From: Andrew Blackwell [mailto:[email protected]] Sent: 13 May 2015 08:56 To: John Pearce Subject: RE: Roding Lane South

John

Thank you for confirming this. As you may know, we represent a client who has a private ,enclosed area of land that is need of ground restoration given its previous history of unmanaged tipping and the substantial extent of Japanese Knotweed. Because it is naturally contained by a high bank against the River Roding, we maintain this is one site where the Green Belt can be rolled back ,without compromise to the essential NPPF tests. If development is linked to fresh public open space and wildlife enhancement within the site (and along the River Roding) we see an exciting community gain as well as scope for further new homes.

A dialogue with David was progressing which we are keen to maintain so all features of our ideas are fully appreciated within the Council. This is particularly so as I am aware there is a Neighbourhood Services Committee on the 3/6 to consider possible Green Belt revisions. We would be receptive to any opportunity to briefly present our ideas and welcome the chance to meet you if it is possible.

I look forward to your reply.

Kind regards

Andrew

Andrew Blackwell Divisional Managing Partner Planning Division

Saxon House, 27 Duke Street, , CM1 1HT DD: 01245 505 080 Fax: 01245 251 214 Mob: 07880 781378

The UK’s leading regional property consultancy www.bidwells.co.uk

From: John Pearce [mailto:[email protected]] Sent: 12 May 2015 16:28 To: Andrew Blackwell Subject: RE: Roding Lane South

From: Andrew Blackwell [mailto:[email protected]] Sent: 12 May 2015 15:51 To: John Pearce Subject: Roding Lane South

Dear Mr Pearce

I understand that David Hughes has left the authority. I have been having regular liaison with him with regard to Green Belt representations. Could you please confirm who is now taking David's place and overseeing the Green belt review and emerging local plan allocations? Kind regards

Andrew

Andrew Blackwell Divisional Managing Partner - Planning Division

DD: 01245 505 080 Mob: 07880 781 378 Fax: 01245 251 214

Saxon House, 27 Duke Street, Chelmsford, CM1 1HT Land South of Roding Lane, Redbridge - Illustrative Masterplan

Woodford Bridge Road Green Belt Boundary The top of the flood embankment on the western edge of the site provides a clearly defined and permanent physical Green Belt boundary to both the Spire Roding Hospital Local Open Space Key site and Investment Area. The resulting open space can be A small area of amenity space will be provided to the north east corner of protected by Borough Open Space Policies. the site to extend the frontage of the Hospital. Development to be set back Site Boundary Mosaic of habitats - wildflower and positively address the space and views from the north along Roding grassland and scrub Lane South. The location provides the opportunity for creating a landmark Proposed residential buildings Potential SUDs comprising building to define the vista along Roding Lane from the north. predominantly 2 storey swales / ponds

River Roding Potential landmark / feature Boundary trees and scrub - Public Open Space and Buffer to River Roding building existing vegetation retained Open space to the western and south western boundaries coincides with SUDs along principal streets Strategic native tree planting areas of landscape and ecological importance including the scrub and tree belts that constitute the habitat margins of the River Roding. These natural Development Area Residential development is confined to areas that contain habitats of low habitats will be retained and enhanced, with the development ensuring their Natural Play Avenue / street tree planting Footpath value to biodiversity and the natural environment with buildings set back management in perpetuity. All of the area will be open to public use providing Space forming a green frontage along Roding Lane South with a positive relationship community, social and physical benefits. Planting / hedges to building Natural play area - play between the built form and open space to ensure active surveillance of the frontages incorporating features in landscape setting The design of the open public realm. wildlife friendly species As established by the Redbridge Characterisation Study the development space will be multi- A Amenity grass / recreation functional incorporating will positively respond to the surrounding context and ‘Garden City’ character areas nature conservation, with buildings informed by the surrounding urban form and a strong structure informal recreation, play, Green Street of planting, such as avenue trees. Important mature trees will be retained seating and sustainable where informed by arboricultural survey. drainage. There will be a mosaic of habitat types A incorporating locally native species beneficial to both BAP and protected Open Space & Green Streets / Corridors species, including bats Buffer Green streets will be created west-east through the and birds. built form and along Roding Lane South providing secondary green corridors that integrate with and All biodiversity enhancement measures will be informed by detailed B Bus Stop complement the wildlife corridor shown on the Section A-A: Green Street ecological survey and guided by the principles of the Nature Conservation Masterplan Concept for GB11B. SPD and BAP. Avenue tree Swale with planting wildflower & marginal planting Principal Street Access to Roding Valley Park Potential to enhance the existing gateway from Roding Lane South to the Roding Valley Park and Roding Way by improving the existing pedestrian Potential and cycle access and providing signage to promote awareness of the river. SUDs Roding Lane South Weir

The green streets incorporating a strong structure of planting, such as avenue trees, and other features such as swales and green roofs / walls will ensure Front gardens incorporating wildlife friendly species ecological permeability through the urban area linking the river with the Redbridge Recreation Ground. Green Street

Section B-B: Open Space

A406 North Residential dwellings Circular Road Roding Way overlooking open space Scrub and tree belts defining site boundary Footpath and margins to the River Roding

River Roding Swale

.

JBA 14/278-SK01: Illustrative Masterplan

Client Site Todcharm Ltd. Land at Roding Lane South, Redbridge Drawn by Date Scale Rev BC / REB March 2015 NTS @ A2 . James Blake Associates Ltd.

