GREATER LONDON AUTHORITY
WESTMINSTER CITY COUNCIL
INSPECTOR’S REPORT
INTO
OBJECTIONS
TO
THE WESTMINSTER UNITARY DEVELOPMENT PLAN REVIEW
PART II (CRITERIA-BASED POLICIES)
CHAPTER 11 : RIVER THAMES
Inspector: J P MacBryde DA(Edin) DipTP(Lond) ARIBA MRTPI MCIT FRSA
Assistant Inspector: G E Roffey BA(Hons) DipTP MRTPI
Dates of Inquiry: 15 October 2002 – 28 March 2003
PINS File Ref: X5990/429/3
City of Westminster Unitary Development Plan review – Inspector’s Report
Chapter 11 : River Thames
City of Westminster Unitary Development Plan review – Inspector’s Report
TABLE OF CONTENTS
PAGES
UDP PART II (CRITERIA-BASED POLICIES)
CHAPTER 11 : RIVER THAMES
RT00
RT01
RT02
RT03
RT04
RT05
RT06
RT07
RT08
RT09
RT10
RT11
RT12
GENERAL INTRODUCTION
DESIGN OF DEVELOPMENT
RIVER VIEWS
ENVIRONMENT
ACTIVITY PROMOTION
RIVER DEVELOPMENT
RIVER CROSSINGS
PIERS
PERMANENT MOORINGS
THAMES PATH
RIVER ACCESS
SAFETY ISSUES
FLOOD DEFENCES
Chapter 11 : River Thames
1052-1065
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1053
1055
1056
1056
1057
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1059
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Chapter 11 : River Thames
City of Westminster Unitary Development Plan review – Inspector’s Report
CHAPTER 11
RT00:
RIVER THAMES
General Introduction
Objectors and Supporters
9
28
138
139
143
295
Historic Buildings and Monuments Commission
London Tourist Board
Westbourne Neighbourhood Association
Westminster Society
Environment Agency
Port of London Authority
Summary of Objections and Supporting Statements
(a)
(i)
The recognition of the value of the Thames as open space and for Westminster’s
biodiversity is welcomed. However, in order to fully explain the reasons why
development can threaten this value, the final sentence should be altered to
read: “….that it could damage it, both directly and indirectly, e.g. from lighting
and disturbance as well as built structures.” Objection withdrawn on condition
that amended text is submitted to the Environment Agency. [143]
(b)
(i)
The fourth bullet point could usefully be expanded to refer to the River Thames
as a means of transport for both passengers and freight. [295]
(c)
(i)
Support objectives. [143] [28] [139] [9] [138]
Summary of Council’s Response
(a)
(i)
Agreed, suggested text has been added to para 11.24. [143]
(b)
(i)
Whilst use of the River Thames for transporting freight is supported (policy
TRANS 12 in the Transport Chapter), it is considered that there are no suitable
sites within Westminster for landing facilities for freight. As such, policies in the
River Thames Chapter are geared towards encouraging passenger transport
facilities only. [295]
(c)
(i)
Support welcomed. [143] [28] [139] [9] [138]
Inspector’s Reasoning and Conclusions
11.0.1 It would seem that the River Thames within Westminster no longer has riparian
facilities for the transport of goods. Reference has indeed been added in TRANS 12 in
support of goods transfer and transport and this is supported by the PLA (295). Oddly
enough, the sole waste transfer depot in Westminster at Grosvenor Dock was recently
closed (in 1996) and is now being redeveloped. This site is also the subject of a related
objection (269) and is considered later (see RT01). I accept the LPA’s claim that no further
freight transfer facilities are likely to be made available in Westminster during the currency of
the UDP and I accordingly endorse the alterations to Policy TRANS 12 and to the supporting
text introducing Chapter 11.
Recommendation
q
R11.0.1 Modify the Introduction to Chapter 11 (River Thames) in accordance with
the Pre-Inquiry version of the Review UDP.
