Wandsworth Local Development Framework
DMPD & SSAD Proposed Submission Statement of Consultation
(Committee version)
April 2011 DMPD & SSAD Proposed Submission Statement of Consultation
DMPD & SSAD Proposed Submission Consultation Report
1 Introduction 3 2 Consultation Undertaken – who was invited to comment and how they were invited to comment 4 3 Representations and Council's response 7 Development Management Policies Document 7 General comments on DMPD as a whole 7 Chapter 2 – Sustainable Development Principles 9 Chapter 3 – Housing 22 Chapter 4 – Town Centres and Shopping 32 Chapter 5 – Industry, Employment and Waste 41 Chapter 6 – Open Space, the Natural Environment and the Riverside 46 Chapter 7 – Community Facilities 50 Chapter 8 – Transport 51 Appendices 54 Site Specific Allocations Document 56 General Comments on the SSAD as a whole 56 Introduction 58 Chapter 2 - Nine Elms 59 Chapter 3 - Central Wandsworth and the Wandle Delta 75 Chapter 4 - Clapham Junction 83 Chapter 5 - Tooting 87 Chapter 6 - Putney 88 Chapter 7 - Balham 99 Chapter 8 - Roehampton 99 Chapter 9 - Other sites 101 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 10 - Other Thames Riverside sites 102 Appendices 104 4 Next steps 106 DMPD & SSAD Proposed Submission Statement of Consultation
1 Introduction
1.1 The Planning and Compulsory Purchase Act 2004 introduced a new system of development plans, requiring the Council’s Unitary Development Plan (2003) to be replaced by a series of documents within the new Local Development Framework (LDF). The first stage is the production of the Core Strategy which sets out the Council's spatial vision, strategic objectives and spatial strategy on how the borough should develop over the next fifteen years along with core policies and information on monitoring and implementation.
1.2 The Core Strategy was submitted to the Secretary of State on 20th March 2009. Following an exploratory meting, the Inspector held Examination Public Hearing Sessions in February 2010. The Inspector's report was received in June 2010 which found the Core Strategy sound. The Core Strategy was adopted by Council 20th October 2010.
1.3 The next stage in the development of the LDF is the preparation of the Development Management Policies and Site Specific Allocations Documents. The Development Management Policies Document (DMPD) supports the Core Strategy and London Plan by setting out the Council's detailed policies for managing development in the borough. The Site Specific Allocations Document (SSAD) sets out the main sites where development or other change is anticipated in the borough, or where the Council has particular objectives or is supporting or promoting specific proposals to help deliver the Core Strategy.
1.4 Initial consultations on a draft SSAD (issues and options) took place at the same time as the draft Core Strategy in 2006. Detail on the results of this consultation exercise is contained in the report ‘Core Strategy Issues and Options – Summary of Consultation' (June 2006).
1.5 The Preferred Options version of the SSAD and DMPD were open for comment during the consultation period from 11th December 2009 to 16th February 2010. The consultation was initially planned to close on the 5th February, which allowed 8 weeks rather than the statutory 6 week requirement, to take account of the Christmas period. The consultation period was then extended from the 5th February to the 16th February, to allow people more time to respond, and to align with the end of the Core Strategy hearing sessions. A summary of issues raised through this consultation and how they were dealt with, was provided in the Preferred Options Statement of Consultation.
1.6 The Proposed Submission versions of the SSAD and DMPD were published for representations relating to issues of soundness from 29th October to 10th December 2010. This report describes the consultation that was undertaken during this period, provides a summary of responses received, and the Council’s responses to these comments.
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2 Consultation Undertaken – who was invited to comment and how they were invited to comment
2.1 Generic letter to consultation database: The Planning Service maintain a database of statutory and non-statutory consultees. The list of statutory consultees, and the letter sent to them, is contained in Appendix 1. The list of non-statutory consultees, and the letter they received, is contained in Appendix 2.
2.2 Targeted letters: Core Strategy Policy PL7 – Land for Industry and Waste, states that the SSAD will ultimately identify land to be safeguarded for waste management purposes. At preferred options stage a number of sites were identified for consultation purposes, with the intention of undertaking further detailed analysis to allocate suitable sites following the consultation period. Letters were sent to all land owners/occupiers of these sites. At proposed submission stage, further work was carried out in the Council's Waste Site Selection evidence base document. This resulted in the allocation of seven waste sites. Landowners of allocated sites were sent a letter, offering a meeting with Council officers to explain the implications and process from here. Landowners/occupiers of sites that were identified at preferred options stage, but not allocated at proposed submission stage, were also sent a letter advising them of the updated position. A copy of the letters and lists of recipients are contained in Appendix 3.
2.3 The preferred options version of the Site Specific Allocations Document proposed to allocate the Garratt Mill site at Trewint Street, for an additional Gypsy and Traveller site to meet need for additional pitches identified in the London Plan. The Mayor has indicated in a statement for the Draft Replacement London Plan (DRLP) that he proposes to replace policies on Gypsy and Traveller provision and associated targets with a different policy approach to enable boroughs to address their requirements most effectively in light of local circumstances.
2.4 The Core Strategy contains a commitment to review the borough's housing target and affordable housing target in light of changes to housing figures in the London Plan. The allocation of the Garratt Mills site for Gypsy and Traveller provision has been removed and the borough's allocation of Gypsy and Traveller site(s) will be reviewed through the Core Strategy review of overall housing requirements, to align with any changes in the published London Plan. Further work will be undertaken at that time to review need and to justify any site allocation. A copy of the letter sent to the owner/occupier of the Garratt Mills site providing an update of the current position is contained in Appendix 4.
2.5 Brightside Advertisement: A full page advertisement on the LDF was published in the November edition of Brightside, the Council's newspaper, which included half a page for the adoption of the Core Strategy and half a page advertising consultation on the DMPD and SSAD. A copy of the advertisement is contained in Appendix 5.
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2.6 Statutory Notice in Wandsworth Guardian: A Statutory Notice was placed in the Wandsworth Guardian on 28th October 2010. A copy of the notice is contained in Appendix 6.
2.7 Presentations/Meetings: A letter was sent to the Putney, Wandsworth, Battersea and Balham Socities, Clapham Junction Action Group and the Tooting Local History Group offering to meet with the groups and explain the DMPD and SSAD documents and process related to the consultation. Clapham Junction Action Group chose to send in a series of questions for the planning service to respond to, rather than attend a meeting. The meeting was not taken up by the Balham Society. Officers within the planning department attended the following meetings and either gave a presentation on the documents and the implications most relevant to each group or conducted a round table discussion of issues.