LANDSCAPE ARCHITECTURE • LANDSCAPE PLANNING ECOLOGY • ARBORICULTURE Maps / Aerial Images reproduced from Ordnance Survey data by permission of Ordnance Survey Open Space and Buffer - habitat mosaic The Black Barn, Hall Road Licence number 100020449 © Crown copyright of native grassland, scrub and trees Lavenham, Suffolk CO10 9QX Tel. 01787 248216 E-mail. [email protected] Carly Herod

Subject: FW: LOCAL PLAN_Response Form3 doc Attachments: JBA 14_278-Doc1A FINAL Roding Lane South Vision LOW RES.pdf; LOCAL PLAN_Response Form 16.12.14 DRAFT.pdf

From: Andrew Blackwell [mailto:[email protected]] Sent: 16 December 2014 15:58 To: DPD (Planning Service Area) Cc: [email protected]; Myk Tucker; Kate Howard Subject: FW: LOCAL PLAN_Response Form3 doc

Please find enclosed representations on behalf of Todcharm Ltd.

Fundamental to these representations is the appraisal of Green Belt attribute and development potential at Roding Lane South. The appraisal report is contained in the low res pdf attachment and confirms how an appropriate ,realigned Green Belt boundary is possible to release sustainable development and with allied community benefit. Additional hard copies of this will be provided as it is assumed this will be welcomed for convenient viewing and further consultation within LB Redbridge.

My client welcomes the opportunity to meet with the Council to explore common ground posed by these representations and hope this can be possible in the early part of next year.

Confirmation of receipt of these attachments is welcomed.

Andrew Blackwell Divisional Managing Partner - Planning Division

DD: 01245 505 080 Mob: 07880 781 378 Fax: 01245 251 214

Saxon House, 27 Duke Street, Chelmsford, CM1 1HT

The UK’s leading regional property consultancy www.bidwells.co.uk

1

Land at Roding Lane South, Redbridge

Representations to the Redbridge Local Plan Review on behalf of Todcharm Ltd.

Preferred Options Report Extension: Alternative Development Strategies

November 2014

© JBA Consultancy Services Ltd.

JBA Consultancy Services Ltd. • Chartered Landscape Architects

The Black Barn Hall Road Lavenham Suffolk CO10 9QX on behalf of Todcharm Ltd. tel. 01787 248216 e-mail. [email protected] Land at Roding Lane South, Redbridge

Representations to the Redbridge Local Plan Review on behalf of Todcharm Ltd. Preferred Options Report Extension: Alternative Development Strategies

November 2014

CONTENTS

1.0 Introduction 2

2.0 Site Opportunities and Constraints 4

3.0 Green Belt Purposes and Site Function 10

4.0 Development Opportunities 11

5.0 The Vision 13

6.0 Summary and Conclusion 13

FIGURES

Figure 1 - Site Location

Figure 2 - Site Context and Policy Constraints

Figure 3 - Site Analysis

Figure 4 - Site Views

Figure 5 - Views

~~ FINALFINAL REB/REBDB JBAJBA JBAJBA 21Nov/08 2014/2012 Figure 6 - Masterplan Concept for GB11B - Redbridge Green Belt Review Stage 5 (2010) Revision Purpose Originated Checked Authorised Date Document Number: LandDocument at Roding Ref: Lane South, Redbridge Figure 7 - Development Strategy and Vision

JBAJBA 14/278-Doc12/225–Doc1 1 RepresentationsLANDSCAPE AND to the VISUAL Redbridge APPRAISAL Local Plan Review– Land on at behalf of Todcharm Road Ltd., Burnham-on-Crouch

1 1.0 Introduction Figure 1: Site Location

Background Key 1.1 The land the subject of these representations comprises 2.89 ha and is situated immediately south of the M11 Spire Roding Hospital on Roding Lane South, Redbridge, refer to Figure 1. Site location

1.2 As part of its Core Strategy Review, and to inform the content of the Redbridge Local Plan 2015-2030, the A406 London Borough of Redbridge needs to deliberate and decide on the preferred options for future growth. There is currently an acute unmet housing requirement (running at 2,000 new homes per year) and both the Not to scale extent and quality of development are pressing considerations.

1.3 The recent Redbridge Local Plan - Preferred Options Report Extension: Alternative Development Strategies seeks to test alternative strategies beyond the development of the Oakfields Playing Fields at .

A406 1.4 Any alternative strategy needs to comply with the principles of sustainable development in locations close to jobs, services, facilities and public transport routes; that protect existing environmental assets and built/ residential character; and where public open space can be made available. A12

1.5 A reconsideration of Green Belt sites is one option (Strategy 4) currently under review. Concern has rightly been expressed that Green Belt cannot be undermined where the land clearly fulfils the essential functions A12 prescribed in the National Planning Policy Framework, namely:

• To check unrestricted sprawl of large built up areas; Maps reproduced from Ordnance Survey data by permission of Ordnance Survey Licence number 100020449 • To prevent neighbouring towns from merging into one another; © Crown copyright • To assist in safeguarding the countryside from encroachment; • To preserve the setting and special character of historic towns; and • To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

