (Union Way & Old Oak Street)
    • Potential new Hythe Road station
    • New/improved walking/cycling connections
    • Improved roads
    • Safeguarding for one potential new road connection from Scrubs Lane


    2. Scrubs Lane

    The Planning Inspector’s interim findings in Old Oak North affected allocations on some sites on Scrubs Lane and directed their removal for mixed-use development from the Local Plan. We consider that the sites on Scrubs Lane are developable and are proposing to the Planning Inspector that they remain allocated for a mix of uses. 

     There is also a new development site south of the Grand Union Canal called the North Pole East Depot, which is now available for development. 

    These changes will continue to result in Scrubs Lane being a well-connected neighbourhood in its own right, home to 3,500 new homes, 1,100 new jobs and five clusters of lively uses (including shops, local facilities, community uses and places to socialise) each with new and/or improved open spaces. 

    Scrubs LaneOriginal approachProposed Approach
    Land use
    Residential led, mixed use. four clusters of shops, cafes and facilities
    Residential led, mixed use. five clusters of shops, cafes and facilities
    Building heightsRange of building heights with 4 tall buildings
    Range of building heights with 6 tall buildings
    Homes  
    2,600 homes
    3,500 homes
    North Pole East Depot now identified for delivery within the Plan period.
    Jobs and non-residential floorspace
    1,200 jobs
    1,100 jobs
    Public realm
    • Four new open spaces
    • New lively attractive ground floor uses and spaces for people to enjoy
    • Five new open spaces
    • New lively attractive ground floor uses and spaces for people to enjoy
    Infrastructure
    • New/improved walking and cycling routes
    • New east-west road connections 
    • New/improved walking and cycling routes
    • New east-west vehicle, walking and cycling road connections (Wormwood Scrubs Street)
    • Safeguarding for a potential new road connection from Scrubs Lane into Old Oak North 


    3. Channel Gate

    Channel Gate is to the west of Old Oak Lane and extends north and south of the Grand Union Canal. Most of this site has been acquired and cleared by HS2 as a construction compound. The site was previously designated as industrial land (Strategic Industrial Location) in the draft Local Plan. We are now proposing that the site is allocated for housing, so that it can deliver new and affordable homes, as well as deliver some shops, cafés and restaurants, employment uses and social infrastructure, centred around a new 2-hectare public park.

    Channel GateOriginal approachProposed Approach
    Land use
    Commercially focussed hub. Part of Old Oak Town Centre
    Commercially focussed hub. Part of Old Oak Town Centre
    Building heightsArea where tall buildings are appropriate
    Area where tall buildings are appropriate
    Homes  
    0 homes
    3,100 homes
    Jobs and non-residential floorspace

    7,600 jobs, 124,000sqm 

    600 jobs, 10,700sqm 

    Public realm
    • Expansion and enhancement of Old Oak Community Gardens
    • Canalside open space
    • New lively attractive ground floor uses and spaces for people to enjoy
    • New 2-ha public park
    • Expansion and enhancement of Old Oak Community Gardens
    • Canalside open spaces
    • New lively attractive ground floor uses and spaces for people to enjoy
    Infrastructure
    • New/improved walking and cycling routes
    • New/improved roads
    • New/improved walking and cycling routes
    • New/improved roads
    • New social infrastructure


    4. Other High Speed 2 work sites

    The station site and sites to the west (known as Acton Wells East and West in the draft Local Plan) were proposed for release from industrial land in our previous draft Local Plan in order to deliver housing and town centre uses. The modifications change the numbers of homes and jobs on these sites, taking account of more recent development capacity modelling. These changes will continue to deliver a dynamic new high density mixed-use area, focused on open spaces and the Old Oak Major Town Centre connecting the Old Oak Common Station to an enhanced North Acton Centre.

