21 Garlick Hill, London, EC4V 2AU T: 020 7489 0213 F: 020 7248 4743 E: [email protected] W: dwdllp.com
Date: 19/09/2016 Our Ref: 9867
Planning Policy
London Borough of Redbridge
Planning and Regeneration
PO Box 2
Town Hall
Ilford
IG1 1DD
Sent via Email: [email protected]
Dear Sirs
REDBRIDGE LOCAL PLAN 2015‐2030: PRE‐SUBMISSION DRAFT CONSULTATION REGULATION 19 OF THE TOWN AND COUNTRY PLANNING (LOCAL PLANNING) (ENGLAND) REGULATIONS 2012. We have been instructed to submit written representations to the London Borough of Redbridge on behalf of the PDSA, who hold the freehold interest of land on the north side of Woodford Bridge Road, Redbridge, IG4. The site comprises of:
1. The PDSA Hospital, associated car parking and Pet Cemetery 2. St Swithin’s Farm and the surrounding grazing land plus a block fronting Woodford Bridge Road comprising of 2 x 2 bedroom flats and a row of 4 garages. Our representations relate to the second parcel of land referred to above as detailed on the attached Site Location Plan at Appendix 1, which totals circa 2.33 ha (5.46 acres).
This letter responds to questions 5 and 6 detailed in Part B of Redbridge’s representation form and should be read in conjunction with the completed form.
5. Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty‐to‐cooperate. Please be as detailed as possible. If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co‐operate, please also use this box to set out your comments.
1. The Pre Submission Draft Local Plan confirms that the subject site should be released from the Green Belt designation. Our client supports this decision. 2. The supporting text to draft policy LP34 (Managing and Protecting the Borough’s Green Belt and Metropolitan Land) considers land, including the subject site that is proposed to be released from the Green Belt and states that (Paragraph 6.1.9): “The Council therefore proposed to release the parcels of existing Green Belt in the borough which do not meet the purposes of the Green Belt to ensure there is sufficient land available to be able to meet the Borough’s challenging housing and infrastructure growth requirements. The Council
Partners
A M Davis FRICS IRRV R J Greeves BSc (Hons) MRICS A Vickery BSc MRICS IRRV S Miles BSc (Hons) MRICS N P Draper FRICS IRRV A R Holden BSc (Hons) FRICS G Denning B.Eng (Hons) MSc MRICS A Meech BSc MRICS N M Fennell BSc MRICS G Bullock BA (Hons) BPI. MRTPI B Murphy BA (Hons) MRUP MRTPI
Dalton Warner Davis LLP is a Limited Liability Partnership. Registered in England No. OC304838. Registered Office: 21 Garlick Hill, London, EC4V 2AU
considers that the sites above which are proposed to be allocated as ‘Opportunity Sites’ (See Appendix 1) will contribute to sustainable patterns of development as these sites are all located within the borough’s Investment and Growth Areas, which are highly accessible locations and near the borough’s main transport corridors.”[DWD emphasis] 3. The sites referred to in paragraph 6.1.9 are listed in paragraph 6.1.7 and include the subject site (Roding Hospital and the Surrounding Area (parcels GB11b and GB11c)). The subject site also falls within the South Woodford Investment and Growth Area (Policy LP1D), however it is not proposed as an ‘Opportunity Site’. 4. Policy LP1D identifies that in order to deliver growth and regeneration in South Woodford the Council will seek to provide 650 homes, 2,000 sqm of new retail floorspace, 5,000 sqm of new employment floorspace, 100 new jobs and infrastructure improvements. The supporting text to this policy advises that “The Opportunity Sites within the Investment and Growth Area have the potential to provide approximately 651 new homes” (paragraph 3.6.5). 5. The table at Appendix 1 of the Pre Submission Local Plan details the ‘Opportunity Sites’ identified to come forward in the South Woodford Investment and Growth Area in Phase 1, 2 and 3 and their development capacity: Phase 1 (2015‐ 2020) – total indicative development capacity of 55 units (consent has been granted for all these sites). Phase 2 (2021 – 2025) – total indicative development capacity is 545 units (no current planning application or new permission for any of the sites). Phase 3 (2026 – 2030) ‐ no sites are listed. 6. The table at Appendix 1 confirms a total development capacity of 600 units, which is lower than the 651 suggested in the supporting text to policy LP1D and the Council’s target to provide 650 units within the South Woodford Investment and Growth Area. The identified capacity is only an estimate given that no planning permissions have been granted for the sites identified as part of Phase 2. Delivery of the number of dwellings is by no means certain. 