NEW SOUTHWARK PLAN
The New Southwark Plan (NSP) has been in preparation since 2013, and been through a number of consultations. The Council consulted on the Submission Version of the Plan between November 2017 to February 2018 and on the Amendments to that version of the plan between January and May 2019. The Council will now consult on a version of the plan called New Southwark Plan (Southwark Council’s Proposed Changes to the submitted New Southwark Plan, June 2020). Consultations will take place between 27 August 2020 and 26 October 2020.
On this page you will find information about the NSP consultation the Examination in Public (EiP), as well as details about the workshops we will be organising to support local people in submitting comments to the Council on the NSP and making representations in the EiP.
FAQS
The New Southwark Plan Consultation (27 August 2020 - 26 October 2020)
This version of the plan incorporates the following changes from the New Southwark Plan Proposed Submission Version 2017:
Amended policies version consulted on from January-May 2019
Minor amendments in response to consultation from the 2017 and 2019 consultations (tracked changes)
Further amendments in response to the Inspector’s queries in their letters dated 20 April and 2 June 2020 (purple tracked changes).
The consultation on this version of the plan provides opportunities for:
People/organisations who have not previously commented to make comments across the whole plan.
People/organisations who have commented before their comments must only relate to the new changes.
The Inspectors will take account of all comments to the 2017 and 2019 consultations so these do not need to be re-submitted. People who respond to the 2020 consultation will be able to make representations at the EiP hearings next year, as can people who submitted comments to the earlier consultations in 2017 and 2019.
This consultation will focus on the NSP (Southwark Council’s Proposed Changes to the Submitted New Southwark Plan 2020) as well as a number of updated evidence base documents that have been submitted to the Inspectors after the submission of the plan.
1. WHY IS THERE ANOTHER CONSULTATION?
The plan as submitted to the inspector is too substantially different to the proposed submission version of the plan, which was consulted on in 2017/18.
The 2019 Amended Policies Version (APV) consultation did not comply with the legal requirements. The Statement of Representations Procedure requires responses should be allowed in writing or by way of electronic communications. The amendments following the 2019 (APV) consultation have not been presented as main modification in the 16 January 2020 submission version of the NSP.
2. WHERE CAN I FIND THE DOCUMENTS FOR THE NSP CONSULTATION AND EIP?
The information is across the web pages:
Examinations Documents (new documents)
Submission Documents (previously submitted to the inspectors)
3. WHO CAN RESPOND TO THIS LATEST CONSULTATION?
The Inspectors have agreed with Southwark Council that people who have already commented on the earlier versions of the plan can only comment on the new amendments.
People who have not commented before can comment on the whole plan.
The Inspector’s views are set out in their letters to the council (Documents EIP14 and EIP25 on this page of the council website “Administrative Documents”).
4. WHAT DID THE INSPECTORS' LETTER SAY ABOUT THE CONSULTATION?
Inspectors' comments:
"We will be taking into account all duly made representations on the 2017/18 Proposed Submission Version plan. We will also take into account those representations already received on the 2019 Amended Policies Version content. Accordingly, as part of the next consultation we do not want people to re-submit representations that have already been made on either the PSV or APV plan content.
When making comments, we would want representations to be clear which proposed change/main modification reference they were commenting on. We do not consider it necessary that the whole plan is reconsulted on again."
5. WHAT DOES THE INSPECTORS’ APRIL LETTER SAY ABOUT THE PLAN?
Inspectors’ letters have useful information about the New Southwark Plan. In their April letter, Inspectors asked the Council to withdraw the plan because it was unsound. The second option offered by the Inspectors - which they did not favour because the Council is consulting on a document produced 3 years ago - was to reconsult; this is the option the council have chosen.
The main issues identified by the inspectors included:
Spatial strategy and considerations for housing and employment
Sustainability appraisal, Integrated Impact Assessment, Site Selection and Flood Risk
Plan-wide viability
Gypsies and Travellers and caravan/houseboat residents' needs
6. HOW IS THE COUNCIL RESPONDING TO THIS LETTER?
The Council is publishing much of the additional material and background documents to answer the Inspector’s queries. However the various issues raised in the Inspector’s letter are potential areas where the plan is unsound.
7. WHAT ABOUT THE STATEMENT OF COMMUNITY INVOLVEMENT?
Southwark Council’s Statement of Community Involvement (SCI) says that it will carry out 6 weeks informal consultation before the 6 weeks formal consultation.
At the time the coronavirus crisis hit, the council was consulting on its amended SCI. This consultation has been suspended and it is unlikely to resume until after the next NSP consultation.
The guidance on plan-making provided by the government was updated to account for the fact that many SCI’s will not be able to be complied with during the on-going restrictions related to coronavirus. This amendment stated the following:
“Should the Statement of Community Involvement be reviewed and updated in response to the coronavirus (COVID-19) pandemic?
Where any of the policies in the Statement of Community Involvement cannot be complied with due to current guidance to help combat the spread of coronavirus (COVID-19), the local planning authority is encouraged to undertake an immediate review and update the policies where necessary so that plan-making can continue.”
At present, the council have not updated the current SCI policies, as far as we are aware. The consultation plan for the next NSP consultation only makes comments in respect of changes to the draft SCI, which has not yet been adopted by the council.
8. HOW WILL THE COUNCIL BE CONDUCTING THE CONSULTATION OF THE NEW SOUTHWARK PLAN?
The Council has published a statement of consultation (EIP74), which we believe is an extremely limited attempt at consultation. The government produced guidance on how to proceed with consultation during COVID-19. Some examples include: using video-conferencing platforms, using advocates to support those who cannot access the digital world.