Chapter 11 : River Thames
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RT01:
The Design of Development
Objectors and Supporters
9
113
139
143
269
295
Historic Buildings and Monuments Commission
Ramblers Association
Westminster Society
Environment Agency
St James Homes
Port of London Authority
Summary of Objections and Supporting Statements
(a)
(i)
New street furniture should be of high quality design and take lead from listed
benches and other elements. Trees, although welcome, should not conflict with
the many listed buildings overlooking the Thames, and should be of appropriate
stature, i.e. London Planes. Design development should be dealt with on an
individual basis, and Public Art encouraged, but not leading to clutter. [9]
(b)
(i)
Strategic Guidance for London RPG3B states that the detailed boundary of the
Thames Policy area will be defined in UDPs. The boundary of the Thames
Policy Area as proposed on Map 11.1 is considered to require review, as it
unnecessarily includes land well removed from the River Thames, specifically in
terms of the Grosvenor Dock site and the Western Pumping Station site (which is
scheduled in part as R5 in Schedule 1 of the UDP). These sites benefit from
planning permission, are substantially removed from the River Thames, and
include land over which normal development control policies can be applied, and
through which any issues relating to the impact of future development on the
River Thames can be addressed. The boundary of the policy area therefore as it
affects the site should be amended to delete the inclusion of the Grosvenor Dock
site. [269]
(c)
(i)
Would like to see an assumption against high buildings included in the overall
policy, as oversized buildings - already generally unwelcome across the City as a
whole - could have quite devastating effects along the river. [139]
(d)
(i)
Policy supported. [143, 113, 295]
(e)
(i)
Support way that developers are specifically referred to other relevant policies
within the plan when considering Thameside redevelopment. However, as the
Thames is such an important area of open space and is of significant amenity,
recreation and nature conservation value, would it be appropriate to cross
reference to policy ENV 13 as well? [143]
(f)
(i)
Welcome a specific lighting strategy for the TPA; the strategy should also
consider including a statement about appropriate and sympathetic lighting that
does not overspill on to the Thames foreshore as this can affect wildlife.
Welcome the reference to the “Tidal Thames: Landscape Assessment Design
Guidelines” as a useful guide to developers when considering the design of
riparian developments. [143]
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Summary of Councils Response
(a)
(i)
Whilst policy RIV 1 does not refer to these issues specifically, supporting text at
paragraph 11.8 does give consideration to the streetscape and refers to
supplementary planning guidance for the Thames Policy Area, which gives more
detailed consideration to street furniture, trees and views, and public art. [9]
(b)
(i)
The boundary of the Thames Policy Area has been drawn up with reference to
the proposed boundary in Map 2(b) of RPG3B Strategic Planning Guidance for
the River Thames. This boundary was reviewed according to criteria
recommended by LPAC’s Thames Working Party. The City Council also
appointed consultants to review the boundary of the Thames Policy Area in July
1999. They recommended the inclusion of the whole of the Pumping Station site
in addition to the Grosvenor Dock site. In addition, the area is also included in the
Draft London Plan Annex 2 Thames Policy Area indicative map BR4
Wandsworth to Bermondsey. The area meets the criteria for designating the
Thames Policy Area set out in Annex 2 the Blue Ribbon Network policy BR29.'
[269]
(c)
(i)
Policy DES 3 already considers high buildings throughout the whole of the
borough, and is cross referenced at paragraph 11.13.A further reference to DES
3 has been added to para 11.9 stating "Policy DES 3 notes that proposals for
high buildings will not normally be granted planning permission if they are
considered to have an adverse visual impact on the setting of the River
Thames." [139]
(d)
(i)
Support welcomed. [143] [113] [295]
(e)
(i)
A cross reference to policy ENV 13 will be added to para 11.23, following RIV 3
which considers environment, open space and wildlife. [143]
(f)
(i)
Comments for the proposed strategy are noted and support welcomed. [143]
Inspector’s Reasoning and Conclusions
11.1.1 The nominal objections made by the HBMC (Historic Buildings and Monuments
Commission) appear to be more in the nature of comments. The concern regarding the
Thames-side development and its design quality are fully understood and supported. Some
of the finest set-piece urban compositions and vistas are indeed obtained from the riverside
on the opposite bank from Westminster. However, Policy RIV 1 effectively reinforces other
UDP Policies. The latter include significant Chapter 10 Policies (eg DES1, DES3, DES5-7)
which are either endorsed or strengthened elsewhere in this report. The UDP needs to be
read as a whole and I do not think it necessary to introduce a parallel set of Urban Design
Policies in respect of the Thames, especially since it has the added protection of the River
Thames Policy Area definition. I would merely add that the entire Thames frontage in
Westminster is covered by long-standing conservation area designations (see Map 10.2).