7. The development capacity detailed at Appendix 1 also does not correspond with Table 3 (Housing delivery by location and plan phase) of the Pre‐Submission Local Plan which advises that South Woodford Investment and Growth area is expected to provide 88 units in Phase 1, 412 units in Phase 2 and 151 units in Phase 3 totalling 651 units. This suggests 500 units to 2025, rather than the 600 listed in Appendix 1. 8. These figures are not clear and we therefore question the soundness of the plan in relation to the housing allocations within the South Woodford Investment and Growth Area, which based on the sites detailed in Appendix 1, fall short of the Council’s housing targets for this area. 9. The Council has overlooked the potential of the subject site to deliver further housing within this Growth Area and to help Redbridge meet its housing targets in the Plan period. The site has previously been considered for housing by the Council. Stage 5 of The Green Belt Review (2010) undertaken by Colin Buchanan looked at potential development opportunities on Green Belt land and set out a proposed masterplan for GB11B, which the subject site falls within. The masterplan considered the potential of residential development on St Swithin’s Farm stating that (paragraph 3.3.14):
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“We believe there exists an opportunity to create an additional residential site on the St Swithin’s Farm site in line with the previous idea of locating apartment sites central to the Parcel to limit impact on surrounding neighbours and optimising the views. Residential development: say one apartment site ‐ potential capacity for up to 50 new units. “ 10. The masterplan (Appendix 2) prepared on behalf of the Council suggests that the St Swithin’s Farm site has capacity for high density residential development. The map excludes the far east section of the land owned by the PDSA, that currently forms part of St Swithin’s Farm, from this proposed use and incorrectly describes this land as ‘existing playing fields’. The overall capacity of the site would therefore be greater than that suggested. 11. The Draft Green Belt Review (January 2016) undertaken by Wardell Armstrong does not further discuss the potential residential use of the subject site and The Pre‐Submission Draft Policies Map (July 2016) instead designates the majority of the subject site as ‘Open Space’ describing the land as ‘Open Spaces – PDSA Cemetery for Animals’. The part of the site comprising of existing farm buildings, garages and a 2 flats has been excluded from the Open Spaces designation. An extract of the Policies Map is provided at Appendix 3. We consider that the remainder of the site owned by the PDSA should also be removed from this proposed Open Space designation. 12. Figure 3.1 of The Redbridge Open Space Study (July 2016) identifies the St Swithin’s Farm grazing land as a 'PDSA Cemetery for Animals' (Plot 145). Plot 145 is not a Cemetery and it is not the PDSA’s intention to use this part of the site as a Cemetery in the future. The existing PDSA Pet Cemetery is correctly identified at Plot 302 on Figure 3.1 and the PDSA seek to retain the site in this use. No direct reference is made to Plot 145 in the main Open Space Study report and it is unclear why the site is considered suitable as Open Space. This designation has not been appropriately justified by the Council and for this reason, and the reasons set out below, we do not consider that the allocation of this land as Open Space is sound. 13. St Swithin’s Farm is privately owned by the PDSA, it has never been open to the public, there are no rights of way and it is not the PDSA’s intention to make this land available to the public. The National Planning Policy Framework (NPPF) (2012) describes Open Space as “All open space of public value, including not just land, but also areas of water (such as rivers, canals, lakes and reservoirs) which offer important opportunities for sport and recreation and can act as a visual amenity” (page 54). The subject site does not meet this criteria because it is not available for public use. Paragraph 73 of the NPPF considers that Open Space assessments “should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area”. It is not considered that the Open Space study has undertaken this in relation to the subject site. 14. There is a large amount of open space near to the subject site, including the Beal High School playing field to the north and east of the subject site, Redbridge Recreation Ground to the south of the site and retained Green Belt to the west of the site, alongside the North Circular. Some of this land is publically accessible. The removal of the subject site from the Open Space designation would not result in a deficit of Open Space at this location. 15. Furthermore, the designation of this site as Open Space is likely to constrain future development of land which is considered suitable for release from the Green Belt to meet Redbridge’s housing and infrastructure needs (paragraph 6.1.9 of the Pre Submission Local Plan) as it may be considered to conflict with the policy requirements of LP35 (Protecting and Enhancing Open