2.8 The Putney Society: The Putney Society is the local amenity society for Putney and Roehampton. The society arranged a special members meeting specifically to discuss the consultation on the SSAD and the DMPD on 30th November 2010 which was held in the Brewer Building, Putney High Street. The meeting was attended by approximately 70 members of the society. Following a presentation from Council officers there was a question and answer session which continued for around an hour. The majority of questions related to tall buildings.
2.9 Battersea Society: A meeting was held on the 19th November 2010 at the Town Hall, where a round table discussion of issues took place and a number of questions where answered.
2.10 Wandsworth Society: A meeting was held on the 26th November 2010 at the Town Hall in a similar format to the Battersea Society meeting.
2.11 Tooting Local History Group: The Tooting Local History Group is a local amenity society made up of voluntary members of the community. An officer attended a meting of the group on 2nd November 2010 at the Progressive Club, Mitcham Road. Following a short presentation, a lively question and answer session followed.
2.12 Clapham Junction Town Centre Partnership: The Clapham Junction Town Centre Partnership Board is made up of representatives from the business community in Clapham Junction including the Chamber of Commerce, Battersea Arts Centre and the Metropolitan Police. It includes business representatives from the Northcote Road Business Network, St John’s Hill Business Association and Lavender Hill Traders’ Association. The Partnership prepares an Annual Business Plan in collaboration with the local representatives with a view to improving the economic well-being of the town centre as well as the quality of new development and enhancing the quality of the public realm of the shopping streets. The Local Development Framework featured on the agenda of the Partnership Board meeting held on 2nd December 2010. An officer
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from the Planning Service attended these meetings and presented the SSAD and the DMPD for discussion, most notably as they affect Clapham Junction town centre. Representatives were invited to make comments on the documents.
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3 Representations and Council's response
Development Management Policies Document
3.1 The following section outlines the representations received in relation to the DMPD and the Council's response.
General comments on DMPD as a whole
3.2 A number of introductory statements providing background to representations have been registered against the whole of the document, however for the purposes of this report, only those representations that relate to the content of the documents or the LDF/consultation process are addressed. General support for the document was received from several parties including Natural England, Minerva, English Heritage and Greater London Authority, who have no conformity issues with the DMPD, but point out matters of clarification. The Coal Authority and the Highways Agency have confirmed they have no comments to make on the document at this stage.
3.3 Issues with the consultation undertaken, LDF process and online consultation software were raised by a number of residents and the Putney Society. The Council acknowledge that a large amount of material is produced as part of the Local Development Framework process and that this has the potential to create barriers to participation. However we are working within a statutory process which requires the preparation of a vast amount of technical evidence based material to support the development plan for the borough in order for it to be found sound by the Planning Inspectorate. This is why every endeavour is made to enhance participation, by holding meetings and giving presentations with amenity groups, landowners and developers, along with the circulation of public notices and advertisements described in the previous section.
3.4 The Health and Safety Executive made the same requests as at preferred options stage, relating to Hazardous Installations, which were addressed in the proposed submission version of the document.
3.5 Real Estate Opportunities suggest reference is made to the relationship between the DMPD and the draft replacement London Plan in the introduction to the document. This change has been made.
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Development Management Policies Document
Representor Representor reference Representation Soundness test number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Mrs Patricia Poulter 396982 2 Not specified
Health and Safety Executive 1299 22 Not specified
Suzanne Constanti-Taylor 490768 40 Not specified
James Taylor 490769 43 Not specified
Mrs Isabel Wooller 204045 46 Not specified
Highways Agency 223757 80 Not specified
Putney Society 802 81 1, 2
Natural England 1240 162 Sound
Greater London Authority 1407 240 Sound
English Heritage 1415 233 Sound
Minerva 40433 164 Sound
Coal Authority 169659 1 Not specified
BP and M Adams 404083 252 Not specified
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Chapter 2 – Sustainable Development Principles
General development principles - Sustainable urban design and the quality of the environment (DMS1)
3.6 NHS Wandsworth request a minor change in relation to the assessment of social infrastructure capacity in clause e which has been accepted as it is considered to enhance clarity of the policy. Several minor wording changes were requested by residents and residents' groups, which largely requested reversion to the preferred options wording (Patricia Poulter, Isabel Wooller, CR Atkins, Clapham Junction Action Group). DMS1a is opposed as it makes reference to optimising the potential of sites and this is considered to encourage over-development of sites. This policy criterion has been retained as it is taken directly from the sustainability criteria set out in Policy 2A.1 of the London Plan and is considered important in ensuring the best use is made of previously developed land in accordance with PPS3 and the London Plan, however further clarification has been provided in the context (para 2.3) to clarify that this needs to be appropriate to the local context and take into account the London Plan density matrix. DMS1d is opposed as the requirement to justify and mitigate any impact on natural features, open spaces and strategic views has been removed. Preferred options versions of Policy DMS1h and i were seen to have a degree of duplication in that they both related to impacts on natural features/landscape features. These clauses were merged into Proposed Submission version of Policy DMS1d. It is acknowledged that the policy now lacks the need to justify impacts where they do occur, but it is considered that only having to justify impacts, rather than seek to reduce them, does not go far enough either. Therefore, the Council has amended DMS1d to require any impacts on natural features, open spaces and strategic views to be avoided, remedied or mitigated.
3.7 Removal of Preferred Options para 2.2 from the Proposed Submission version is opposed as it is considered that local distinctiveness should be addressed in the document. The paragraph was removed as it was felt that this was already adequately covered by the Core Strategy, however reference to the importance of local distinctiveness has now been included in the submission version. Paragraph 2.3 is opposed on the basis that reference to new developments being expected to achieve improvements to the public realm and reflect the character of the site and its wider environment has been removed. Reference to these elements have in fact been retained. In relation to paragraph 2.4, Mrs Poulter and Isabel Wooller request extension of the consideration of impacts of mixed-use developments on residential amenity and safety. This is accepted and the final sentence of para 2.4 has been amended to reflect this. Amendments to paragraph 2.6 are requested to ensure that applicants are required to demonstrate their development would not overload existing infrastructure. The wording already requires this, and no changes are considered necessary.
3.8 Thames Water consider the policy does not adequately address water and sewerage infrastructure and para 2.6 has been amended to list the types of utility infrastructure which are covered by the policy to avoid any confusion. Workspace Group
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find the policy to be too prescriptive and repetitious. An exercise of reducing repetition in policies was undertaken at Proposed Submission stage, and the Council considered that DMS1 now provides a sound policy covering all the necessary general policy considerations, without being overly repetitious. UK Power Networks request reference to the operational requirements of businesses, however this is already contained in clause k of the policy.