11.1.2 The objection by St James Homes (269) was one of the comparatively few that were
heard by way of appearance at the UDP Inquiry. Consequently, I was able to ask questions
of both the objectors and LPA witnesses regarding both the rationale and the repercussions
of including the redevelopment site within the Thames Policy Area (TPA). The site (notation
V12 on the Proposals Map) extends to 2.8 hectares around the former waste transfer station
at Grosvenor Dock off Chelsea Bridge Road (A3216). In addition, the redevelopment site,
now under construction and intended to house a variety of land uses, including residential
and commercial, was the subject of one of the few accompanied inspections I carried out,
Chapter 11 : River Thames
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courtesy of the objectors and attended by representatives of the LPA. I note that the site
was excluded from both the Pimlico (27) and Belgravia (23) Conservation Areas, as originally
designated (see Map 10.2).
11.1.3 My site inspections (both accompanied and unaccompanied) indicated that the
authorised development is well under way and looks set for early and successful completion.
I note with particular approval that maximum pedestrian permeability across and within the
redevelopment site is provided for in the approved details of the scheme. This is especially
important in view of the emergent London Plan’s firm advocacy (Policy BR20) of “extend
(ing) the existing or…new walking and cycling routes along the Blue Ribbon (ie waterway)
Network as well as new access points … to be provided as part of development proposals.”
My site inspection indicated that the much the most likely direct riverside access would be
gained through the curtilage of the vacant TWA Western Pumping Station (site R5),
immediately to the east of the development area and also included within the TPA. My
conclusion is that both sites V12 and R5 are appropriately included within the TPA since they
have clear functional, industrial archaeological and historical links with the River Thames.
11.1.4 The objection by the Westminster Society (139) has already been effectively met by
my several recommended modifications to Policy DES 3 (High Buildings). The objection by
the Environment Agency is noted as having been accommodated by a cross-reference to
Policy ENV 13, which is endorsed. In this connection, as elsewhere in the report, I would
recommend the removal of bullet point in paragraph 11.1 in favour of sub-paragraphs (a-g) in
view of the need to refer to these important criteria in the determination of individual planning
applications (or in the possible case of site V12) the future approval of reserved matters.
Recommendations
q
R11.1.1 Modify Policy RIV 1 and its supporting text in accordance with the PreInquiry version of the Review UDP.
q
R11.1.2
Modify paragraph 11.1 by the insertion of sub paragraphs (a-g).
RT02:
River Views
Objectors and Supporters
113 Ramblers Association
143 Environment Agency
Summary of Objections and Supporting Statements
(a)
(i)
Supported.[143] [113]
Summary of Council’s Response
(a)
(i)
Support welcomed [143] [113]
11.2.1 The representations that have been made in respect of this Policy are all expressions
of support. Since there are no duly made objections outstanding, I need not reach any
conclusions or recommend any modifications apart from endorsing the Pre-Inquiry Version of
the UDP in respect of this Policy and its supporting text
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Recommendation
q
R11.2.1 Modify Policy RIV 2 and its supporting text in accordance with the PreInquiry version of the Review UDP.