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Spaces) which states that the Council will protect existing green space and resist inappropriate development. 16. The PDSA has instructed Stagg Architects to prepare a masterplan of the site and appointed EAS transport consultants to consider development capacity of the site and highways and access arrangements. The proposed masterplan is provided at Appendix 4, together with the written transport advice at Appendix 5. The work undertaken to date by the PDSA suggests that the site has the capacity for: 118 units which equates to a density of 51 units per hectare or 190 habitable rooms per hectare. 73 houses (3 and 4 bedrooms) and 45 flats in 3 storey blocks (1 and 2 bedrooms) Access and exit to the development via Woodbridge Road 500 sqm of communal green space plus 800 sqm of child’s play space totalling 1,300 sqm All houses are provided with rear gardens and the flats have balconies 150 car parking spaces are proposed (1.3 per unit average) 17. Whilst further discussion with the Council is required to agree the masterplan and detailed design, the masterplan provided at Appendix 4 demonstrates the opportunity to bring forward this currently underutilised site. The removal of this site from the Open Space designation and the allocation of this site as an ‘Opportunity Site’ will facilitate the provision of housing development to assist the Council meet the requirements of Policy LP2 (delivering Housing Growth), which states that the Council will deliver a minimum target of 16,845 new dwellings in the period 2015 to 2030, and Policy LP1D which seeks to provide 650 new homes in the South Woodford Investment and Growth Area. 18. Any proposed housing scheme on the site would be required to provide an element of communal green space. As illustrated by the masterplan at Appendix 4 open space would be provided on site which would be open to the public and of an improved quality to the existing condition of the land. If the Open Space designation is retained it is expected that the site will remain as existing, and closed to the public. 19. The subject site is surplus to the PDSA’s requirements and is currently underutilised. Most of the buildings on site are dilapidated, although there is a small element of horse grazing undertaken from the site. The PDSA would support development coming forward on this site, within the next 5 years. It is envisaged that the PDSA would sell the site or enter into a Joint Venture agreement with a developer. It is considered that the site could be delivered within Phase 1 or Phase 2 of the plan period. 20. The allocation of part of this site as Open Space will prevent housing being bought forward on a site which is currently underutilised. In summary we do not consider that the allocation of this land as Open Space is sound because: It has not been appropriately justified – the allocation of this land as Open Space cannot be appropriately justified because it is not available for that purpose It has not been positively prepared – the Open Space allocation conflicts with the Council’s proposal to exclude the land from the Green Belt and restricts its ability to meet its
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objectively assessed housing need and its associated strategy to bring forward development on land parcels released from the Green Belt and to provide 650 homes within the South Woodford Investment and Growth Area. It is not consistent with National Policy‐ it is not considered that the site has been appropriately assessed by the Council as an Open Space, in line with the NPPF. In addition, the Open Space designation will constrain development that should be deemed, in our view, sustainable on the site. 6. Please set out what modification(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the test you have identified at question 5 above where this relates to soundness. (NB please note that any non‐compliance with the duty to co‐operate is incapable of modification at examination). You will need to say why this modification will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as detailed as possible.
