On behalf of members, Westminster Property Association has submitted a response to Westminster City Council’s Retrofit First Policy Guidance consultation. The Guidance will underpin the Council’s Retrofit First policy, which was a key part of its Partial Review of the City Plan.
In the response, we state that the policy remains the most challenging aspect of delivering long-term and sustainable development and we reiterate our calls for a ‘Retrofit First, Not Retrofit Only’ approach. Whilst retrofit is often the optimal route to delivering low carbon development, it is not always the most appropriate or viable option.
We also raise specific concerns on the Guidance which are:
- The complexity and volume of information to be submitted at each step of the Sequential Test, even where applicants are not relying on that step to justify more extensive development.
- The suggestion that public benefits used to justify the application of Step 4 must go beyond the minimum requirements of the development plan, discounting the possibility that compliance with the plan could constitute a public benefit.
- Requirements that other sites are considered as potential alternatives for redevelopment in some circumstances, going beyond draft policy.
- The limited flexibility for applicants to deal with changes at post-determination stage, given Westminster’s complex urban environment.