1.6 In support of Strategy 4 these representations, explain how the modification of Green Belt boundaries within Planning Policy and Agreed Position within the London Borough of Redbridge the representation site provide the scope to deliver developable land without compromise to issues of Green Belt protection, landscape and ecology. 1.10 The most recent expression of planning requirements and ambition from Redbridge is set out in ‘Redbridge Local Plan 2015-30 - Draft Preferred Options Extension: Alternative Development Strategies.’ 1.7 This report therefore assesses the site and its context, identifying the constraints and opportunities that have been used to inform the modification of the Green Belt boundary and an illustrative framework for 1.11 The following is confirmed within and which we support and make comment upon: development. Page 16 ‘the Council has nevertheless identified three alternative strategies which it believes to be credible 1.8 It invites support to the premise that the land offers: and to embrace the realistic range of approaches that are available. The preferred option may involve a combination of two or more.’ 1) retention of structural landscape with scope to enhance existing planting; 2) the creation of public open space for informal recreation; 1.12 We agree with this approach since a mix of strategies could create the best balance of considerations and 3) ecological protection and enhancement including ecological connectivity and permeability; outcomes. We do not wish to challenge Oakfields but do see extra scope for current Green Belt locations, 4) scope for residential development; and which can be developed without compromise to the essential purposes of the Green Belt. 5) a clearly defined Green Belt boundary along the River Roding. 1.13 Within Appendix A, is an officer report. This states: 1.9 Overall the site offers the opportunity to extend the South Woodford Investment Area with residential development set in a landscape and ecological framework. This framework will extend and complement the para. 3.1 ‘The resultant Investment Area strategy will help shape the Council’s presumption in favour of Regionally important Roding Valley Park and provide a west – east green corridor offering the potential to sustainable development… close to major transport nodes and including or closely relating to an established link the river with adjoining open spaces as part of the Green Grid and maintaining ecological town centre.’ permeability. 1.14 We agree that sites closer to transport nodes are the most sustainable, but if coupled with environmental enhancement there is opportunity to secure even more community benefit.

2 Figure 2: Site Context and Policy Constraints

Frontage to the Spire Roding Hospital, Roding Lane South

The River Roding Corridor and Roding Way adjacent to the site

Interwar suburban housing fronting Roding Lane South and adjacent streets Footpath access between Roding Way South and the River

Key Site

Green Belt

Major Development in Green Belt Green Corridor

SINC

River Roding

Roding Valley Park

Industrial Estate

Residential

Roding Valley Park adjacent to the site Locally Listed Victorian Pumping Station and Allotments Building Maps reproduced from Ordnance Survey data by permission of Ordnance Survey Licence number 100020449 Sub Station © Crown copyright Road Infrastructure

Electricity Pylons

Significant vegetation

Principal footpaths 3 1.0 Introduction Continued: Figure 3: Site Analysis

1.15 The current consultation report acknowledges that sites not recommended by the 2013 Green Belt Review can be revisited, where they are less critical to Green Belt integrity. It also states that ‘There are also strong Substation sustainability arguments in favour of developing some green belt land. For example sites to the immediate east of Barkingside and Underground Central Line Stations…’

1.16 We agree that proximity to public transport connections are of extra sustainability benefit. Roding Valley 1.17 The location of the site, the subject of these representations, is illustrated in Figure 2. Roding Lane South Way Electricity Pylons lies on a bus route and sits close to both Redbridge and South Woodford Central Line Tube stations. The South Woodford District Centre lies 2km to the north west with 1.5km to the south east. The land is bound by strong geographic features including the raised embankment east of the River Roding with the Spire Roding Hospital Road A406 North Circular further to the west.

1.18 As part of Strategy 4, based on the most recent considerations expressed by Redbridge, the following complementary attributes exist and which deserve fresh consideration. We invite comment to these hitherto Redbridge unrecognised attributes with the following evidence base and resulting “Vision” providing explanatory detail: Recreation Ground

1) through development will overcome dereliction and provide positive use; River Roding 2) through development will create much needed homes; 3) through development fresh boundaries to the Green Belt can be created, securing non- coalescence, protecting the open space and essential openness where important; 4) through development important landscape and ecological habitats can be created and managed; 5) through development public open space can be created; 6) development at this location is sustainable. Bus Stop

Key

2.0 Site Opportunities and Constraints Site Boundary Weir Context Trees and woody scrub Roding Lane South 2.1 The site is situated immediately south of the Spire Roding Hospital on Roding Lane South, Redbridge. The Dense scrub surrounding urban context shown on Figure 2 comprises a mix of uses with the hospital and electricity substation to the north, and residential streets accessed off Roding Lane South to the south and east. Scattered scrub Beyond this lies the Woodford Trading Estate, other buildings (such as schools) set in landscaped grounds, Japanese Knotweed and the Redbridge Recreation area. Intensively grazed paddock Roding Valley 2.2 The residential area comprises interwar housing typical of the Borough. The built form is low- to medium- Park Grassland / ruderal mosaic density with a permeable grid of streets. Dwellings are predominantly two storey semi-detached with areas Watercourse of bungalows and occasional terraces. The overall feel is relatively homogenous, with wide front gardens, Roding Valley walls, hedges and avenue tree planting contributing to the suburban and Garden City character. The Mown track Way Victorian pumping station to the south is a building of local importance. Boundary / Internal Fence

2.3 The west of the site is bound by the River Roding. The river corridor is dominated by road and utilities Photograph Location infrastructure namely the A406 North Circular, it’s intersections with the M11 and A12, and overhead (Figure 4 & 5) Victorian Pumping Roding Valley Park electricity lines. Station Surfaced Footpath / 2.4 The river, part of the London Blue Ribbon network, follows an engineered course that is enclosed by flood cycleway banks to both sides, in conjunction with the A406 embankment to the west. In the vicinity of the site these Informal footpath banks are densely vegetated, isolating the river and screening the majority of views both to and from the Allotments Allotments Locally Listed Building adjacent urban area.

Maps reproduced from Ordnance Survey data by permission of Ordnance Survey Licence number 100020449 © Crown copyright

4 2.0 Site Opportunities and Constraints Continued: Figure 4: Site Views

2.5 The Roding Valley Park forms a green corridor through the urban area. The Park comprises sports / Western boundary screened Spire Roding Hospital Northern boundary recreation areas and allotments and is characterised by a variety of habitats including areas of closely mown by vegetation / rough grassland, scrub and pockets of woodland. The area is accessed by a network of paths and cycle routes, including the Roding Way.