1. In order to make the Local Plan sound we propose that: The Open Space designation is removed from the St Swithin’s Farm grazing land The 2.33 ha site (comprising of St Swithin’s Farm, the associated grazing land, 4 garages and the block of 2 flats) should be listed as an ‘Opportunity Site’ in Appendix 1 of the Pre‐ Submission Local Plan as follows: Address Size Ward Current Proposed Indicative Phasing Planning (ha) Use Use Development Period Status Capacity St Swithin’s Farm 2.33 Clayhall Farm/ Housing 118 1 or 2 No current and the Grazing planning surrounding Land application grazing land, or Woodford Bridge new Road permission
2. It is considered that the above proposed amendments will make the Local Plan sound for the following reasons: The additional units that the development of the site would provide will help ensure that the Council has sufficient housing allocations to meet its target of providing 650 new homes in the South Woodford Investment and Growth Area as set out in policy LP1D. Based on the current allocations listed in Appendix 1 of the Pre Submission Local Plan we do not consider that this target can be met. The purpose of the Council releasing parcels of existing Green Belt in the borough which do not meet the purposes of the Green Belt, as set out in the NPPF is “to ensure there is sufficient land available to be able to meet the Borough’s challenging housing and infrastructure growth requirements” (paragraph 6.1.9 of the Pre‐Submission Local Plan). The allocation of the St Swithin’s Farm grazing land as Open Space is not feasible because it is in private ownership. It will also prevent the growth sought by the Council and therefore
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conflicts with other parts of the Local Plan. The St Swithin’s grazing land has the potential to provide housing units, as detailed in the Masterplan provided at Appendix 4.
If you have any further queries in relation to the submitted form or the above please do not hesitate to contact Emma Penson of this office (02073322115/ [email protected])
Yours faithfully
Dalton Warner Davis LLP
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APPENDIX 1 – SITE LOCATION PLAN
9867 PDSA, Woodford Bridge Road
St Swithin's Farm and Grazing Land 2.33 ha (5.46 acres)
Mon
Peoples Dispensary for Sick Animals
PDSA Hospital St Swithin's Farm and Pet Cemetery
m
WOODFORD BRIDGE ROAD
23.0m
Games Court
0m 25m 50m 75m
Ordnance Survey © Crown Copyright 2016. All rights reserved. Licence number 100022432. Plotted Scale - 1:1250
Ref.: DWD/01
APPENDIX 2 ‐ GREEN BELT REVIEW (2010) – STAGE 5 MASTERPLAN
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APPENDIX 3 – PRE SUBMISSION DRAFT POLICIES MAP EXTRACT SHOWING OPEN SPACE DESIGNATION
(Green Line denotes Open Space designation)
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APPENDIX 4 – MASTERPLAN OF THE SUBJECT SITE PREPARED BY STAGG ARCHITECTS
9867 stagg architects ǁǁǁ͘ƐƚĂŐŐĂƌĐŚŝƚĞĐƚƐ͘ĐŽ͘ƵŬ area schedule - summary
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(Areas below are Net Internal)
Apartments:
2-bed 1-bed 70m2 50m2
35 no. 10 no.
Houses:
4-bed 3-bed 3-bed APARTMENTS LOCATED OVER 100m2 88m2 88m2 3-FLOORS
EXPANDED SITE AREA (SOLID LINE) = 2.33 hectares (5.46 acres)
26 no. 23 no. 24 no.
Total Units = 118
Site Area = 2.33 ha
APARTMENTS LOCATED OVER Density: 3-FLOORS 51 units per hectare / 20 units per acre
2-bed 70m2 1-bed Car Parking: 50m2
2-bed Approx 150 spaces (1.3 per unit CORE 70m2 average)
CORE Amenity: 1-bed 2-bed 2no. 2-BED FLATS ABOVE 50m2 70m2 BEAL Garden lengths generally = 10 to 12 HIGH metres SHARED GREEN SCHOOL SPACE PLAY AREA 1-bed 1-bed = 500m2 = 800m2 43m2 45m2
1-bed 1-bed PDSA 40m2 40m2
WOODFORD BRIDGE RD
LARGER 4-BED HOUSES IN OUTLINE OF EXISTING FLATS AND CORNERS WITH LARGER GARDENS
RODING LN S GARAGES TO BE DEMOLISHED EXISTING BUILDING RETAINED AND CONVERTED
6m WIDE ACCESS ROADS (with 6m and 13.6m radiuses)
STRAIGHT ACCESS ROAD ENTRANCE WITH VISIBILITY SPLAY OF 2.4m x 45m
SINCLAIR HOUSE
