Local Plan Modifications Stage explained

Understand more about the Modifications Stage of the Local Plan and what it does, the process and how it addresses key issues.

About the Local Plan

What is the Local Plan?

The Richmond upon Thames Local Plan is a key planning policy document which will guide development in Richmond over the next 15 years. The Local Plan identifies the amount, type and location of development in the borough.

The Local Plan provides the opportunity to set out and address the current and future needs of our borough. This includes housing needs of all types, planning for infrastructure and where this should go, identifying land for employment use and how best to protect our environment. This is used to guide decisions on planning applications.  

What consultation has happened up to this stage?

The Local Plan is going through an examination in public and hearings were held throughout June and July 2024, which is the final part of the Local Plan process prior to adoption. The independent Planning Inspectors scrutinised the Local Plan, taking into account representations submitted by residents and other stakeholders during the ‘Regulation 19’ consultation on the Publication Local Plan. 

Prior to the Examination in Public the Plan had been through several rounds of consultation:

• In the summer and autumn of 2021, we held informal engagement, including a series of community conversations and workshops with schools.
• From December 2021 to January 2022, we consulted on the Pre-Publication Draft Local Plan (Regulation 18), inviting feedback from a range of stakeholders – from residents, development professionals, and neighbouring boroughs.
• From June to July 2023, we held consultation on the Publication Draft Local Plan (Regulation 19) – a third public consultation was held to seek further feedback from residents, businesses and other stakeholders. This version of the Plan was then submitted for examination.

You can read more about the process and key issues on the Local Plan explained page which was produced at the time of the ‘Regulation 19’ consultation on the Publication Local Plan in 2023.

Where can I find out more about the Local Plan?

The Draft Local Plan page includes more information on the Local Plan. This includes further details on consultation and the process to date.

There is also an explanation if you want to understand further in general what planning policy is about. 

What happened at the examination? What were the outcomes of the Affordable Housing and Biodiversity discussions at the hearing sessions?

Throughout the examination, the Inspectors explore the potential for Main Modifications to resolve the soundness and legal compliance issues they have identified. These can range in scope from redrafting parts of an individual policy or the supporting text, to deleting policies or site allocations or the insertion of new ones.

Our record of actions and/or proposed changes arising from discussions during hearing sessions have been added to the Examination library, in a section on hearing action points. Any follow up on actions and documents that were sought by the Inspectors or discussed in the Examination hearings have now been added to the Examination library as supporting background documents. The Inspectors did suggest some areas for changes, particularly due to concerns about deliverability of the Local Plan.

For example, the Inspectors set out (as noted in the hearing action points in HA-03) that a modification would be needed to align the borough’s minimum Biodiversity Net Gain requirements with national minimum requirements at 10% (rather than 20%) and the proposed modifications to Policy 39 address this and are set out at MMs 66 to 68 in the Schedule. Another example is on affordable housing where the Inspectors set out (as noted in the hearing action points in HA-03) that a modification would be needed to align the policy with the London Plan and the threshold for the fast track route and a new version of Policy 11 is proposed to address this at MM49 in the Schedule.

What is being consulted on now?

The Planning Inspectors requested we propose some changes to the Publication Local Plan as part of the examination process, and have now prepared the changes they consider necessary. The prepared changes are known as Main Modifications, and alongside this we have prepared some Additional (Minor) Modifications.

The consultation is focused on the Inspectors’ Main Modifications, with the accompanying updated Sustainability Appraisal and Habitats Regulations Assessment, and not on the other contents of the Publication Local Plan. Comprehensive consultation has been completed prior to this consultation on the contents of the draft Local Plan. The Planning Inspectors are considering comments in line with the proposed modifications in relation to their ‘legal compliance’ and ‘soundness’.

Any comments made during earlier stages have been considered during the examination process by the Inspectors. Any comments made on the contents of the Local Plan that are not subject to modifications will not be considered at this stage. 

Modifications explained

What are the Main Modifications to the Local Plan?

Main Modifications are changes to the Regulation 19 version of the Local Plan that will affect the ‘soundness’ and ‘legal compliance’ of the plan. The changes have been proposed by the Planning Inspectors as part of the examination process. The modifications aim to propose changes that will enable the Local Plan to be formally adopted. The proposed Main Modifications consist of a schedule of modifications in the order that they appear in the plan.

How have they been put together?

The Inspectors undertaking the Local Plan Examination, Jameson Bridgwater PGDipTP MRTPI and Graham Wyatt BA(Hons) MRTPI, have produced the modifications, which the Council is consulting on their behalf. This is without prejudice to the Inspectors’ ultimate conclusions and recommendations on the Plan.

What are Additional Modifications and how are they different from Main Modifications?

Additional Modifications are minor changes which do not affect the plans ‘soundness’ or materially affect the plan’s policies.