Site Description 2.6 The site (approximately 2.89ha) is broadly triangular and is bordered by Roding Lane South to its eastern and southern boundaries. The land falls broadly north east to south west towards the River Roding which lies to the west. The boundary with the river (part of the wider flood embankments) is formed by moderately sloping banks, between 6-8m high, that extend up to the level of the site. The bank continues along the southern edge of the site where the land steeply slopes down to a backwater or ditch.

2.7 The eastern and northern boundaries are defined by a high chainlink fence, reinforced with timber panels along the boundary with the hospital grounds with scattered vegetation along Roding Lane South.

2.8 The site itself comprises landfill resulting in locally disturbed ground with piles of exposed rubble. The area VIEW S1: Northern Boundary from Paddock supports a range of vegetation types (largely unmanaged) including a mix of grassland, tall ruderal, scrub and dense woodland as set out in Figure 3 and the photographs in Figure 4. Houses fronting Roding Scattered scrub to 2.9 To the north east is a paddock, fenced off from the remainder of the site, with scattered scrub increasing Green Lane South western edge of paddock towards the western fence line (Views S1, S2 and S6). The area is intensively grazed and is subsequently of low ecological value.

2.10 Tall ruderal vegetation with scattered scrub and patches of grassland are present to the central and southern area with occasional groups of semi-mature trees (Views S3 and S4). To the western and southern boundaries the site is contained by established trees and dense scrub (View S5). These areas provide the highest ecological value within the context of the site, forming the margins of and buffer to the River Roding corridor.

2.11 Large stands of Japanese Knotweed are present throughout much of the area degrading its ecological value. As such, the ecological and conservation value of the site in its current unmanaged condition is poor.

Views 2.12 Views from within the site are limited. In the paddock, views are contained by properties fronting on to Roding VIEW S2: View South from Paddock Lane South to the east (View S2 and S6), with the building and car park of the Roding Spire Hospital to the north (Views S1 and S3). Within the central and southern areas, views are enclosed by the established trees and dense scrub. The River Roding located below the site is completely screened by the topography Japanese Knotweed Spire Roding Hospital Mown pathway and vegetation (Views S4 and S5).

2.13 Representative views from the surrounding area are shown in Figure 5.

2.14 From Roding Lane South the paddock provides an open area of rough ground, contained by the scrub and mature trees to the west and south which form a well vegetated backdrop (Views 1 to 6). The views become more enclosed to the south where the mature trees extend to the roadside (Views 7 and 8). In all views the River Roding, A406 and urban areas on the other side of the valley are screened by vegetation both within and adjoining the site. The electricity pylons and overhead lines are the only visible features.

2.15 In views both north and south along the River Roding including the Roding Way (Views 9 and 10), the site and the adjacent hospital building are screened by the embankment and established vegetation along the western boundary. To the south there are glimpses of the Victorian Pumping Station.

VIEW S3: View North from Central Area

View Wd: northern boundary at the reservoir - continued 5 2.0 Site Opportunities and Constraints Continued: Figure 4: Site Views Continued:

2.16 The A406 is lined by woodland belts developed from the original highways planting. Despite the elevation of the road, views are generally enclosed, with occasional glimpses out to urban areas on the high ground on Mature trees Green Roding Lane South the edges of the valley to both the west and east. The River Roding and adjoining development including the Spire Roding Hospital is not visible.

Policy Constraints 2.17 The policy constraints of the site and surrounding area are shown on Figure 3. The River Roding is subject to a number of non-statutory designations, some of which incorporate the site and adjoining land. As demonstrated by the potential release of other Green Belt land immediately adjacent to the site also within these policy areas none of these policies poses such a constraint as to prevent the development of the site subject to:

• The protection and enhancement of the green corridor; • The consideration and integration of landscape features and habitats; and • Development of a suitable scale and design. VIEW S4: View North from Paddock 2.18 The River Roding is part of London’s Blue Ribbon Network. The waterway and immediately adjoining land is strategically important as a multi-functional corridor providing flood management, wildlife habitats, green infrastructure and recreational opportunities. London and Borough Wide Policies seek to protect and Roding Lane South enhance the Blue Ribbon Network for these uses and to protect its open character.

2.19 The River Roding and wider river valley is designated at the local level as a Green Corridor forming a continuous area of open space through the urban environment and providing permeability and habitats for wildlife. In the vicinity of the site the majority of the Green Corridor is incorporated into the Roding Valley Park, but the area also includes areas of land with no public access, such as the site. Borough Wide Policy E2 seeks to protect and enhance Green Corridors. Development proposals may be acceptable, provided that effective habitat linkages along the corridor are maintained.

2.20 The nearest statutory ecological designations are SAC/SSSI and Lee Valley SPA/Ramsar, located approximately 1.8km and 5.8km to the west respectively. Redbridge Council has already considered the effects of development within the Borough on these sites; as the designations are both physically and hydrologically remote, there will not be any impact on these internationally important areas.

2.21 The entire site in included within the non-statutory designation, Roding Valley SINC (Borough Grade 1 importance), whilst the Roding River north of the Liverpool Street to Southend Railway SINC (Metropolitan VIEW S5: Established Woodland to South of Site Importance) lies off site, but adjacent to the west.