    Old Oak Common Station SiteOriginal approachProposed Approach
    Land use
    Industrial land
    Residential led mixed use. Part of Old Oak Town Centre
    Building heightsRange of building heights to support high density industrial development
    Range of building heights. Includes areas where tall buildings will be considered appropriate away from sensitive locations.
    Homes  
    0 homes
    100 homes
    Jobs and non-residential floorspace

    15,200 jobs, 178,400sqm 

    17,100 jobs, 200,500sqm 

    Public realm
    • New 2 ha local park
    • Improve existing open space
    • New lively attractive ground floor uses and spaces for people to enjoy
    • New 2 ha local park
    • Improve existing open space
    • New lively attractive ground floor uses and spaces for people to enjoy
    Infrastructure
    • New routes for walking, cycling, buses and cars. (Old Oak Street linking North Acton, Old Oak South and Old Oak North)
    • New routes for walking, cycling, buses and cars. (Old Oak Street linking North Acton and Old Oak South)
    • Walking and cycling eastern access connection


    Acton WellsOriginal approachProposed Approach
    Land use
    Mixed use
    Mixed use
    Building heightsRange of building heights. Includes areas where tall buildings will be considered appropriate away from sensitive locations.
    Range of building heights. Includes areas where tall buildings will be considered appropriate away from sensitive locations.
    Homes  
    1,300 homes
    2,205 homes
    Jobs and non-residential floorspace

    1,800 jobs, 21,700 sqm

    3,200 jobs, 38,000sqm

    Public realm
    • New open spaces
    • New lively attractive ground floor uses and spaces for people to enjoy
    • New open spaces
    • New lively attractive ground floor uses and spaces for people to enjoy
    Infrastructure
    • New/improved walking and cycling routes
    • New/improved roads
    • Area of search for new secondary school
    • New/improved walking and cycling routes
    • New/improved roads 
    • Area of search for potential GP health centre 

    Q3n. Do the modifications deliver the same benefits as the previous version?

    Yes. We think that the proposed modifications provide an improved and more deliverable Local Plan for the Old Oak and Park Royal area while maintaining our existing overall vision. 

    It delivers new homes and space for jobs across a wider spread of sites, including more publicly owned sites, that are better connected to existing neighbourhoods and the Old Oak Common Station while also benefiting from lower infrastructure costs, making our revised plans more deliverable. 

    There is a greater amount of industrial floorspace being proposed than previously which will help to better meet local and London-wide industrial needs and deliver a greater diversity of jobs.

    Importantly, key landowners have expressed their in-principle support for the new land uses and homes and jobs targets for their landholdings.

    Q3o. How have you engaged with key stakeholders while developing your modifications?

    We undertook extensive engagement with residents, businesses, landowners, public bodies and other community stakeholders to inform the development of our modifications. 

    Key landowners and relevant public bodies have provided Statements of Common Ground to the inspector. This is to confirm:

    • That the GLA and TfL consider our modified draft Local Plan to be in general conformity with the London Plan.   
    • Landowners are willing and supportive of their site being allocated for a particular land use, number of homes, spaces for jobs and when they will be built. 

    OPDC’s officers undertook an informal programme of community engagement on the emerging draft Local Plan modifications from 24 November to 18 December 2020. This engagement was publicised on our website and social media channels alongside advertisements in local newspapers. Emails were sent to stakeholders, community groups and a leaflet was produced to explain the proposed modifications to the draft Local Plan. Officers held two virtual community meetings, these were attended by 71 residents and interested parties and also offered to meet individual resident groups to present the proposed modifications. Although this was not a formal consultation, we invited community members to make comments on the proposed draft modifications. Verbal comments were made during the two community meetings and these were responded to during and after the meeting. Some other comments were also sent by email. These comments have been used to inform the development of evidence and proposed modifications to the draft Local Plan.

    Q3p. How do I understand what the track changes in the Local Plan relate to?

    We understand that navigating the proposed changes is complex. We’re here to help make the information as accessible as possible to help you provide responses. 

    The below provides information for how to find and understand the modifications. If you need further advice, contact as at localplan@opdc.london.gov.uk or 020 7983 6520.

    The track changes in the Local Plan relate to modifications that have been made to the draft Local Plan in response to directions from the Planning Inspector. They comprise of either ‘Main’ or ‘Minor’ modifications:

    • Main Modifications are changes made to the Local Plan to ensure that it is found ‘sound’ by the Inspector (see FAQ Q2b for what being sound relates to).
    • Minor Modifications are less significant modifications that aren’t required for the plan to be found ‘sound’.  (see FAQ Q2c).