RT03:
Environment, Open Space and Wildlife
Objectors and Supporters
113 Ramblers Association
143 Environment Agency
Summary of Objections and Supporting Statements
(a)
(i)
Supported. [113] [143]
Summary of Council’s Response
(a)
(i)
Support welcomed. [113] [143]
11.3.1 The representations that have been made in respect of this Policy are all expressions
of support. Since there are no duly made objections outstanding, I need not reach
any conclusions or recommend any modifications apart from endorsing the PreInquiry Version of the UDP in respect of this Policy and its supporting text
Recommendation
q
R11.3.1 Modify Policy RIV 3 and its supporting text in accordance with the PreInquiry version of the Review UDP.
RT04:
PROMOTING ACTIVITY
Objectors and Supporters
139 Westminster Society
253 Insignia Richard Ellis
295 Port of London Authority
Summary of Objections and Supporting Statements
(a)
(i)
Would prefer to see a stronger predisposition against additional A3 uses on piers
and permanently moored vessels, as against the waterfront, in policy RIV4. [139]
(b)
(i)
Fails to promote development which could enhance the riverside. [253]
(c)
(i)
Support the requirement for developers to explore the potential to service
riverside sites by water and the encouragement of water-dependant and
waterfront enhancing uses along the river side. [295]
Summary of Council’s Response
(a)
(i)
Policy RIV 4 aims to balance activity on the riverside and the need to protect
amenity. Specific reference is made to policies for bars and restaurants in
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paragraph 11.26. Policy RIV 5 notes that proposals built over the river should be
for transport purposes only. Policy RIV 7 considers piers, a note has been added
to the policy application at paragraph 11.44. Policies for considering A3 uses are
also referred to in the supporting text for policy RIV 8, Permanently Moored
Vessels paragraph 11.50 [139]
(b)
(i)
The policy aims to balance activity on the riverside and the need to protect
amenity. [253]
(c)
(i)
Support welcomed. [295]
Inspector’s Reasoning and Conclusions
11.4.1 The range of relevant Chapter 11 Policies (RIV 4, 5 and 8) appear to me to draw the
correct balance between promoting worthwhile and welcome tourist and amenity facilities on
the river frontage. Class A3 uses are also subject to the fairly stringent control of the various
Chapter 8 Policies (qv). In my view, there is no particular need more actively to “promote”
riverside development, as advocated by one objector (253). In my experience, such
development is actively being pursued by a wide variety of agencies; it is only necessary to
look at the recent worthy examples of Tate Britain (in Westminster) and Tate Modern (in
Southwark) that are linked by dedicated river craft services to see that such initiatives have
been readily encouraged by the riparian London Boroughs.
Recommendation
q
R11.4.1 Modify Policy RIV 4 and its supporting text in accordance with the PreInquiry version of the Review UDP.
RT05:
DEVELOPMENT BUILT INTO OR OVER THE RIVER
Objectors and Supporters
113 Ramblers Association
295 Port of London Authority
Summary of Objections and Supporting Statements
(a)
(i)
Full support for consulting the Port of London Authority on development
proposals into or over the river. [295]
(b)
(i)
Policy supported [113]
Summary of Council’s Response
(a)
(i)
Support welcomed. [295]
(b)
(i)
Support welcomed. [113]
Inspector’s Reasoning and Conclusions
11.5.1 The representations that have been made in respect of this Policy are all expressions
of support. Since there are no duly made objections outstanding, I need not reach any
conclusions or recommend any modifications apart from endorsing the Pre-Inquiry Version of
the UDP in respect of this Policy and its supporting text
Chapter 11 : River Thames
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Recommendation
q
R11.5.1 Modify Policy RIV 5 and its supporting text in accordance with the PreInquiry version of the Review UDP.