We have chosen to include a list of minor amendments to the plan which are published alongside the consultation. There are separate schedules of modifications for both the Main and Additional Modifications.

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

We have produced a schedule of Main and Additional Modifications which details any changes to the publication (Regulation 19) version of the Local Plan. The Modifications are set out in order of the Local Plan, as identified under the heading ‘Section of the Plan’. The proposed additions are recorded by highlighted underlined text and deletions are recorded through highlight and strikethrough. 

The page numbers correspond with those in the publication (Regulation 19) Local Plan.

Are there any changes proposed to the Policies Map?

The schedule of Main Modifications includes changes to the Policies Map designations where relevant. There was an interactive map showing the Publication (Regulation 19) Local Plan policy designations spatially or it can be viewed as a PDF.

Are modifications needed to bring the plan in line with recent government announcements on planning?

In December 2024 the government announced changes to planning as part of their commitment to increasing delivering of new homes, including a new National Planning Policy Framework (NPPF). However, as we have already progressed to this stage in preparing the new Local Plan there are transitional arrangements so the Examination continues under the relevant previous version of the Framework.

Increases in housing targets represent a significant challenge in the borough given limited land supply and constraints, but are set to inform the plan-making process and will be relevant to the update of the London Plan commencing in 2025 and the next review of the Local Plan.

The Inspectors are only looking for comments relating to the Main Modifications and the supporting consultation documents in relation to the ‘soundness’ of the plan and legal compliance, not in relation to the Government’s recent changes.

Commenting on the Main Modifications

Who can comment?

Anyone can comment on the consultation and the Council and the Planning Inspectors will review all consultation responses. We welcome comments from residents and stakeholders on the proposed modifications and supporting consultation documents.

The Inspectors will consider the consultation responses when writing their final report on the Local Plan. All consultation responses on the Main Modifications will be considered and could lead to further modifications or if the Inspectors decide necessary further public hearings. The Inspectors will consider whether the Local Plan is considered to be sound prior to adoption.

How do I make a representation?

We welcome your comments on the Main Modifications. The consultation will run from 31 January to 17 March 2025. No late representations will be accepted.

To respond to the consultation online please visit our consultation page. We encourage comments electronically to reduce the processing time for comments. Wherever possible we would appreciate submissions in word or PDF format that allow us to cut and paste the representations. This will speed up our process of summarising the representations and passing on to the Inspectors.

Responses can also be made through post.

Please make a reference to the Main Modification reference when making comments.

What can I comment on?

The consultation is only looking for comments relating to the Main Modifications and supporting consultation documents in relation to the ‘soundness’ of the plan and legal compliance. The Main Modifications schedule is available to view.

Comments on any other part of the Local Plan will not be considered at this stage as there was opportunity to comment on this during previous rounds of consultation. All comments made prior to this stage were considered during the examination period by the Inspectors. There is no need to repeat comments that were made in previous rounds of consultation.

What is ‘soundness’ and ‘legal compliance’?

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

Soundness comprises 4 components:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is practical to do so and consistent with achieving sustainable development
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence
• Effective – the plan should be deliverable over its period (in this case 15 years) and based on effective joint working on cross-boundary strategic matters
• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

What happens to my comments?

The Planning Inspectors will consider all comments received on the Main Modifications consultation.

Why do I have to give my details?

The Planning Inspectorate requires for respondents to give their details and therefore responses cannot be made confidentially. Anonymous representations will not be considered. Comments will be attributed to individuals and organisations and will be passed on to the Planning Inspectorate.

The representations will be made publicly available on our website for transparency. Emails and addresses will not be published on the website. 

What are the supporting consultation documents?

Alongside the Schedule of Main Modifications and the Schedule of Additional Modifications, the consultation is supported by an updated Sustainability Appraisal (SA) and the updated Habitats Regulation Assessment (HRA). 

What happens next?

Following the consultation, we will forward all representations to the Planning Inspectors for their consideration. The Inspectors will consider all responses along with what has been presented throughout the examination period to determine whether the Local Plan is considered ‘sound’ and legally compliant.

The conclusions will be presented in a written report of their final recommendations including the Main Modifications necessary to make the plan sound. We can then move forward to adopt the Local Plan once the recommendations from the Inspectors have been included. 

Future consultation

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

This Local Plan is at the final stage, however in the future work will begin on the next review. As the process to prepare a Local Plan takes a few years, and the context for a plan such as wider social factors or the national and regional planning guidance changes, there will at some point be the need to commence a review.

How can I be added to the database to be informed of future consultation?

Our website will be updated as the Local Plan progresses. To be kept up to date via email or letter on planning policy consultations please opt-in to our Local Plan database by sending your contact details to LocalPlan@richmond.gov.uk.