3.9 Additional minor changes have been made in response to internal comments from Development Control officers where issues have been identified through implementation. An additional clause has been added to the policy regarding developments involving hazardous substances or processes. The Proposed Submission version included a paragraph on this in the context, but it is considered that a specific policy clause is also required to ensure that the safety of residents, users of the site and the environment are maintained. A clause regarding the avoidance and removal of street clutter has been included in response to the Government's move to reduce street clutter to enhance the safety and amenity value of London's streets.
The historic environment (DMS2)
3.10 English Heritage and National Grid are generally supportive of the policy. Sutherland Grove Residents Association request clarification of which policies should be complied with to allow demolition of heritage assets. No changes have been made as Policy DMS2c clearly refers to the relevant PPS5 policies. Mrs Poulter and Mrs Wooller request the policy extend to any building, monument, site, area or landscape that is proposed for inclusion as a designated or undesignated heritage asset. This change is not considered necessary as the context to DMS2 (para 2.28) lists the heritage assets that are covered by the policy, and includes "Any other building, monument, site, place, area or landscape positively identified as having a degree of significant warranting consideration in planning decisions (undesignated HA)". This would allow for the policies to apply to any building or area proposed for listing or local listing, where it is considered to have met this test.
Sustainable design and low-carbon energy (DMS3)
3.11 National Grid Property consider that as currently worded, development could be compromised or prevented from coming forward if a district-wide heating and cooling network is not in place. Greater flexibility in the policy is requested to acknowledge that for some developments, particularly smaller developments, this will not be technically or economically feasible. The policy has been amended to take into account the technical feasibility and economic viability of creating new heat networks. Schemes that come forward in the early phases of redevelopment in an area with potential for heat networks need not be delayed if a network has not yet been developed. However it is important for the development of efficient heat networks that schemes are designed to allow
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connection to networks in the future. UK Power Networks (EDF Energy) request that a definition of 'minor development' is set out to make information requirements clear. Further clarity has been provided.
3.12 Mrs Patricia Poulter and Mrs Isabel Wooller state that developer contributions should not be used to compensate for pollution. The text of the document has been amended to signpost Core Strategy Policy IS4 (Protecting and enhancing environmental quality) and to refer to the potential of a future low emissions SPD to be produced in conjunction with Environmental Services. Port of London Authority support the policy in principle, but consider that it does not go far enough towards encouraging the use of the river for the transportation of construction and waste materials to and from development sites. This is already covered by Core Strategy Policy IS1b, and it is not considered necessary to repeat here. Sutherland Grove and Area Residents' Association request an indication of how the tension between energy conservation and historic heritage conservation might be resolved. It is not considered appropriate to set this approach out in detail as cases will need to be assessed individually, however, this part of the text has been expanded with reference to guidance produced by English Heritage. REO (Powerstation) Ltd request reference to the requirement for a preliminary assessment rather than a pre-assessment estimator, in part a of the policy. This has been amended to refer to a 'preliminary assessment report'.
3.13 The interim sustainability checklist produced by the Council was originally intended to be replaced by an SPD. Given the success of the checklist in providing succinct guidance and the availability of other guidance on this topic, it is no longer considered necessary to produce a dedicated SPD. The text has been amended accordingly. As funding for Heat Mapping work under the Decentralised Energy Masterplanning Programme (DEMaP) is no longer being provided, the text has been altered to remove the commitment to produce a detailed heat map for Wandsworth. Reference to the London Heat Map has been retained as some local information is already available and detailed mapping may still be performed if alternative methods or funding sources are identified. As the Draft Replacement London Plan is likely to remove the 20% renewables target and replace this with a higher overall CO2 reduction target, the text has been amended to re-affirm that total CO2 emission reductions will be considered, with the 20% renewables target remaining as an aspiration.
Tall buildings (DMS4)
3.14 Core Strategy Policy IS3 identifies town centres, focal points of activity and Nine Elms near Vauxhall as locations where tall buildings may be appropriate. Outside these areas, tall buildings are likely to be considered inappropriate. The Preferred Options DMPD and SSAD went into further detail for the town centres, focal points and Nine Elms near Vauxhall, identifying for sites and areas, the height at which a building will be considered tall, and the height above which buildings are unlikely to be considered acceptable. The was based on work carried out in the Council's Stage 2 Urban Design Study - Tall Buildings (S2UDS). In the Proposed Submission versions of the DMPD and
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SSAD the upper heights were removed as it was felt that the evidence base to support this was not sufficiently robust. It was also clear that developers were seeing the heights as starting points, rather than likely upper limits and there was much opposition to the actual heights from Putney residents. The Council considered the most robust assessment of tall buildings to be the retention of the definition of what is regarded as a 'tall building' in different locations, which would trigger assessment of tall buildings against the detailed criteria Policy DMS4.
3.15 Opposition from Putney residents remains. Several respondents consider that the removal of the upper heights implies that buildings even taller than this are acceptable (Mrs Patricia Poulter, Suzanne Constanti-Taylor, James Taylor, Mr and Mrs Clive and Gilda Rees, Peter Carpenter, BP and M Adams). This is not accepted. As discussed above, buildings which trigger assessment against DMS4 will be robustly assessed and there is no assumption of any height being automatically acceptable. Peter Carpenter suggests the use of plot ratios, if maximum heights are not going to be implemented. Plot ratios have been used by the Council in the past as a useful tool to determine an appropriate scale of development based on the capacity a site is considered capable of managing. Whilst this indirectly addresses height of buildings relative to undeveloped space on-site, it is not a tool that can be used to directly shape or assess other impacts of tall buildings such as visual impacts. The London Plan Density Matrix is the current method of establishing an appropriate density on a site, taking into account its context and access to public transport, and as is considered to be more effective than plot ratios as a density range is provided rather than a hard and fast ratio to be adhered to.
3.16 Mrs Patricia Poulter, Mrs Isabel Wooller and BP and M Adams submitted the same detailed requests for changes to the policy. Clause v (actually iv) is proposed to be amended so that it requires a 'positive' visual impact rather than an 'acceptable' visual impact. The Preferred Options version of this clause was to "show, through a detailed design analysis, how the proposal visually affects surrounding areas". The implied purpose of providing this design analysis was to enable officers, members and local residents to be able to make an informed assessment on the acceptability of the visual impact of a proposal. It was felt that the way the policy was worded did not make explicit that this was the reason for providing the information, and that one could argue that to simply provide the information would satisfy the criteria. The policy clause was amended to address this at Proposed Submission stage. It is acknowledged that the clause results in a degree of subjectivity, requiring value judgements to be made about whether something is acceptable or not, but a decision has to be taken about whether the visual impact of a proposal is acceptable, weighting up pros and cons and different people's views. Clapham Junction Action Group request reference in this policy clause that the visual representations must accurately represent what would be seen by the human eye. This is accepted, but is considered more appropriate to be within the context to the policy.