Western boundary screened by vegetation Mown pathway Mature trees

VIEW S6: View North from Central Area

6 Figure 5: Views

Site

Roding Lane South Spire Roding Hospital

VIEW 1: Roding Lane South on Junction with Woodford Bridge Road in front of the Spire Roding Hospital to north of site

Site

VIEW 2: Falmouth Gardens on Junction with Roding Lane South to east of site

Site

Roding Lane South VIEW 3: Roding Lane South near Junction with Falmouth Gardens showing site frontage

7 Figure 5: Views Conitnued:

Site

Spire Roding Hospital Roding Lane South

VIEW 4: Roding Lane South on Junction with Falmouth Gardens towards Spire Roding Hospital

Site Roding Lane South Green Falmouth Gardens

VIEW 5: Roding Lane South on Southern Edge of Green

Site

Roding Lane South VIEW 6: Roding Lane South near Entrance to Roding Valley Park

8 2.0 Site Opportunities and Constraints Continued: Figure 5: Views Continued:

2.22 The SINC area is protected at the local level by Core Strategy Strategic Policy 2 Site (beyond vegetation & urban area) and Borough Wide Policy E2. As such development proposals should not harm the nature conservation value of such sites. The Nature Conservation SPD sets out Allotments Roding Lane South guidance that where development may affect a SINC, a positive approach should be taken to ensure that the proposal can deliver an overall improved outcome for VIEW 7: nature conservation. Roding Lane South on Junction with Leigh Avenue 2.23 As large areas of the site are dominated by non-native invasive species, it is South of Pumping Station considered that the site itself is of limited value in the context of the wider SINC. As such, the development can be confined to areas of low ecological value, whilst enhancing retained habitats to increase their botanical and habitat diversity, strengthening their function and value. Therefore, a sensitively designed masterplan would not only accommodate a development with no significant adverse impact upon the SINC but could enhance the value of the site within the wider context.

2.24 The Victorian Pumping Station 180m to the south of the site is Locally Listed. Borough Wide Policy E3 requires that new development is not detrimental to such heritage assets and preserves their setting. The building, a local landmark, is located in an open position to the west of Roding Lane South but is visually A406 Flood separated from the site by intervening vegetation. Development of a suitable scale embankment Roding Valley Way River Roding embankment Site and design will not affect the setting of the building. VIEW 8: Public Footpath on Bridge 2.25 The site lies on the edge of an Archaeological Priority Zone an area of known over River Roding to South archaeological importance. The designation is not intended to prevent the of Site development of these areas, but would trigger the need for an archaeological investigation in accordance with Borough Wide Policy E4.

2.26 The area lies outside of the flood zone.

Opportunities 2.27 As part of the Blue Ribbon Network and Green Grid, the River Roding is a strategic component of both East London and the Borough’s Green Infrastructure (GI) providing a green corridor connecting urban areas to the , the Green Belt and beyond. The East London Green Grid Framework SPG establishes the importance of this GI to sustainable development, providing economic, social and environmental benefits. Site A406 Flood River Roding Roding Valley Way embankment 2.28 With full consideration of the East London Green Grid Framework SPG, through embankment development, the location of the site adjacent to the River Roding provides strategic VIEW 9: opportunities to deliver positive enhancements to the GI network by: Roding Valley Way North of Site adjacent to Spire Roding • Protecting those areas and features of landscape and ecological Hospital importance, enhancing the value of habitats for a range of wildlife and ensuring that they are maintained in perpetuity; • Providing an additional area of safe and accessible public open space alongside the river corridor, incorporating informal recreation opportunities and promoting healthy living; and • Improving public access between the urban area and the adjoining open spaces to the east, the footpath and cycle route network along the river and Roding Valley Park to the west and providing enhancements to existing routes where required.

9 2.0 Site Opportunities and Constraints Continued: Figure 6: Masterplan Concept for GB11B - Redbridge Green Belt Review Stage 5 (2010)

2.29 In meeting the requirements above, there is a vast opportunity to enhance this area of land through development, satisfying the NPPF and local policies regarding nature conservation, contributing to Local and UK BAP priorities, fulfilling the vision of the GI strategy, as well as increasing and enhancing the natural value of the local area for both people and wildlife.

3.0 Green Belt Purposes and Site Function

Context 3.1 The River Roding is incorporated in to the Green Belt and is one of a number of ‘fingers’ of land that extend south from the edge of the wider Metropolitan Green Belt into the urban conurbation. In the vicinity of the site the current Green Belt boundary extends east to the A1400 Woodford Avenue. The Spire Roding Hospital / Electricity Substation and Beal High School are identified as existing Major Development Areas in the Green Belt.

Green Belt Review Site 3.2 The Core Strategy Review acknowledges the need for the release of Green Belt land to deliver the majority of housing required. The areas proposed to be released have been determined through the Council’s Green Belt Review and include five ‘Investment Areas’, the broad extent of which are included in the Redbridge 2028 Core Strategy Review Preferred Options Report.

3.3 One of the identified areas is the South Woodford Investment Area, which incorporates the land immediately to the north and east of the site. This land incorporates a mix of uses and facilities including the Spire Roding Hospital, Beal High School, Hatton School and Redbridge Recreation Ground. As part of the Investment Area 35.78 ha of land is proposed be released from the Green Belt to provide the expansion of these facilities alongside the provision of new residential development in areas of existing open space. The masterplan concept as included in the Green Belt Report Stage 5: Redbridge Site Studies is shown in Figure 6.