REVISIONS REVISIONS KEY PLAN SCALE BAR N 3rd FLOOR, 44-46 NEW INN YARD, LONDON EC2A 3EY DRAWING TITLE REV DATE AMENDMENT REV DATE AMENDMENT (METRES) [email protected] PROPOSED OPTION 1 A 29.04.16 TRANSPORT CONSULTANT COMMENTS stagg architects www.staggarchitects.co.uk B 09.05.16 TRANSPORT CONSULTANT COMMENTS 1:1250@A3 0 10 25 50 75 NOTES AND CLARIFICATIONS CLIENT PROJECT DATE DRAWN A1 SCALE A3 SCALE PLEASE READ DRAWING IN ACCORDANCE WITH CROSS-REFERENCED SPECIFICATION / SCOPE OF WORKS. DALTON WARNER DAVIS LLP, ST SWITHIN'S FARM, c STAGG ARCHITECTS LIMITED. NO IMPLIED LICENCE EXISTS. 14.03.16 GS/BS 1:625 1:1250 THIS DRAWING SHOULD NOT BE USED TO CALCULATE AREAS FOR THE PURPOSES OF VALUATION. 21 GARLICK HILL, WOODFORD BRIDGE ROAD, SUBJECT TO PLANNING PERMISSION, BUILDING REGULATIONS, STATUTORY UNDERTAKER SEARCHES AND DESIGN DEVELOPMENT. STATUS DRAWING NO REV DO NOT SCALE DRAWINGS. DIMENSIONS GOVERN. ALL DIMENSIONS TO BE VERIFIED ON SITE BY CONTRACTOR BEFORE PROCEEDING. LONDON EC4V 2AU ILFORD, IG4 ARCHITECT SHALL BE NOTIFIED IN WRITING OF ANY DISCREPANCIES. INFORMATION 51603-SK-01 B
APPENDIX 5 – EAS TRANSPORT ADVICE ON MASTERPLAN
9867 19 th May 2016
Emma Penson Unit 108 The Maltings Dalton Warner Davis LLP Stanstead Abbotts Herts SG12 8HG
Tel 01920 871777 By Email www.eastp.co.uk
Dear Emma,
St. Swithin’s Farm, Woodford Bridge Road, Ilford IG4 5LN Highway Summary Note
EAS were commissioned to investigate options for a new site access to a proposed residential development located at St Swithin’s Farm, located off Woodford Bridge Road, Ilford. This letter provides a summary of the access appraisal for the site. It has been prepared to provide advice on the site’s development potential to inform a masterplan of the site.
The site is located off Woodford Bridge Road between Roding Lane South 130m to the west of the site boundary and the northbound dual carriageway of Woodford Avenue (A1400) 550m to the east of the site. The site is located around 400m to the west of the Beal High School, 800m to the north of the Redbridge Primary School, and 1.2km to the north of Redbridge underground station.
A number of options for accessing the site and the internal road layout were considered as part of an initial appraisal. The selected option is on the basis of a single point of access in close proximity to the current access point to St Swithin’s Farm, with an internal loop provided within the site boundary. This is illustrated on SK01 which shows the access arrangement, visibility splays & dimensions, and SK02 which illustrates swept path analysis; both attached to the rear of this letter.
The access and internal road arrangement was selected on the basis of the following advantages:
• adequate visibility splays can be provided to 2.4m x 45m to meet the Manual for Streets requirement for design speeds of up to 31-32mph as illustrated on SK01, and based on an automatic traffic counter speed survey taken on Woodford Bridge Road;
• the existing tree belt along the site frontage and main St Swithin’s Farm feature building can be retained, whilst also achieving the required visibility splays;
• the proposed access point has been modelled on the basis of measured background peak traffic flows and up to 120 dwellings, and the junction performed well within capacity in both the morning and evening peak hours, with no queuing modelled;
• the internal arrangement of a loop road should negate the need for a second point of access for a development of this size; and
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• the proposed 6m access roads, 6m radii and minimum centreline radius of 13.6m is adequate for a maximum size refuse vehicle to enter and exit the site in a forward gear as demonstrated on SK02 attached.
I trust this summary will provide the required evidence to inform a masterplan of the site, if you require any further information please do not hesitate to contact me.
Yours sincerely,
Stephen Adams
Encl: SK01 Access Arrangement and Visibility Splays Rev A SK02 Swept Path Analysis Rev A