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3.17 Clause vii (actually vi) is proposed to be amended to ensure that no unreasonable harm is being caused to existing businesses. This is not accepted as this is already covered in Policy DMS1. Addition of the words "any neighbouring properties" is requested at the end of clause viii (actually vii) , however this is not considered necessary as neighbouring properties would be included as part of 'surrounding development' which the policy already considers. Similarly, addition of the words "from all aspects" is requested at the end of clause x (actually ix), but as this policy criterion relates to consideration of how development sits within the streetscape, the policy consideration here is the impact of development on the streetscene, not from all aspects. It would also not be desirable to have active frontages or legible entrances from all aspects. Clause xi (actually x) is opposed as reference to public spaces adjacent to sites that may not be in the ownership of the developer is considered inappropriate. This is accepted and the policy has been amended to remove reference to the location of public spaces. Clause xiii (actually xii) is opposed as on the basis that security implications of public spaces and increased commercial activity are not considered. As set out in para 4.16 of the S2UDS, a key consideration of a management plan required by this policy is security. Therefore, no changes are considered necessary.
3.18 Mrs Clive and Gilda Rees, and BP and M Adams consider that there is different treatment for residents living within conservation areas to those living outside these areas. The policies and evidence base supporting the policies do contain specific reference to heritage assets including conservation areas and listed buildings, as this is required by Planning Policy Statement 5 - Planning for the Historic Environment. However the criteria in Policy DMS4 requires the impact on all areas, not just conservation areas, to be considered and addressed, so no changes to the policy have been made in response to these representations. Sutherland Grove and Area Residents Association consider that there should be greater protection for residents in conservation areas, however no changes are made to the policy as DMS2 and DMS4 are already considered to adequately address impacts on heritage assets. Mr and Mrs Rees also have concerns about the height/overbearing impact of tall buildings if they are to be set back from Upper Richmond Road to allow active ground floor uses. The buildings along this road already contain deep setbacks from the road frontage, and in any case the impacts on neighbours would be considered as part of DMS4. There is also some concern about management and policing of town centre activities in this location. Policy DMS1 requires developments to be designed in a way that provides a safe and inclusive environment which maximises personal safety and minimises opportunities for crime and antisocial behaviour. Developers and planning officers are advised to contact the Crime Prevention Design Advisor at Wandsworth Borough Police for guidance on Crime Prevention Design principles. If a problem were to arise from the uses coming forward as part of redevelopments along the high street despite efforts to design out crime, this would be managed by the police in the same way such issues are managed elsewhere. The above mentioned parties, as well as Clapham Junction Action Group question why the requirement to respond positively to any characteristic alignment and setback of surrounding buildings was removed between Preferred Options and Proposed
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Submission stage. It is accepted that this was an important part of the policy that should have been retained, and has been reinstated in the Submission version. The removal of clause xiv from the Preferred Options version of the DMPD opposed. This required an applicant to describe how the scale of a building fits within its context. This is considered to be adequately covered by Policy DMS1a and b.
3.19 National Grid Property consider that the majority of the criteria in DMS4 are applicable to all development, do not relate specifically to tall buildings and do not have regard to EH/CABE guidance on tall buildings. Covent Garden Market Authority, Anastasia Limited, Metropolitan Police, Senex Capital Ltd, UK Power Networks Ltd, Sleaford Street Management Company Ltd and REO (Powerstation) Ltd also consider the policy repeats the requirements of other policies. REO Powerstation Ltd suggest alternative wording to avoid duplication and lack of clarity. This is not accepted as an exercise of removing duplication between Policy DMS1 (General Development Principles - Sustainable urban design and the quality of the urban environment) and DMS4 was undertaken at Proposed Submission stage. While some of the criteria in DMS4 have similarities with other policies, such as the assessment on historic environment and transport impacts, these impacts are integral to the assessment of tall buildings, and are explicitly stated here to ensure they are robustly assessed. The S2UDS also relates each of the criteria directly to the EH/CABE criteria, which has now been supported by English Heritage.
3.20 English Heritage welcomes the amended treatment of the historic environment and tall buildings throughout the proposed submission version of the documents and consider that they now combine to provide developers with a clear understanding of the needs of the heritage assets that relate to the development of sites and areas in Wandsworth. Greater London Authority state that the Council should ensure that Policy DMS4 is consistent with the amended text agreed with GLA officers which relates to the Nine Elms Area Spatial Strategy in the SSAD. This representation is address in the SSAD section of this report.
3.21 Mrs Partricia Poulter, the Wandsworth Society, BP and M Adams and Mr and Mrs Clive and Gilda Rees suggest that the definition of storeys should also be qualified in metres. The Stage 2 Urban Design Study describes storeys as an average of 3m. This is based on a middle ground between average residential floor to ceiling heights which are generally 2.5m and average commercial floor to ceiling heights which are generally 3-4m. The 3m assumption has now been referenced in the context to DMS4, along with a requirement for planning applications to express the height of their buildings in storeys and metres. Clarification has also been provided that the ground floor is counted as a storey.
3.22 Threadneedle Property Investments and Prices Securities Ltd consider that it is inappropriate to refer to the S2UDS with any suggestion that it will be important in development control decision making. Reference is only made to the S2UDS as a background evidence base document, the same way in which other evidence base documents are referred to in the Core Strategy and DMPD, for example the DTZ
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Employment Land and Premises Study or the Retail Needs Assessment. These documents can provide important background information which can assist development control decisions and reference is therefore retained, however it is not proposed that the document take the status of a Supplementary Planning Document.
3.23 Several respondents point out that reference to Appendix 1 in the policy should be Appendix 2 (Threadneedle Property Investments and Prices Securities Ltd, Royal Mail Group Ltd, Metropolitan Police Service). This has been corrected.