3.4 As identified in the Green Belt Review the site falls within the same Green Belt Parcel as the South Woodford 3.7 The site was recommended for release at Stage 3A of the Green Belt Review as part of the total release of Investment Area, namely GB11 ‘Roding Hospital.’ The River Roding to the west is identified as GB09 GB11 ‘Roding Hospital.’ This was on the basis that the ‘urban’ and ‘relatively built up’ area meets none of ‘Roding Valley Park.’ The boundary between the two parcels is defined by the River Roding. the national policy objectives of Green Belt and only a number of the local purposes, namely by providing areas of locally but not strategically important open space. 3.5 Stage 3 of the Green Belt Review assesses the role of each Green Belt Parcel against the five purposes of the NPPF, namely: 3.8 GB09 ‘Roding Valley Park’ in contrast is described as a ‘corridor of open land straddling the M11… bordered by urban development to the east and west.’ The area was assessed at Stage 3A as similarly meeting • To check unrestricted sprawl of large built up areas; none of the national policy objectives, but was none the less recommended ‘to be retained as Green Belt • To prevent neighbouring towns from merging into one another; because of its role by linking the wider Green Belt (to the north) with Park and • To assist in safeguarding the countryside from encroachment; (to the south).’ Despite this, the desk study considers that certain elements ‘particularly the eastern side • To preserve the setting and special character of historic towns; and of the parcel should be considered for sub-division and potential removal from Green Belt.’ Locally the • To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. area is considered to provide important open space, a barrier between the local centres of Woodford and Redbridge, and the setting to Wanstead Bridge / Woodford Bridge Conservation Areas as well as a number 3.6 The majority of Green Belt in the Borough is described as ‘atypical’ comprising green wedges and corridors. of listed buildings. As such the definition of ‘countryside’ above is taken to include ‘countryside in and around towns’ or CIAT i.e. land on the urban fringe that performs similar functions. In addition a number of local purposes are also 3.9 At Stage 3B of the review, following site-based analysis, land within parcel GB09 Roding Valley Park was identified as: re-categorised as CIAT, due to its ‘scale and relative openness in spite of the M11.’ As such in contradiction to previous findings the study concludes that the area meets national policy by ‘preventing encroachment.’ • To check sprawl into locally important open space; As the boundaries of the area are ‘well defined... any infill (as initially recommended) would subsequently • To prevent the merging and coalescence of local centres (within the urban conurbation); lead to encroachment’ and as such the area should be retained in full. • To safeguard locally important open space; and • To preserve the setting and character of conservation areas.

10 3.0 Green Belt Purposes and Site Function Continued:

3.10 Within GB11, the area subject to these representations, is also singled out as a ‘woodland area…. connected 3.20 As set out above parts of GB11 ‘Roding Hospital’ such as the site do provide local but not strategically to GB09 containing the Roding Valley.’ The area is subsequently subdivided and incorporated into GB09 as important areas of open and amenity space. Unlike other areas, the site is not currently subject to public CIAT and retained to safeguard land from encroachment. access.

Contribution of the Site to National Objectives 3.21 In respect of other local purposes identified in the Green Belt Review the land does not prevent the merging 3.11 These representations strongly disagree with the conclusions of the Green Belt review that that the site of neighbouring towns or local centres, with GB09 ‘Roding Valley Park’ (including the floodplain and strategic meets this national objective and safeguards countryside from encroachment. infrastructure) providing a local barrier between Woodford and Redbridge. The built environment of the area comprises interwar and modern development and does not form the setting of any conservation area or 3.12 Indeed the Green Belt review is particularly contradictory in respect of the nature of the site and its Green listed building. Belt function. Green Belt Boundary 3.13 The Stage 3B Site Assessment Sheet for GB11 ‘Roding Hospital’ concludes in the summary that ‘The small 3.22 It is proposed that the site as part of GB11 ‘Roding Hospital’ does not fulfil the purposes of Green Belt at the triangular parcel to the south of Roding Hospital,’ namely the site ‘both physically and visually link with national level. It is proposed that the land is released and incorporated in to the South Woodford Investment GB09.’ This statement is in opposition to earlier statements in respect of vegetation structure that: Area, an area identified as a sustainable location for development.

‘there is scrub woodland to the western part of the GB parcel near to Roding Hospital…. This provides a 3.23 In considering the new Green Belt boundary, the top of the flood embankment provides a clearly defined and degree of visual enclosure from land to the west…’ permanent physical boundary.

As well as earlier aspects of the summary summary which state: 3.24 The function of the site as open space is similar to other areas within GB11 already identified for release. As highlighted through the assessment of constraints and opportunities the location of the site adjacent to the ‘Roding Hospital and the substation area within the GB parcel (located to the west of Roding Lane South are River Roding provides a strategic opportunity to deliver positive enhancements to the GI network. visually separated from GB09 by a screen of vegetation.’ As such the area along with land to the east which is enclosed by development ‘do not therefore meet PPG2 [national] GB purposes.’ 3.25 We subsequently agree with para 3.3.6 of the Stage 5 report that ‘as part of the release of this site from the Green Belt it is suggested that part of the site not subject to development should have some form of policy 3.14 It is noted that the full Site Assessment Sheet for GB11 is not included in the original study published on protection to the open space / urban open space.’ It is suggested that this would ensure that those areas of the Council’s website. As such the public have not had opportunity to view or comment on the correct land within the site but outside of the resulting Green Belt boundary are suitably protected as wildlife habitat assessment. and publically accessible open space.

3.15 Informed by a thorough assessment of the site and its context, we support the view that the land is physically separated from GB09 ‘Roding Valley Park’ by the flood embankment and resulting change in level between 4.0 Development Opportunities it and the River Roding. Furthermore the vegetation on this bank and the tree belts to the western and southern edges of the site (continuations of those that similarly define the substation and Spire Roding 4.1 The analysis of opportunities and constraints in conjunction with the potential to re-establish a new permanent Hospital to the north as described above), visually screen and separate the land from the wider corridor to Green Belt boundary demonstrates that the site can deliver significant landscape, ecological and open the west. space benefits alongside the delivery of much needed development.