RT06:
RIVER CROSSINGS
Objectors and Supporters
113
143
295
632
823
Ramblers Association
Environment Agency
Port of London Authority
Westminster Cycling Campaign
Sustrans
Summary of Objections and Supporting Statements
(a)
(i)
Though support the policy for river crossings, object to the restriction that new
crossings should improve only pedestrian access. Cycling and public transport
should also be considered. [823] [632]
(b)
(i)
It is necessary to stress the importance of the rivers flood defences in light of the
possible impacts new river crossings can have upon them. Therefore the
Agency would ask that the following text be added to the last sentence:
“….impacts on the foreshore and wildlife and ensure the integrity of flood
defence structures.” Objection withdrawn on condition that amended text is
submitted to the Environment Agency. [143]
(c)
(i)
The Agency has concerns over structures which could are termed “living bridges”
and would like the addition of the following final sentence: “Residential
accommodation, offices, shops or other non water-dependent structures will not
be allowed on any new river crossing” Objection withdrawn on condition that
amended text is submitted to the Environment Agency. [143]
(d)
(i)
Full support for consultation with the Port of London Authority on new proposals
for River crossings. [295]
(e)
(i)
Policy supported [113]
Summary of Councils Response
(a)
(i)
Support for policy welcomed. The policy allows for pedestrian and non-motor
vehicle access. A note has been added to paragraph 11.39 to acknowledge the
potential conflict between pedestrians and cyclists. [823, 632]
(b)
(i)
Agreed, suggested text has been added to paragraph 11.39. [143]
(c)
(i)
Agreed, suggested text has been added to paragraph 11.38. [143]
(d)
(i)
Support welcomed. [295]
(e)
(i)
Support welcomed. [113]
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Inspector’s Reasoning and Conclusions
11.6.1 Most of the objections have been accommodated by alterations to the supporting text,
which are endorsed. My reading of the altered policy and text reveals no explicit embargo or
restrictions on the use by cyclists of river crossings. Indeed, my inspections suggest that
such new facilities (eg Hungerford Bridge) are of equal benefit to people on foot and
(wheeling if not actually riding) bicycles. I note that the LCN at present enjoys only four
crossing points within Westminster so that additional cyclist facilities would no doubt be most
welcome.
Recommendations
q
R11.6.1 Modify Policy RIV 6 and its supporting text in accordance with the PreInquiry version of the Review UDP.
RT07:
PIERS
Objections
9
113
143
295
295
824
Historic Buildings and Monuments Commission
Ramblers Association
Environment Agency
Port of London Authority
Port of London Authority
City Cruises Plc
Summary of Objections and Supporting Statements
(a)
(i)
The objections to Policy RIV4 are that the policy is extremely limiting because
none of the existing purpose designed pier recesses are available for new
access to the river and will not secure the aim of increasing the use of the
Thames for passenger transport. The policy should be amended to allow for new
accesses downstream of Westminster Bridge.[824] [295]
(b)
(i)
The requirement for environmental, archaeological and hydrological
assessments is too onerous and would deter developers from putting forward
proposals to increase passenger transportation on the river. Amend first
sentence of para 11.44 to read: "When considering proposals for piers, the City
Council will take into account the impact on wildlife, archaeological and
navigation." [295]
(c)
(i)
There should be a presumption against 'up and over' piers. Note the objection to
'up and over piers' in paragraph 11.45, and resistance to new permanently
moored vessels. Note the supporting text and supplementary planning guidance.
Should be sufficient to cover objections. [9]
(d)
(i)
The objector is concerned with the impact of piers and associated structures on
both flood defences and riverine ecology. They ask that the paragraph should be
altered to read: “…and will require environmental, ecological, archaeological and
hydrological assessments of proposed sites for piers to identify and eliminate
adverse impacts on the stability of flood defences and on the riverine ecology.”
Objection withdrawn on condition that amended text is submitted to the
Environment Agency [143]
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(e)
(i)
The Agency is concerned that there are many tourism and leisure uses which
could be located on piers which would not be seen as water-dependent and
therefore inappropriate. These uses would be contrary to our own encroachment
policy and strongly resisted by the Agency through the planning and land
drainage consent stages. Therefore, the Agency would ask that the first bullet
point of the policy be altered to read: “…..Thames for water-dependent leisure,
tourism or public transport.” Objection withdrawn on condition that amended text
is submitted to the Environment Agency [143]
(f)
(i)
Support the City Council’s commitment to increasing passenger and freight
transportation on the River Thames and agrees that greater use of the river for
transport will benefit the environment by reducing the need for road transport.