3.24 The Wandsworth Society oppose town centre boundary adjustments on that basis that these have been made to allow tall buildings. The Council response to these representations is contained in the 'Appendices' section of this report. The Wandsworth Society also consider that there is no logical reason why tall buildings should be associated with commercial success or regeneration, and request the Council to provide evidence that this is the case. The Council's overall spatial approach to tall buildings, being that they 'may be appropriate' in town centres, focal points of activity and Nine Elms near Vauxhall is established in the Core Strategy and cannot be challenged here. Identifying the relationship between tall buildings and regeneration is not Wandsworth specific. The EH/CABE guidance says at para 1.1 that "Cities and their skylines evolve. In the right place, tall buildings can make a positive contribution to city life...Individually, or in groups, they affect the image and identity of a city as a whole. In the right place they can serve as beacons of regeneration, and stimulate further investment."
3.25 Several respondents oppose the identification of Nine Elms (outside the Battersea Power Station focal point and Nine Elms near Vauxhall) as an area where tall buildings are likely to be inappropriate (refer SSAD representations). Core Strategy Policy IS3d makes it clear that outside town centres, focal points and Nine Elms near Vauxhall, tall buildings are likely to be inappropriate. There is therefore no scope to consider this area as potentially 'suitable' for tall buildings. This does not mean to say that no tall buildings will be accepted, but they have a stronger argument to make in terms of meeting the criteria in DMS4. The height at which buildings are considered tall in this location was raised at Proposed Submission stage to 11 storeys to align with the Vauxhall Nine Elms Battersea Opportunity Area Planning Framework (VNEB OAPF) which states that buildings will be an average of 8-10 storeys.
3.26 Anastasia Limited consider that the 11 storey height at which buildings are considered tall in VNEB is not backed up by evidence and is at odds with Core Strategy Policy IS3d. Senex Capital Ltd make similar comments in relation to 9 storeys throughout the Thames Policy Area. The arguments in both cases rely on taller buildings in very close proximity to the sites, and do not take account of the wider context which has formed the assessment set out in the S2UDS. In response to Anastasia's representation, one building of 13 storeys in height to the north of the Marco Polo site does not constitute the 'prevailing height' of surrounding buildings. Similarly, in response to Senex Capital's representation, two buildings of 15 and 7 storeys near 110 York Road do not justify a 'prevailing height' of 12 storeys.
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3.27 Barton Wilmore consider that the policy relating to the Thames Policy Area would mean that reserved matters applications for the Battersea Reach site would technically be a departure from policy. This is not the case. If the principle of building height has already been established through an outline permission, reserved matters applications would not be subject to DMPD Policy DMS4 (depending on the matters that have been reserved). Barton Wilmore also consider that defining the height at which buildings are considered tall is at odds with the Core Strategy. This view is shared by REO (Powerstation) Ltd, Senex Capital Ltd and Anastasia Ltd. St James Group object to the approach of the policy overall, stating that building heights should be judged on a site by site basis rather than identifying areas as potentially appropriate or inappropriate for tall buildings. The adopted Core Strategy policy contains the statement that "the height at which buildings will be considered 'tall' on individual sites will be contained in the Development Management Policies Document". The principle of providing further detail on heights in a supporting DPD has therefore been accepted as an appropriate approach by the Core Strategy Inspector.
3.28 Workspace Group Plc and UK Power Networks (EDF Energy) are supportive of the policy overall, but have objections to specific heights which are addressed through the consultation summary of the SSAD.
3.29 Stargas Nominees consider that they should be considered part of Area B - Thames Policy Area, rather than Area D - Remainder of borough. This is accepted as the site should form part of the Thames Policy Area given its location just north of the railway. The Proposals Map and site information have been updated accordingly.
Flood risk management (DMS5)
3.30 Anastasia Limited welcome the changes that have been made at the proposed submission stage, but consider they do not go far enough in terms of meeting the requirements of PPS25. Anastasia Limited request the Council undertake an exception test for all sites allocated for proposed development in the SSAD and that DMS5 is amended to remove the requirement for the applicant to undertake an exceptions test on these sites. The Council's approach to the exceptions test is for it to be carried out at the planning application stage by the applicant as part of a Flood Risk Assessment. The reason for this approach is that specific flood risk information regarding the requirements of the exceptions test is regularly updated by the Environment Agency and the most up to date information should be used when applying the exceptions test. To assist applicants the Council have produced a Strategic Flood Risk Assessment and a Sequential Test report in which exception test supporting information is provided.
3.31 Sutherland Grove and Area Residents' Association consider the policy is confusing and unhelpful and would support a policy whereby all development should ensure that at least 50% of front and rear gardens is always left in soft landscaping for drainage purposes. Further detail is provided in Policy DMH5 to say that front gardens will remain completely free of buildings and structures apart from when lightwells are
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proposed and 50% of the front garden will remain. The GPDO allows for hard surfaces as long as they are porous or they direct water run-off to a permeable or porous area or surface within the curtilage of a dwellinghouse.
3.32 Thames Water supports the aims of Policy DMS5 but object to the wording in Table 2.2 requiring the redevelopment of existing developed sites to result in an overall net flood risk reduction within Flood Zone 3b. Thames Water consider that such onerous flood risk management policies for Flood Zone 3b means that the essential utility infrastructure of the Thames Tunnel may not be compatible and subsequently the development may not deliver Core Strategy Policy IS6.
3.33 The Council's approach is to restrict development within Flood Zone 3b and where possible reduce existing risk. This has been supported by the Environment Agency. To clarify, the Council is supportive of water compatible development and essential infrastructure in Flood Zone 3b so for clarification and to address Thames Water's concerns the wording has been amended to state that the overall net reduction in flood risk does not apply to water compatible development or essential infrastructure.
3.34 As a result of testing planning applications against the Proposed Submission version of the policy the approach to basement accommodation within Flood Zone 3b has been changed. Basements may be acceptable in Flood Zone 3b unless they are self-contained, involve a conversion to a higher vulnerability classification or are providing habitable rooms. In all cases the policy criteria must be met to be considered acceptable. The text has been amended to reflect this in Policy DMS5.
Sustainable drainage systems (DMS6)
3.35 Sutherland Grove and Area Residents' Association make the same comments as those that relate to DMS5. The same response applies. St James Group consider the SUDS measures for a site should only be required to achieve no greater than existing flows. The SUDS measures have been set in accordance with the Mayor's preferred standard identified in the sustainable design and construction SPG which is in accordance with the London Plan Policy 4.A.14 Sustainable Drainage. This approach is supported by the Environment Agency.
3.36 St James Group also oppose part b of the policy, stating that if on-site SUDS are provided no contributions should be required. Part b of the policy merely identifies that where appropriate, contributions will be sought, and flags up that the details of these requirements will be set out in a forthcoming SPD/CIL charging schedule. On site provision of SUDS would be taken into account in calculating any contribution to be made, however this level of detail will be provided in the SPD/CIL schedule and it is not considered necessary to be set out in policy.