3.16 Furthermore, although the site assessment sheet for GB09 ‘Roding Valley Park’ considers that the area has Positive Use and Delivery of Development a lack of woodland the A406 embankment and associated tree belts along with the vegetation along the 4.2 Development will enable the positive use of derelict land with the delivery of much needed homes. The eastern edge ensures that this section of the corridor is strongly enclosed and visually isolated with limited site is well related to proposed development within the South Woodford Investment Area and is sustainably visual connection to urban areas in close proximity to both the west and east. located near to local centres and transport links.

3.17 The remainder of the site, although relatively open to the north east, relates to the development including Green Belt Boundary the building and car park of the Spire Roding Hospital to the north, with adjacent residential areas wrapping 4.3 An analysis of the site demonstrates that it does not fulfil national Green Belt purposes. The top of the flood around the curve of Roding Lane South and forming an urban boundary to the east and south. This, in embankment on the western edge of the site provides a clearly defined and permanent physical Green Belt combination with the vegetation to the west ensures that the land does not feel part of a wider area of boundary to both the site and South Woodford Investment Area. countryside, and can be developed without causing encroachment. 4.4 At the local level, the site provides local amenity space. To maintain this function an area to the north east 3.18 As such the conclusions of the Stage 3A assessment that the land does not meet any of the national and along the western and south western edges of the site should be undeveloped to provide a green purposes of Green Belt is strongly supported. framework to the development with extensions to the existing open areas in front of the Roding Hospital and a buffer to the river corridor. The existing substation and Spire Roding Hospital define a logical limit to the Local Objectives extent of the urban area. 3.19 We endorse the view set out in the Redbridge Local Plan 2015-30 - Draft Preferred Options Extension: Alternative Development Strategies that ‘some sites are more critical to green belt integrity than others.’ 4.5 The resulting area of open space can be protected by Borough Wide open space policies. This is particularly true of those aspects identified at the local level.

11 4.0 Development Opportunities Continued:

Retention and Management of Important Landscape Features and Habitats 4.6 The development described above will be confined to areas that contain habitats of low value to biodiversity • Wooded areas and significant trees within the site will be subject to an arboricultural survey and the natural environment, with the location of open space to the west and south west coinciding with and those identified of importance will be safeguarded. Important trees will be protected from areas of landscape and ecological importance including the scrub and tree belts that constitute the habitat disturbance during construction by standard industry practices and in accordance with guidance margins of the River Roding. These natural habitats will be retained and enhanced, with the development set out in the Trees and Landscaping Supplementary Planning Document; ensuring their management in perpetuity. • The western and southern area of the site has potential for increased public access as an area of nature conservation importance. In combination with other enhancements to the site, 4.7 There is ample opportunity within the south of the site to retain and enhance any features and habitats of there may be opportunity for educational programmes, facilities and community engagement in ecological value and increase the access and quality of this area for use as public open space or parkland. nature conservation; The retention and enhancement of habitats, where appropriate, are likely to be of more value to biodiversity • A mosaic of habitats and habitat structures will provide the greatest nature conservation value. than creating new, more traditional habitats and as such any features of high value will be retained where These will be implemented into the design of landscaping and planting schemes throughout the possible. It is likely that large areas of the site will need to be cleared in order to eradicate Japanese site; Knotweed. This means that there is an opportunity to significantly increase the biodiversity and nature • Creation of artificial ponds or wetland areas near to the waterways will provide a valuable conservation value of the site by allowing native species to re-colonise along with creating new habitats. The environment for aquatic plants, invertebrates, fish and amphibians as well as providing a retention of ecological features on site combined with the creation of new habitats will provide the highest suitable resource for local bird populations and increase the value of the bat buffer zone in natural value. accordance with the Redbridge BAP. Such aquatic habitats will also be highly attractive features for public attention and private enjoyment as well as further opportunity for promoting nature 4.8 All biodiversity enhancement measures will be informed by detailed ecological survey and guided by the conservation through education and community engagement; and principles of the Nature Conservation SPD and London Borough of Redbridge Biodiversity Action Plan • Installing bird and bat boxes on site will provide additional wildlife benefit, along other (Redbridge BAP) to ensure the highest benefit for nature conservation within the context of the site and enhancements for invertebrates, small mammals and other BAP and protected species. wider area. Nature conservation, protection and enhancement of open space and areas of ecological and community value will be achieved through the following methods: 4.9 The current ecological and nature conservation value of the site is extremely limited due to current land use and management. The site is located within the Roding Valley SINC and in order to satisfy the requirements • New, more valuable habitats will be created to enhance the value of the open space, of section 4.3 of Strategic Policy 2 of the Core Strategy and Policy E2 of the Borough Wide Policies, there particularly in the south of the site and along the riparian zone of the River Roding. Whilst is opportunity to enhance the nature conservation value of the site through the protection and enhancement creating new habitat will have a large role to play in rehabilitating this area, attention will be paid of valuable habitats and the eradication of non-native invasive plants which have a detrimental effect on to retaining existing features which may contain more value to biodiversity conservation; the environment. There is also vast opportunity to significantly improve, regenerate and enhance the site’s • Due to the current poor value of the majority of habitats on site, there is a great opportunity to nature conservation value through development in relation to the objectives of the London Borough of enhance this area’s natural value providing an enhanced green corridor along the edge of the Redbridge BAP, the Local Development Framework Core Strategy and the Borough Wide Policies. River Roding. Enhancing this area will be beneficial for many species within the landscape, particularly bats and birds. Enhancement to the green corridor will address the objectives of Public Access and Use the Redbridge BAP; 4.10 As outlined above development of the site will provide areas of high quality local open space, all of which will • Reduction in surface water run-off by incorporation of Sustainable Drainage Systems, such as be accessible to the community. The open spaces will be designed to be multi-functional providing a range swales and retention ponds, will manage flood risk and provide a valuable habitat for wildlife; of opportunities for informal recreation, children’s play and seating alongside wildlife habitats and sustainable • Restoration of land adjacent to the River Roding by removing invasive Japanese Knotweed and drainage. As such the area will provide social and physical benefits as well as potential opportunities for re-planting with locally native species, retaining as much natural habitat as possible. Creation educational programmes (in conjunction with local schools and community groups) and engagement in of linear features such as this will be beneficial for the watercourse as a green corridor; nature conservation. • Restoration of habitats alongside the River Roding and protecting the waterways from disturbance, pollution and damage throughout construction in accordance with the requirements 4.11 The approach to the site will provide a positive relationship between the open space and built form to ensure of The London Plan: Blue Ribbon Network; active surveillance of the public realm. • By using current and further site specific ecological survey data, all protected and BAP species will be protected. Mitigation for any loss of habitat can be provided prior to, during and after 4.12 In conjunction with the development there is potential to enhance the existing gateway from Roding Lane the construction phase; South, promoting pedestrian and cycle access to the Roding Valley Park and Roding Way. This could • Protecting and where appropriate, enhancing habitats on site will extend habitats and include improvements to the existing pedestrian route and signage to promote awareness of the river. vegetation within the borough for the benefit of wildlife, contributing to green corridors and reducing the effects of habitat fragmentation; Green Infrastructure • Establishing secondary green streets or corridors west to east through the site and along 4.13 The site provides the opportunity for development set within a strong landscape and ecological framework. Roding Lane South enhancing the links between existing strategic and local open spaces and The design approach described above incorporating the retention and management of important landscape maintaining ecological permeability through the urban area. Green streets will incorporate features and habitats; ecological connectivity and permeability; alongside provision of public access will a strong structure of planting, such as avenue trees, and other features such as swales and provide improvements to the River Roding corridor and ensure a positive contribution to the Blue Ribbon green roofs / walls; Network and East London Green Grid.