Agree that there is not enough pier capacity to cope with any increase in demand
for transport and that, if passenger transport on the river is to be encouraged
more piers will be needed. Full support for consultation with the Port of London
Authority on proposals for new or improved piers. [295]
(g)
(i)
Policy supported. [113]
Summary of Council’s Response
(a)
(i)
The City Council wishes to control the location of piers, particularly downstream
of Westminster Bridge, in order to protect the historic landscape and listed
structures. There are six purpose built pier recesses within the listed
embankment wall in Westminster. Three are currently in pier use - Westminster
Pier (downstream of Westminster Bridge), Embankment Pier (downstream of
Hungerford Bridge) and the Thames Police Pier (downstream of Waterloo
Bridge). The three remaining recesses are used for permanently moored boats.
The City Council wishes to encourage more active use of these pier recesses.
[824, 295]
(b)
(i)
The proposal for a pier is of a sufficient size to merit an assessment of impacts.
The UDP has policies to protect Sites of Nature Conservation Importance, of
which the Thames is of Metropolitan significance, and sites of archaeological
significance. This is within their remit as a local planning authority. [295]
(c)
(i)
The policy already has a presumption against up and over piers in the listed
section on the embankment wall, as it directs pier proposals to the existing
accesses. In addition, paragraph 11.45 already notes that "Proposals
downstream of Westminster Bridge are directed to existing purpose-designed
pier recesses in order to avoid the use of ‘up and over’ type brows which are
considered to have an adverse impact on the character and appearance of the
listed embankment wall." [9]
(d)
(i)
The suggested text has been added to paragraph 11.44. [143]
(c)
(i)
Suggested text has been added to the policy. [143]
(f)
(i)
Support for policy application welcomed. [295]
(g)
(i)
Support welcomed. [113]
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Inspector’s Reasoning and Conclusions
11.7.1 Many of the objections to Policy RIV 7 have been met by alterations to it and its
supporting text, which are duly endorsed. It is hard to imagine a UDP Policy whose
implementation or application is likely to be the subject of more widespread consultation (eg
GLA, TfL, PLA, Environment Agency, HBMC and other London Boroughs). The one design
of pier that is correctly identified as obtrusive and unsightly is the “up and over” variety and
these are rightly restricted under Policy RIV 7(A)(d) as far as the listed sections of river walls
are concerned.
Recommendations
q
R11.7.1 Modify Policy RIV 7 and its supporting text in accordance with the PreInquiry version of the Review UDP.
q
R11.7.2 Modify Policy RIV 7 by the insertion of paragraphs (A) and (B) and
subparagraphs (a-d).
RT08:
PERMANENTLY MOORED VESSELS
Objections
9
Historic Buildings and Monuments Commission
143 Environment Agency
295 Port of London Authority
Summary of Objections and Supporting Statements
(a)
(i)
There should be a strong presumption against permanently moored vessels, with
special reference to the grade II listed stretch of Embankment, Waterloo and
Westminster Bridges. Every effort should be made to dislodge existing moored
vessels, and use properly existing designed points of access by Sir Joseph
Bazalgette. [9]
(b)
(i)
This paragraph relates to the need to limit the number of vessels in order to
protect the river front. The Agency would ask that the following bullet point be
added: "protect the river as a continuous wildlife corridor and not a fragmented
unsustainable corridor”. Objection withdrawn on condition that amended text is
submitted to the Environment Agency [143]
(c)
(i)
Support consultation with the Port of London Authority on proposals for
permanently moored vessels. As part of the review of RPG3b within the Major's
Spatial Development Strategy, there are proposals to revise the 1990 LPAC
guidance on permanently moored vessels and structures. [295]
Summary of Council’s Response
(a)
(i)
The policy lists a number of stringent criteria, including "do not compromise
views of the river and the setting of listed buildings and structures" and "do not
jeopardise the long term use of existing purpose-designed pier recesses for their
original purpose." Also, paragraph 11.51 notes that "To ensure the openness of
the river is maintained, over-concentration of permanently moored vessels will be
resisted" and the "relocation of permanently moored vessels from the purpose-
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designed pier recesses will be welcomed, as this will enable the pier recesses to
be used for their original purpose" [9]
(b)
(i)
Agreed, suggested text has been added to paragraph 11.54. [143]
(c)
(i)
Support welcomed. [295]
Inspector’s Reasoning and Conclusions
11.8.1 The representations that have been made in respect of this Policy have all been
accommodated by revisions to the supporting text. Since there are no other duly made
objections outstanding, I need not reach any conclusions or recommend any modifications
apart from endorsing the Pre-Inquiry Version of the UDP in respect of this Policy and its
supporting text
Recommendations
q
R11.8.1 Modify Policy RIV 8 and its supporting text in accordance with the PreInquiry version of the Review UDP.