17 DMPD & SSAD Proposed Submission Statement of Consultation
Consultation with the Environment Agency (DMS7)
Sutherland Grove and Area Residents' Association consider the policy should provide different policies for consideration areas. This is not considered necessary as whether or not a property is in a conservation area has no bearing on flood risk management, or the need to consult with the Environment Agency.
Advertisements (DMS8)
3.37 Sutherland Grove and Area Residents' Association request a specific policy relating to the historic environment. No changes have been made as DMS2 adequately covers heritage assets including conservation areas, and is PPS5 compliant.
Telecommunications (DMS9)
3.38 The Mobile Operators Association welcome the inclusion of Policy DMS9. Patricia Poulter and Isabel Wooller request amendments to the policy to consider amenity and health considerations as well as potential impact of development on telecommunications reception. As these are all considerations of PPG8 to which the policy refers, no changes have been made.
Chapter 2 - Sustainable Development Principles
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with national policy
DMS1 - General development principles - Sustainable urban design and the quality of the environment
NHS Wandsworth 152395 192 Sound.
Patricia Poulter 396982 4 & 8 Not specified
Thames Water 233792 34 I, 3
Isabel Wooller 204045 47 Not specified
Clapham Junction Action Group 364229 78 Not specified
Workspace Group Plc 397170 93 2, 3
Sutherland Grove and Area Residents' 491359 109 Not specified Association
18 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 2 - Sustainable Development Principles
CR Atkins 404674 123 Not specified
UK Power Networks (EDF Energy) 1326 179 Not specified
Addition Land and Network Rail 222140 237 1
DMS2 - Managing the historic environment
National Grid Property 234008 65 Supportive
English Heritage 1415 72 Supportive
Mrs Patricia Poulter 396982 9 Not specified
Mrs Isabel Wooller 204045 48 Not specified
Sutherland Grove and Area Residents' 491359 110 Not specified Association
DMS3 - Sustainable design and low carbon energy
National Grid Property 234008 66 Not specified
Mrs Patricia Poulter 396982 10 Not specified
Port of London Authority 1405 23 1, 3
Mrs Isabel Wooller 204045 49 Not specified
Sutherland Grove and Area Residents' 491359 111 Not specified Association
UK Power Networks (EDF Energy) 1326 180 Not specified
REO (Powerstation )Ltd 49810 203 Not specified
Greater London Authority 1407 247 Not specified
DMS4 - Tall buildings
Mrs Patricia Poulter (2) 396982 3 & 11 Not specified
Suzanne Constanti-Taylor 490768 41 Not specified
Mr James Taylor 490769 44 Not specified
Mrs Isabel Wooller 204045 50 Not specified
National Grid Property 234008 67 Not specified
Clapham Junction Action Group 364229 79 Not specified
Royal Mail Group 494648 156 1, 3
Wandsworth Society 847 163 1
19 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 2 - Sustainable Development Principles
Mr and Mrs Clive and Gilda Rees 403058 170 Not specified
Threadneedle Property Investment 495034 173 Not specified and Prices Securities Ltd
Barton Willmore (2) 491197 82 & 83 1, 2
Covent Garden Market Authority 491216 84 2
Workspace Group Plc 397170 94 1, 2, 3
Sutherland Grove and Area Residents' 491359 112 Not specified Association
Mr Peter Carpenter 491438 125 2
Anastasia Limited 38522 137 1
Metropolitan Police 220011 143 1, 2
Senex Capital Ltd 1471 161 1, 3
UK Power Networks (EDF Energy) 1326 181 Not specified
Ballymore Group 366691 196 1, 3
Sleaford Street Management 401115 204 1, 2 Company
REO (Powerstation) Ltd 49810 205 Not specified
St James Group 495333 222 Not specified
Greater London Authority 1407 248 Not specified
Stargas Nominees Limited 404263 232 Not specified
BP and M Adams 404083 249 Not specified
English Heritage 1415 73 Not specified
DMS5 - Flood risk management
Thames Water 233792 39 Not specified
Sutherland Grove and Area Residents' 491359 113 Not specified Association
Anastasia Limited 38522 138 3
DMS6 - Sustainable Drainage Systems
Sutherland Grove and Area Residents' 491359 114 Not specified Association
20 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 2 - Sustainable Development Principles
St James Group 495333 223 Not specified
DMS7 - Consultation with the Environment Agency
Sutherland Grove and Area Residents' 491359 115 Not specified Association
DMS8 - Advertisements
Sutherland Grove and Area Residents' 491359 116 Not specified Association
DMS9 - Telecommunications
Mrs Isabel Wooller 204045 51 Not specified
Mobile Operators Association 1055 154 Supportive
Mrs Patricia Poulter 396982 12 Not specified
Sutherland Grove and Area Residents' 491359 118 Association
21 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 3 – Housing
Protection of residential land and buildings (DMH1)
3.39 Sutherland Grove and Area Residents' Association strongly support the policy of maintaining the range of dwelling sized available within the existing stock, particularly family sized housing with gardens, but request tighter policy within conservation areas. It is considered that the protection of family sized dwellings is a borough wide issue, and there is no basis for a different policy within conservation areas. If a management plan for a specific conservation area finds that the area is characterised by larger dwellings, this would be taken into account in assessing development proposals in the area. Greater London Authority broadly support the policy approach but consider additional signposting and clarity would strengthen the overall approach. In particular, a fourth criteria is recommended to make it clear that the loss of smaller affordable housing units for larger family private market units would not be acceptable. This change has been made as although the loss of affordable housing units would be contrary to Core Strategy Policy IS5, this enhances the clarity of the policy overall.
Conversions (DMH2)
3.40 Sutherland Grove and Area Residents' Association recommend there is a complete ban on conversions applied to conservation areas. This is not accepted as the occupation of a building does not usually have a significant impact on the appearance of a building, character of an area in terms of appearance, or on the street scene. Conversions also play an important role in increasing the number and variety of dwellings in the borough. It is important that conversions are well managed so that the gain of additional dwellings is not achieved at the expense of family sized accommodation. This is what the policy aims to achieve.
Unit mix in new housing (DMH3)
3.41 The policy is broadly supported by National Grid Property, Royal Mail Group, Minerva, UK Power Networks (EDF Energy) and Greater London Authority, particularly part d which provides flexibility in light of individual site circumstances.