12 5.0 The Vision

5.1 The resulting strategy and development vision for the site is set out in Figure 7. This demonstrates a net residential developable area of approximately 1.8 ha in a sustainable location well related to the South Woodford Investment Area.

5.2 The resulting landscape and ecological framework provides the setting to a sensitively designed masterplan that not only accommodates development but indeed enhances the natural value of the local area for both people and wildlife.

6.0 Summary and Conclusion

6.1 These representations have identified that the Green Belt Studies which have informed the current consultation offer conflicting conclusions between their various stages and where the final assessment for this land was missing from its publication. Our findings show that the site does not perform functions consistent with Green Belt guidance but rather, through development, offers scope for improved landscape and ecological management.

6.2 We invite the London Borough of Redbridge to reconsider the development plus open space potential of this land, based on the very careful critique offered by the evidence in this report.

6.3 The scope to deliver a net developable area of 1.8 ha within a rich landscape and ecologically managed setting, offers combined benefits secured through development. It should therefore be counted asa resource to meet urgent housing need. In this context it is asked to be recognised as a very sustainable contributor to Strategy 4, which is supported.

13 Figure 7: Development Strategy and Vision

Green Belt Boundary The top of the flood embankment on the western edge of the site provides a clearly defined and permanent physical Green Belt boundary to both the site Substation and South Woodford Investment Area. Electricity Pylons Local Open Space A small area of amenity space will be provided to the north east corner of the site to extend the frontage of the Hospital. Development to be set back and positively address the space and views from the north along Roding Roding Valley Lane South. Park Wildlife Corridor Roding Valley Way Development Area Woodford Bridge Residential development is confined to areas that contain habitats of low Public Open Space and Buffer to River Roding Spire Roding Hospital Road value to biodiversity and the natural environment with buildings set back Open space to be provided to the western and south western boundaries forming a green frontage along Roding Lane South with a positive relationship coinciding with areas of landscape and ecological importance including the between the built form and open space to ensure active surveillance of the scrub and tree belts that constitute the habitat margins of the River Roding. public realm. These natural habitats will be retained and enhanced, with the development As established by the Redbridge Characterisation Study the development ensuring their management in perpetuity. will positively respond to the surrounding context and ‘Garden City’ character with buildings informed by the surrounding urban form and a strong structure The design of the open of planting, such as avenue trees. Important mature trees will be retained space will be multi- where informed by arboricultural survey. functional incorporating nature conservation, Redbridge Recreation informal recreation, play, Ground River Roding seating and sustainable Green Streets / Corridors drainage. There will be Green streets will be created west-east through the a mosaic of habitat types built form and along Roding Lane South providing beneficial to both BAP secondary green corridors that integrate with and and protected species, Key complement the wildlfe corridor shown on the including bats and birds. Bus Stop Masterplan Concept for GB11B (Figure 6). Site Boundary

Suggested extent of built development

Proposed Green Belt boundary Weir Roding Lane South Access to Roding Valley Park Existing strategic open space Potential to enhance the existing gateway from Roding Lane South to the Roding Valley Park and Roding Way by improving the existing pedestrian Existing & proposed local and cycle access and providing signage to promote awareness of the river. public open space / amenity space Proposed area of residential development

Green Streets forming corridors through urban area linking strategic and local open spaces The green streets incorporating a strong structure Retention & enhancement of Maps reproduced from Ordnance Survey data by permission of Ordnance Survey Licence number 100020449 of planting, such as avenue trees, and other © Crown copyright existing boundary vegetation features such as swales and green roofs / walls will Watercourse ensure ecological permeability through the urban area linking the river with the Redbridge Recreation Surfaced footpath / cycleway

Informal footpath

Potential access enhancements and gateway to Roding Valley Park

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