RT09:
THE THAMES PATH
Objections
113
139
143
295
632
823
Ramblers Association
Westminster Society
Environment Agency
Port of London Authority
Westminster Cycling Campaign
Sustrans
Summary of Objections and Supporting Statements
(a)
(i)
Support the policy for the Thames Path, but suggest that the words 'walk' and
'walkway' are substituted for the word 'path' and 'pathway' as the former,
preclude the use of certain sections of the path by cyclists. As some sections of
the Thames Path are suitable and legal for cycling, the use of 'path' and
'pathway' allow for continuity in discussions about the route through London.
[823]
(b)
(i)
On policy RIV9 (The Thames Path), request that the policy be amended so as:
(i) to set out the City Council's proposals and timetable for the completion of the
riverside walk between Chelsea and Vauxhall Bridges, and (ii) to indicate the City
Council's commitment to the safeguarding of the long term proposed pedestrian
underpasses for the riverside walk to go under the abutments of both Vauxhall
and Lambeth Bridges. [139]
(c)
(i)
The provision of the Thames path on sites where there is no walkway at present,
should be within the site boundaries and not cantilevered over the river wall or
solidly encroaching into the river corridor. Also, the design of the walkway
should be sympathetic to the location and consider the impact on the ecology of
the tideway from e.g. disturbance. The Agency asks that the following point be
added to the Policy: “(B) Permission will not be granted for developments that
create any boardwalks or other solid or overhanging projections riverward of the
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existing flood defence structures in order to accommodate the Thames Path.”
Objection withdrawn on condition that amended text is submitted to the
Environment Agency [143]
(d)
(i)
Supported [113, 295]
Summary of Council’s Responses
(a)
(i)
The terms "walk" and "walkway" have been replaced with "path" and “pathway”
[823]
(b)
(i)
With regard to point (i), it is not considered appropriate to include proposals and
a timetable for completion of the Thames Path here, as the missing links are
privately owned, so extension of the Path is dependent on redevelopment
proposals coming forward. With regard to point (ii), the Council's vision for
completion of the Thames Path is set out in its Supplementary Planning
Guidance for the Thames Policy Area. [139]
(c)
(i)
Agreed, additional point has been added to the policy. [143]
(d)
(i)
Support welcomed. [113] [295]
Inspector’s Reasoning and Conclusions
11.9.2 The representations that have been made in respect of this Policy have mostly been
accommodated by revisions to the supporting text. I accept the LPA’s view that Policy RIV 9
is an “as and when” policy that will be implemented when suitable opportunities occur; by the
evidence of recent progress on both sides of the river, such implementation is likely to be
fairly imminent. There is accordingly little particular purpose or merit in laying down a
specific timetable for completion. In the light of the additional Policy RIV9(C), in response to
the Environment Agency (143) objection, I would add that perhaps RIV9(A) ought to be
strengthened. My reason is that my site inspections indicated that pathway provision has in
some cases not been made available until the completion of development and not as soon
after commencement as is reasonably possible. In view of the considerable interest in such
provision and the inconvenience in finding the existing Thames Path blocked on
redevelopment, I recommend a minor modification.