    An example of how the track changes are shown in the Local Plan is below:


    The track changes in the modified Local Plan have a code for each change which relates to the tables of text Main and Minor modifications and include a short description for each amendment. Modifications within Appendix A and B are coded:

    For Main Modifications:

    • Modifications with the reference MM/PS2/OPDC/REF are Main Modifications made to address the Inspector’s interim findings, ensure general conformity with the London Plan, ensure alignment with the amended Use Class Order or address typographical errors or factual corrections. 
    • Modifications with the reference MM(1-17)/PS/REF are Main Modifications made in response to requests from the Planning Inspector during the examination between November 2018 and August 2019, up to the point of the Inspector’s interim findings.  

    For Minor Modifications:

    • Modifications with the reference MINOR/PS2/OPDC/REF are Minor Modifications that have been made after the publication of the Inspector’s interim findings to correct typographical errors and where appropriate, factual updates.
    • Modifications with the reference MINOR/GeneralREF or MINOR/2/REF are Minor Modifications that were made to the draft Local Plan following Regulation 19(2) public consultation in July 2018 and prior to the submission of the draft Local Plan to the Secretary of State in October 2018. These modifications have already been approved by the OPDC Board at its 28 September 2018 meeting. 
    • Modifications with the reference MINOR/PS/REF are Minor Modifications made to the draft Local Plan in response to requests from the Planning Inspector during the examination between November 2018 and August 2019, up to the point of the Inspector’s Interim findings.

     An example of how the track changes are shown in the tables of text modifications is below:


    Q3q. Have the diagrams and maps in the Local Plan been modified and if so, how can I see these changes?

    The Table of Figure Modifications shows and describes amendments that have been made to figures/maps within the modified draft Local Plan. The image on the left side of the page shows the map as it was in the submission draft Local Plan (October 2018) and the figure on the right shows the modified figure.

     An example of how the track changes are shown in the table of figure modifications is below:



    Q3r. What version of national policy is OPDC’s modified Local Plan being assessed against?

    It is worth noting that because we submitted our Local Plan for examination in October 2018, our Local Plan is being assessed against an older version of national policy – the 2012 National Planning Policy Framework. The Government published an updated National Planning Policy Framework in 2019, which more recently submitted Local Plans are having to accord with. 

    The 2012 National Planning Policy Framework can be viewed here.

    Q3s. Will the Local Plan be reviewed after adoption? And how could it be shaped by current Government planning reform proposals?

    We will take a proactive and flexible approach to reviewing parts of, or all of the Local Plan after it is adopted. The review process will be managed and reported through our annual Planning Authority Monitoring Reports. Currently, we are required to review the Local Plan every five years.

    The Government is currently consulting on various planning reforms set out in the Government’s Planning for the Future White Paper. These reforms, if implemented, will change how future Local Plans are produced, consulted on and updated. We’re monitoring these proposals and will ensure any review of the Local Plan accords with the latest Government legislation, policy and guidance.

Supporting studies

    Q4a. What are Local Plan supporting studies?

    Supporting studies are research documents produced by OPDC or its partners to underpin the policies set out in the Local Plan and ensure they are justified. We have produced a series of new or updated studies to inform the proposed Local Plan modifications.

    Q4b. What’s changed from the previous Bus Strategy?

    The Bus Strategy has been updated to reflect the revised development capacities and phasing of the modified draft Local Plan and to account for the changes to the road network and infrastructure requirements. The updated Bus Strategy sets out a range of new and revised bus routes which will ensure that existing and new communities within the modified Local Plan will be well connected to rail stations, town centres and other destinations. Routes provide connections to Old Oak Common Station, Park Royal, Old Oak Major Town centre, other town centres and with a new link via Wormwood Scrubs Street from Scrubs Lane to Ladbroke Grove and Kensal Canalside Opportunity Area.

    Q4c. What is the purpose of the Channel Gate Development Framework Principles?