The council will be sending information about the consultation to those subscribed to the Council’s mailing list on planning issues, through Southwark News and advertised on social media.
The Council should be urged to improve consultation arrangements and SPN members should point out any barriers and concerns in their consultation responses.
9. HOW CAN WE SEE WHO HAS COMMENTED ON THE PLAN SO FAR?
The documents EIP05 and EIP06, provide the names of everyone who has commented on the proposed submission version and the amended policies version of the plan so far, including where to find the comment in the full lists of the consultation responses.
An issue is how to reach these people where we do not know them and their contact details are redacted. New Southwark Plan Examination: Examination Documents, see the Representations heading and this has a list of reports. The list refers to both the amended and submission versions of NSP.
10. HOW CAN WE SEE WHO HAS RESPONDED AND HOW CAN WE FIND A RESPONSE?
List of responders Proposed Submission Version 2020 – ref no. EIP 05 – download full list of respondents. Shows the ref no. and which report where the comment is. The consultations responses are contained in several reports.
Find the report listed in the Representations section. Earlier consultation responses are PDFs and the online hub responses are in a spreadsheet. Go to the ref no. this is stamped onto individual responses on the PDF. If the response was made online and shown on the spreadsheet it contains all the questionnaire fields. Responses are split up and allocated across the policies – see below.
11. HOW CAN WE SEE PREVIOUS CONSULTATION COMMENTS ON A SPECIFIC POLICY OR SITE ALLOCATION?
Previous consultation comments are all together on the website page which is for documents already submitted to the Inspectors: Submission docs
The web page is set out by policy area e.g. Area Visions, Policies, Site Allocations, structured with background docs, evidence base and consultation responses. The responses are anonymised and have the council response. The documents named "consultation reports" explain the consultation process; they do not contain any summary of all the responses.
12. ARE THERE OTHER WAYS I CAN ACCESS THE CONSULTATION DOCUMENTS?
The documents are available for public inspection in Southwark libraries and you can also request to view the physical copy at the Council’s offices at 160 Tooley Street, and ask for assistance from council officers with accessing the documents online in both the office and libraries.
13. WHAT AMENDMENTS HAVE BEEN MADE THAT COULD BE OF RELEVANCE TO SOUTHWARK PLANNING NETWORK MEMBERS?
Area Visions
The only Area Vision that appears to have significant changes is the Aylesbury Area – see section on growth opportunities (EIP27B p. 42 Tracked Changes version)
Strategic policies
SP1 Quality affordable homes: changes include:
Proposed to increase the proportion of social rented and intermediate housing provided by new developments to 50% of total, in line with the London Plan. This is to be achieved by encouraging developers to exceed the 35% target for social rented and affordable housing.
Encouraging developers to receive affordable housing grant to increase the provision of social rented and intermediate housing
Encouraging developers to provide more social rented and intermediate housing through the fast track route.
Figures are provided for an increase in housebuilding from current levels (1500 – 18,00 per year) to 2235 per year. (Look at Site Allocations for details of where these homes are to be built.)
SP6 Cleaner Greener Safer. The Council declaration of a climate emergency by becoming net zero by 2030 is mentioned in this section.
Development management policies. The policies likely to be of interest to SPN members where there appear to have been significant changes are:
P1 Social rented and intermediate housing (EIP27B Tracked Changes version p. 79)
P2 New family homes
P4 Private rented homes
P5 Student homes
P7 Wheelchair accessible and adaptable housing
P11 Homes for Travellers and Gypsies
P14 Residential design
P16 Tall buildings
P22 Archaeology
P25 Local list
P28 Strategic protected industrial land
P30 Affordable workspace
P34 Town and local centres
P44 Healthy developments
P45 Leisure arts and culture
P53 Car parking
P64 Improving air quality
14. WHAT ARE THE MAIN NEW SUPPORTING POLICY DOCUMENTS CHANGES?
In addition to the NSP there are background research reports and impact assessments which provide the supporting evidence for the policy. The following are published this summer:
EIP23 Habitats Regulation Assessment
EIP20 Viability Background Paper
EIP15A Flood Risk Assessment
EIP22 Gypsy and Traveller Accommodation Assessment Report
EIP54 Tall Buildings Background Paper
EIP72 Integrated Impact Assessment
EIP77 Health Impact Assessment
EIP76A Equality Impact Assessment
15. HOW DOES THE NSP RELATE TO THE COUNCIL’S CLIMATE EMERGENCY STRATEGY (DRAFT JULY 2020)?
The Council will shortly be publishing a draft Climate Emergency Strategy for consultation. This is likely to have significant implications for planning policy and require policy amendments to the New Southwark Plan. The Southwark Planning Network will keep members updated on the draft Climate Emergency Strategy.
SPN WORKSHOPS
We will be organising three topic-based workshops on the New Southwark Plan during the consultation period.
We held Workshop 1 - Transport & Travel and Cleaner, Greener, Safer on Monday 21st September 2020, 7-9pm
Workshop 2 - Industrial Land, Workspace, High Streets and Employment - Wednesday 7th October 2020, 7-9pm
If you would like to attend this workshop, please register on the Eventbrite page for Workshop 2 by Tuesday 6th October 2020 6pm in order to receive the zoom link.
SPN NSP Workshop 3 - Housing (including homes for Gypsies and Travellers) and Building Design, Size and Conservation - Saturday 10th October 2020, 2-4pm
If you would like to attend this workshop, please register on the Eventbrite page for Workshop 3 by Friday 9th October 2020 6pm in order to receive the zoom link