Recommendations
q
R11.9.1 Modify Policy RIV 9 and its supporting text in accordance with the PreInquiry version of the Review UDP.
q
R11.9.2
(A)
q
Further Modify Policy RIV 9(A) to read as follows:
For sites immediately adjacent to the River Thames, whether an existing riverside
path is provided or is absent, all development proposals will be required to
restore or provide a public right of way, if possible either before or early in the
process of executing the development.
R11.9.3 Further Modify Policy RIV 9 by the insertion of sub paragraphs (B)(a-b)
in place of bullet points.
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RT10:
Encouraging Access to the River and its Foreshore
Objectors and Supporters
113 Ramblers Association
143 Environment Agency
295 Port of London Authority
Summary of Objections and Supporting Statements
(a)
(i)
The Agency encourages access to the river and its foreshore. However, access
is not always appropriate for safety or environmental reasons and the Agency is
therefore very pleased that this is clearly recognised within the policy. The only
suggestion the Agency would have is that any encroachment which might occur
through the construction of new accesses should be limited through sensitive
design and any losses to flood storage volume or foreshore habitat should be
adequately compensated for. Objection withdrawn on condition that amended
text is submitted to the Environment Agency [143]
(b)
(i)
Supported [113] [295]
Summary of Council’s Response
(a)
(i)
Agreed, suggested text has been added to paragraph 11.62. [143]
(b)
(i)
Support welcomed. [113] [295]
11.10.1
The representations that have been made in respect of this Policy are either
expressions of support or have been accommodated by alterations. Since there are no duly
made objections outstanding, I need not reach any conclusions or recommend any
modifications apart from endorsing the Pre-Inquiry Version of the UDP in respect of this
Policy and its supporting text
Recommendation
q
R11.10.1 Modify Policy RIV 10 and its supporting text in accordance with the PreInquiry version of the Review UDP.
RT11:
Safety Issues
Objectors and Supporters
295 Port of London Authority
Summary of Objections and Supporting Statements
(a)
(i)
Full support for the provision of safety features as part of new development along
the Thames.[295]
Summary of Council’s Response
(a)
(i)
Support welcomed. [295]
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The representations that have been made in respect of this Policy are all
11.11.1
expressions of support. Since there are no duly made objections outstanding, I need not
reach any conclusions or recommend any modifications apart from endorsing the Pre-Inquiry
Version of the UDP in respect of this Policy and its supporting text
Recommendation
q
R11.11.1 Modify Policy RIV 11 and its supporting text in accordance with the PreInquiry version of the Review UDP.
RT12:
Flood Defences
Objectors and Supporters
143 Environment Agency
Summary of Objections and Supporting Statements
(a)
(i)
In light of climate change certain interim flood defences may need to be reintroduced. Consequently, the more permanent interim defences may need to
be retained. If reference to removal of any of these defences is to be retained
there should be direct mention of these issues and the need to consult the
Environment Agency at the earliest possible moment should be stressed.
Objection withdrawn on condition that amended text is submitted to the
Environment Agency. [143]
(b)
(i)
The Agency welcomes the policy as it attempts to maintain and improve the
existing flood defences. However, developments there may be instances where
flood defences will require replacement or major works as part of developments.
There is also the added issue of flood defence requirements as a result of
climate change and both of these should be reflected in the policy. The Agency
would ask that the two following points be included: (C) The life of new flood
defences should be at least as long as the new development, (D) Any new flood
defences should be designed so as to be capable of being raised and
strengthened at a future date if required as a result of climate change. Objection
withdrawn on condition that amended text is submitted to the Environment
Agency. [143]
Summary of Council’s Response
(a)
(i)
A reference to the climate change implications has been added to paragraph
11.71. [143]
(b)
(i)
The suggested points has been added to paragraph 11.70. [143]
11.12.1
The representations that have been made in respect of this Policy have all been
accommodated by revisions to the supporting text. Since there are no duly made objections
outstanding, I need not reach any conclusions or recommend any modifications apart from
endorsing the Pre-Inquiry Version of the UDP in respect of this Policy and its supporting text
Recommendation
q
R11.12.1 Modify Policy RIV 12 and its supporting text in accordance with the PreInquiry version of the Review UDP.
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