    The Channel Gate Development Framework Principles is a new supporting study for the Local Plan. The modified draft Local Plan is proposing to release Channel Gate from Strategic Industrial Location (SIL) so that it is delivered for housing-led, mixed-use development. It sets out a clear series of principles for the future development of Channel Gate, and the key role that development here will play in supporting the overall regeneration of the OPDC area. It identifies that Channel Gate has the potential to deliver a new residential led, mixed-use neighbourhood of a minimum of 3,100 new homes, and 600 new jobs. The document identifies the infrastructure needed to support redevelopment of the area such as a new street network, a new two-hectare Local Park and community facilities.

    Q4d. Why is Channel Gate now considered appropriate for mixed-use development when it wasn’t previously?

    Channel Gate is largely comprised of cleared sites being used in association with the construction of the HS2 station at Old Oak Common. In the previous version of the draft Local Plan, land at Channel Gate was identified as Strategic Industrial Location (SIL) with the potential to deliver significant industrial intensification to address the loss of industrial floorspace elsewhere in Old Oak. The Inspector’s Interim Findings in relation to Old Oak North have meant that approximately 6,000 homes are no longer deliverable within the next 20 years. To ensure that the redevelopment in Old Oak and Park Royal continues to meet housing needs, OPDC is now proposing to release the SIL designations and identify Channel Gate for housing-led mixed use development. 

    There are a several reasons why Channel Gate is an appropriate site to allocate for housing-led mixed use development. The size of the area, and its location near to Harlesden town centre, Willesden Junction and the future Old Oak Common station, access to existing key routes and its setting on the Grand Union Canal make it ideally suited to deliver a major renewed residential-led, mixed-use community, that is an enjoyable, accessible and inclusive place to live, work and visit. With the majority of the site being in public ownership, and the acquisition and clearance of this land for the construction of HS2, there is an opportunity for a coordinated comprehensive approach to the delivery of this new neighbourhood.

    An illustration showing how Channel Gate could be developed.

    Q4e. What’s changed from the previous Development Capacity Study?

    The Development Capacity Study Update confirms that based on updated and new site development capacity and phasing for the 2018 to 2038 plan period, the number of homes has slightly decreased from 20,100 to 19,850 homes. Economic floorspace (space for employment and retail uses) has increased from 811,200 square metres to 871,350 square metres while the number of jobs has decreased from 40,400 to 36,350. 

    The increase in the economic floorspace is largely due to changes that now support industrial intensification in Old Oak North. Industrial intensification will create more floorspace for existing businesses to stay and expand, but also for new jobs and businesses to locate in Old Oak North. Although the amount of economic floorspace has increased, jobs have decreased as more industrial floorspace is being delivered which typically delivers less jobs per square metre compared to office-based jobs.

    Q4f. How has the modified development capacity and phasing of sites been identified?

    We’ve continued to follow national guidance for identifying updates to the amount and phasing of homes and economic floorspace for each modified and new site. This means the Development Capacity Study Update has reflected information set out in new and updated supporting studies (e.g. the Channel Gate Development Framework Principles and Industrial Land Review Addendum), recent planning permissions and updates from landowners wishing to bring their sites forward for development.

    Q4g. What’s changed from the previous Grand Union Canal Massing and Enclosure Statement?

    Due to the sensitive nature of the Grand Union Canal, we have produced a supporting study to consider what heights would be generally appropriate along the canal. 

    The Grand Union Canal Massing and Enclosure Statement relates to areas outside of Strategic Industrial Locations. Because of the changes to land use designations that we’re now proposing, we have carried out the assessment for Channel Gate which is now proposed for release from Strategic Industrial Location. The assessment has not resulted in changes to the original recommendations. These still generally propose 6-8 storeys with taller buildings at the crossing of key routes, to support people finding their way. Heights along the canal will be informed by the need to protect the character and heritage of the canal and support the delivery of new homes and space for jobs. An illustration showing how sites along the Grand Union Canal in Channel Gate could be developed.

    Q4h. What’s changed from the previous Industrial Land Review Addendum?