3.42 Covent Garden Market Authority are generally supportive of the policy but request the policy is amended to recognise the impact contributions in the Nine Elms area could have on viability of schemes. This change is not considered necessary as the policy already states in part d that the policy will be applied flexibly to take account of viability. As the rest of the borough will also be subject to a tariff based charge when a Community Infrastructure Levy is in place, it is not considered necessary to single out Nine Elms in this policy. Workspace also generally support the policy but oppose the limit on the maximum proportion of 1-bedroom market accommodation. The policy is considered to be overly prescriptive by REO (Powerstation) Ltd, St James Group, Ballymore Group. Ballymore Group also oppose the maximum proportion of 1-bedroom
22 DMPD & SSAD Proposed Submission Statement of Consultation
market accommodation and question the evidence base to support this. The Council looked at examples of small studio units provided in recently completed new developments, but considered that these provided a poor standard of living accommodation which could lead to them being occupied by a transient population, perhaps only on certain days of the week. The impact may be of particular concern in Nine Elms where the significant numbers of new homes achievable could potentially give rise to high numbers of studio units that would not contribute to the “sense of place” that the Council wishes to see created in this location. The 2010 Housing Market Assessment update (HMA) incorporates a commentary on the local market for 1 person accommodation. Given the marked slowdown in new housing starts over the past year, it highlights the need to consider alternative approaches to meeting housing need other than through new development. There continues to be a high demand for one bedroom accommodation in all tenures; however the full HMA undertaken in 2008 noted the risk that any new build targets based solely on such analysis would perpetuate existing problems. The lack of remaining low cost family accommodation limits scope for families to move to larger homes as they grow, effectively forcing families who might otherwise have moved within Wandsworth to relocate outside the borough. To ensure that all new homes in Wandsworth contribute to mixed and balanced communities as required by PPS3 and the London Plan, Policy DMH3 was revised in the Proposed Submission version to further control this type of housing.
3.43 Peter Carpenter considers that the target for intermediate family sized accommodation is inadequate to meet the projected distribution of family units and the targets set out in the London Plan. No changes are considered necessary as Greater London Authority have made a formal representation that the policy remains sufficiently flexible to implement the Core Strategy and London Plan objectives to provide a range of unit sizes. The London Housing Strategy (2008-11) identifies a London-wide target for intermediate and social rented family housing, but acknowledges that there will be local variations. Wandsworth's borough-level evidence of need for family accommodation by tenure is based on the Housing Market Assessment and updates. The DMPD identifies that the borough-level proportions set out in DMH3a are indicative, and will be subject to review throughout the lifetime of the Plan. Given the Council's evidence base in the HMA and the GLA's support, no changes to the policy are justified here.
Residential development including conversions (DMH4)
3.44 Port of London Authority request that paragraph 3.13 (now para 3.16) is amended to more closely reflect the requirements of the London Plan. This change has been made and it is now clear that development next to or opposite safeguarded wharves should be designed to minimise the potential for conflicts of use and disturbance. Covent Garden Market Authority request flexibility in part axii of the policy for large mixed use urban schemes, such as that proposed on the Northern site of Covent Garden Market. No justification has been provided as to why larger schemes should be treated differently and this change is not accepted as it is considered particularly important for larger schemes to comply with Lifetime Homes criteria.
23 DMPD & SSAD Proposed Submission Statement of Consultation
Workspace Group Plc and UK Power Networks (EDF Energy) request greater flexibility in the policy overall and REO (Powerstation) Ltd request greater flexibility in the application of the London Plan Density Matrix. Greater flexibility in either case is not considered necessary as Core Strategy Policy IS3 sets out the principles on scale and density in the borough including application of the London Plan density matrix, and Policy DMH4 states that it will take into account the matrix but does not imply that it will be rigidly adhered to. The policy aims to achieve a high standard of residential quality and further flexibility is not likely to achieve high quality sustainable outcomes.
Alterations and extensions (DMH5)
3.45 Sutherland Grove and Area Residents' Association are supportive of the policy. Mrs Isabel Wooller considers part vii which relates to hardstandings, should not emphasise the importance of conservation areas, as this is of borough wide importance. The statutory basis of conservation areas is that they are of special architectural or historical merit and decision makers are required to ensure that any decision will preserve or enhance the conservation area. The Council considers that the effect of hardstandings on properties in conservation areas is almost always more significant in conservation areas than it is generally and all the Council's Conservation Area management strategies advise against hardstandings. Control over hardstandings in conservation areas can be said to be covered by DMS 2 b.iii). It is agreed that the policy wording should not give the impression that control over hardstandings is only important in conservation areas, and inclusion of the word “particularly” in this part of the policy already makes this distinction sufficiently, however reference to the Council's Conservation Area Management Strategies has been added to the text for clarification.
Residential space standards (DMH6)
3.46 National Grid Property and Mr Peter Carpenter consider the space standards should relate to those set out in the Draft Replacement London Plan. Greater flexibility in application of the standards is sought by Workspace Group PLc, Covent Garden Market Authority, Royal Mail Group, Minerva and REO (Powerstation) Ltd. The evidence base to support this approach is also questioned by Minerva and REO (Powerstation) Ltd. The context to DMH6 explains the evidence base to support the Council's approach. In summary the standards are based on the Council's Housing SPG (which was based on Parker Morris standards). The implementation of the standards has been tested through the Council's New Housing Survey 2004 and re-survey 2007 which found that 91% of respondents on private developments and 68% of respondents in housing association developments were satisfied with their home. Reflecting the responses to the survey the Council has retained these standards with an additional allowance for storage space. These standards are therefore considered to be justified and effective for Wandsworth. The one exception is the standard for studios which has been increased from 35 to 38 sq ms to better align with the draft Replacement London Plan and ensure a higher quality of smaller dwellings in the borough. The 2007 New Housing Survey also recorded low levels of satisfaction with studio units, which the shift in policy aims
24 DMPD & SSAD Proposed Submission Statement of Consultation
to address. St James consider that space standards should apply to affordable housing only and then be applied flexibly. Greater London Authority support the standards in the policy. Currently grant funded affordable housing must comply with the minimum standards set by the Homes and Communities Agency. Occupiers of all forms of affordable or social housing do not have the choice that occupiers of market housing do, therefore it is important that all affordable housing is of a suitable standard to meet current and future occupancy needs.
Residential gardens and amenity space (DMH7)
3.47 Mrs Patricia Poulter, BP and M Adams and Mrs Isabel Wooller consider that it is unclear how, in the case of tall buildings, the inclusion of residential gardens and balconies in particular, can respect the privacy of existing residents. No changes to the policy are made as Policy DMS1 requires overlooking and privacy to be taken into account.