    The Industrial Land Review Addendum replaces the previously published addendums. The 2021 addendum makes recommendations to retain or release (de-designate) sites within the Strategic industrial Location. The recommendations seek to address the Inspector’s Interim Findings for Old Oak North, whilst also ensuring general conformity with the London Plan with respect to OPDC’s housing targets and industrial capacity. The Study proposes to:

    • Retain the SIL designation on sites in Old Oak North, which will allow businesses there to remain and expand.
    • Release (de-designate) the Channel Gate site, as well as small parcels of land on Park Royal Road and School Rd/Victoria Rd. We are proposing that these sites are redeveloped to meet housing needs. 

    The Study also demonstrates the potential for a net gain of 250,428 sq.m. of industrial floorspace capacity across the Local Plan period.    

    Q4i. What’s changed from the previous Infrastructure Delivery Plan?

    The Infrastructure Delivery Plan (IDP) has been updated to set out the revised infrastructure requirements for the area, resulting from the modifications to the draft Local Plan. 

    In addition to identifying the revised infrastructure requirements, the updated IDP also includes a more detailed assessment of how much infrastructure will cost and how it will be funded. This assessment has identified that £347 million of the costs will require funding from planning contributions or other sources. When estimated planning contributions are considered, a funding a gap of between £136 million and £202 million exists and the IDP points to potential funding sources which could meet this funding gap.

    Q4j. What is the funding gap and how does OPDC expect it will be addressed?

    The funding gap represents the estimated infrastructure cost for which no specific funding has been identified, such as from projected planning contributions or general development costs. While a potential funding gap of up to £202 million as identified for the draft Local Plan is significant, it is not unusual for a project of the scale and complexity of Old Oak and Park Royal and is considered to be a reasonable and realistic infrastructure investment when considered against the level of economic growth that will be delivered in the OPDC area. It is also less than the £250m previously awarded to OPDC in principle by Government, through its Housing Infrastructure Funding (HIF). The IDP sets out several options for how the funding gap can be addressed, including national infrastructure funding programmes, or opportunities to borrow against value generated by future development.

    Q4k. What’s the role of the Integrated Impact Assessment Addendum and Habitat Regulation Assessment?

    The Integrated Impact Assessment Addendum (IIA) and Habitat Regulation Assessment (HRA) have been carried out to assess the impacts of the proposed modifications in relation to sustainability, health, equalities and recognised Natura 2000 sites. The outcome of the assessments show that the modifications result only in either positive or neutral outcomes and that in relation to the Natura 2000 sites, the next stage comprising an ‘Appropriate Assessment’ is not required.

    Q4l. What is the purpose of the Old Oak North Intensification Study?

    The Old Oak North Intensification Study is a new supporting study for the Local Plan. The modified draft Local Plan proposes to retain Old Oak North as part of the Strategic Industrial Location, protecting the land for employment use, so businesses there can remain and expand. The Old Oak North Intensification Study has been prepared to establish opportunities (place making principles) to make the area a better place to work in and visit. It also looks at the potential to use land more efficiently so that more industrial business space can be delivered (referred to as industrial intensification) and identifies that 212, 584 sq.m. of new industrial floorspace could come forward in Old Oak North.

    Q4m. What is the purpose of the Preliminary Infrastructure Design and Costing Study?

    The Preliminary Infrastructure Design and Costing Study is a new supporting study for the Local Plan. It sets out preliminary designs and costings for the key infrastructure required to support the delivery of revised site allocations in the modified draft Local Plan, including new and enhanced highways, junctions and bridges, walking and cycling routes, public open spaces and social infrastructure. The study also provides generalised infrastructure costs to be applied to other area-wide infrastructure. These costs have been used to update the Infrastructure Delivery Plan and to provide more specificity on the overall infrastructure costs and potential funding gap.

    Q4n. What’s changed from the previous Scrubs Lane Development Framework Principles?

    Within the Scrubs Lane Development Framework Principles Update, the guiding principles for development along Scrubs Lane have broadly remained the same, including the identification of clusters of shops, cafés, restaurants and services, where east to west routes meet Scrubs Lane and support for a tall building within each cluster. The changes relate to a greater emphasis on town centre uses within clusters; North Pole East Depot being delivered in the plan period; a new cluster being identified at the North Pole East Depot where Scrubs Lane meets the new Wormwood Scrubs Street; a new tall building within this new cluster, an additional tall building within the Hythe Road Cluster and varied heights within clusters. This results in 3,500 new homes for the area where previously 2,600 were identified.

    Q4o. Why is Scrubs Lane still an appropriate location for housing and tall buildings?

    Scrubs Lane will continue to be well connected to existing and new neighbourhoods within easy reach of public transport, town centre uses, services and open spaces. These include Old Oak Common station, Harlesden town centre, an enhanced Willesden Junction Station, Kensal Canalside Opportunity Area and White City Regeneration Area.

     The place itself will provide 3,500 new homes, five clusters of town centre-uses (such as shops, local facilities, community uses and places to socialise), each with new and/or improved open spaces. The design policies specific to Scrubs Lane and those for the whole OPDC area will ensure it will be a well-designed and sustainable place, shaped by the surrounding heritage and movement routes. A coordinated approach to well-designed tall buildings within each cluster is appropriate to help people to navigate to new east to west routes and the clusters of town centre uses. The delivery of well-designed buildings is set out in Local Plan policy D3. This would include responding positively to the existing or new character, positively contributing to the townscape, use of high quality materials and details that enhance local character, well-designed internal spaces, supporting sustainability and security of development.An illustration showing how Scrubs Lane could be developed

    Q4p. Have the impacts on Scrubs Lane's local heritage of building heights proposed in the modifications been assessed?

    Yes. We have updated the Scrubs Lane Strategic Views Assessment and have appended this to the Scrubs Lane Development Framework Principles Update. The Strategic Views Assessment has reflected the changes to building heights proposed in the modifications using new modelling software. The outcome of the assessment does not differ from the previous assessment. In summary, it concludes that the proposed building heights are appropriate, if designs of individual developments are of a high quality. The design quality of individual developments will be considered when determining specific planning applications, rather than the Local Plan itself.

    Q4q. What’s changed from the previous Social Infrastructure Needs Study?

    Within the Social Infrastructure Needs Study Addendum changes have been made to the amount and phasing of social infrastructure required to support the needs of development in the OPDC area, taking into account the changes in development sites. These changes have been informed by discussions with service providers and other stakeholders alongside an updated understanding of availability of existing facilities, updated development capacities and GLA population modelling. The changes have resulted in the need for a smaller on-site primary school (four forms of entry reduced to three forms of entry), removal of the need for an on-site secondary school, change to the phasing for delivering the two community centres and the change in location of the GP health centre from Old Oak North to North Acton and Acton Wells. These requirements will be kept under review as delivery of development progresses as it is extremely important that we deliver the right facilities and social infrastructure when bringing forward new development. 

    Q4r. Why have only four sites been assessed as within the Strategic Site Allocations Viability Assessment?

    As set out in Planning Practice Guidance (PPG) paragraph 005, it is important to consider the specific circumstances of strategic sites that provide a significant proportion of planned development. This is generally accepted to be those sites that are anticipated to provide at least 5% of an area’s envisaged development. As a result, four specific sites have been assessed within the Strategic Site Allocations Viability Assessment to determine their viability for development. These sites are Old Oak North and EMR, which have industrial allocations and Channel Gate and North Pole East Depot which have housing allocations.

    Q4s. What do the results of the Strategic Site Allocations Viability Assessment show?

    The industrial site allocations (Cargiant and EMR) are viable. Channel Gate can viably deliver 25-35% affordable housing without an affordable housing grant from Government and at least 40% with a grant. North Pole East Depot can viably deliver 5-25% affordable housing without grant and at least 35% with grant.

    Q4t. What’s changed from the previous Tall Buildings Statement?

    Within the Tall Buildings Statement Update, the definition of a tall building remains the same, at a minimum of 15 storeys or a minimum of 48 metres above ground level. The areas where tall buildings will be appropriate have been updated to reflect the changes in land uses and development sites and better reflect phasing. These include smaller areas in Old Oak South and Old Oak North, an additional two tall buildings on Scrubs Lane. Channel Gate is identified as an appropriate area, alongside 5-7 Park Royal Road and the whole Brewery Cluster in the west of Park Royal is identified as appropriate.