3.48 The requirement for 40 sq ms amenity space for family accommodation is considered overly onerous by National Grid Property, Workspace Group Plc, Royal Mail Group Ltd, Addition Land Ltd and St James Group, particularly in high density development such as that proposed in the Nine Elms area. Greater flexibility in the policy overall is sought by most of these parties. The Unitary Development Plan required a minimum of 20 sq ms for non-family accommodation and 40 sq ms for family accommodation. In the 2007 New Housing Re-survey, satisfaction with amenity space on new developments was high, with 82% of residents satisfied with communal gardens, and 79% happy with private amenity space. The results of the survey show that there is little correlation between the size of amenity space provided and people's relative levels of satisfaction despite the majority of developments surveyed providing a lower level of private amenity space per dwelling than the policy requirement. What is most important is the quality of amenity space provided, including maximising privacy and minimising overlooking. The amenity space standards have therefore been lowered, but will be minimum standards to achieve in new build developments rather than an optimal level to aim for. The policy also acknowledges that in conversions, the standards may be more difficult to achieve.
3.49 Covent Garden Market Authority consider that the need to provide public open space in Nine Elms should be taken into account in the requirement for amenity space in Nine Elms. This is not accepted as public open space is not a substitute for private amenity space.
3.50 Sutherland Grove and Area Residents' Association are aware of two areas of public open space that they would like to see protected. These areas would be protected by Policy DMO1.
25 DMPD & SSAD Proposed Submission Statement of Consultation
Implementation of affordable housing (DMH8)
3.51 Royal Mail Group are supportive of the recognition that in exceptional circumstances, off-site provision of affordable housing may be acceptable. National Grid Property request flexibility in terms of the percentage requirement of affordable housing. As this is set out in Core Strategy Policy IS5, rather than DMH8 which is providing detail on the implementation of IS5, no changes are made in response to this representation.
3.52 Workspace Group Plc and UK Power Networks (EDF Energy) request flexibility in the application of the affordable housing policy, to take account of viability of development. Minerva request acknowledgement that the level of affordable housing provision may take account of other site specific circumstances and objectives. Adopted Core Strategy Policy IS5d does acknowledge that the level of affordable housing will depend on a number of site-specific factors, and this is explained further in the text. For clarification, a reference to the Core Strategy Policy IS5 has been added.
3.53 REO (Powerstation) Ltd point out that the forthcoming Planning Obligations SPD/CIL charging schedule must accord with the Development Infrastructure Funding Study for the VNEB OA. This is noted and will be taken into account in the preparation of the forthcoming documents. It is the Council's intention to use the DIFS study to inform the CIL charge(s) for Nine Elms.
3.54 Greater London Authority support DMH8 but consider their previous comments that the Council should consider review mechanisms or similar methodology that can assess scheme viabilty at a point closer to delivery and that guidance on this matter should be set out, remain unresolved. The Council has made reference to the use of cascade mechanisms in the context to DMH8, and that further guidance on such mechanisms will be set out in a forthcoming SPD on Planning Obligations/CIL Charging Schedule.
3.55 St James Group consider the requirement for affordable housing should be on the uplift (i.e. Net) units provided, rather than the total number of units on the site (i.e. Gross). The Core Strategy sets out the requirement for affordable housing to be provided on sites capable of providing 10 or more units (gross). This cannot be amended through DMH8. St James request additional guidance on "what the site could potentially provide". The context has been amended to clarify this and will be further amplified in the SPD.
Hostels, staff and shared accommodation (including student housing) specialist and supported housing (DMH9)
3.56 Mr Peter Carpenter considers that the policy identifies a need for student accommodation but does nothing to encourage its provision. The importance of meeting student housing needs is acknowledged in criterion b, which prevents the loss of purpose
26 DMPD & SSAD Proposed Submission Statement of Consultation
built student housing. Core Strategy Policy PL5 sets out the borough's housing targets, and encourages the provision of all new homes including student accommodation. Policy DMH9 sets out the detailed considerations that will be applied to achieve a satisfactory form of development. UK Power Networks (EDF Energy) support the principle of DMH9 but request flexibility to take account of viability issues. As explained above, Core Strategy Policy IS5 deals with scheme viability, and no changes are required to make the policy sound in this respect.
3.57 UK Power Networks also request specific reference that only C3 developments will be subject to the policy, and that Lifetime Homes is only required where relevant. The reference to Lifetime Homes standards has been removed as they will not be applicable in all cases. Similarly St James Group comment that Student Accommodation is Sui Generis and therefore the housing policies should not apply. No changes have been made as the policy approach would include C2 or Sui Generis developments for student housing where no ownership or management arrangement is in place in order to ensure that these developments are not proposing student housing as a way to get around providing affordable housing. In respect of accommodation provided by the private sector for particular client groups (e.g. students or the elderly), additional text has been added to clarify that, without any agreed tie-in or management strategy, this will be treated as standard market housing in applying the policies, including those seeking affordable housing.
3.58 Greater London Authority suggest the Council consider the approach of the Draft Replacement London Plan, which is to seek application of affordable housing policies to a wider range of uses, especially those falling within Use Class C2 that cater for older people. Clarification has been provided in the contextual paragraphs of DMH8 and DMH9 to reflect the borough's identified priority needs for supported housing such as self-contained cluster flats, and that these will count as affordable housing. A commitment to monitor and update changing priorities has been added to the text, along with a cross reference to the affordable housing Policies in IS5 and DMH8.
3.59 Addition Land and Network Rail consider the requirement for student accommodation to be tied to a recognised institution is overly onerous and unjustified. As explained in the context to the policy, the policy aims to close a loophole whereby developers gain speculative permission for student accommodation that is then used for general residential C3 use. This would enable developers to bypass the need to provide affordable housing, or comply with residential amenity and internal space standards. As this could negatively impact the borough's provision of affordable housing units, as well as resulting in substandard residential accommodation the policy requirement has been retained.
27 DMPD & SSAD Proposed Submission Statement of Consultation
Additional amendments
3.60 Within Policy DMH2, the definition of properties that are 'unsuitable for families' has been moved from the policy and placed within the context as a set of guiding principles that will be used to assist in the determination of a properties' suitability for families, with the ultimate assessment being made on a case by case basis. The definition in the policy itself was considered to be too rigid to allow a robust assessment on an individual site basis.
3.61 A minor change to DMH3a has been made to enhance clarity of the policy. DMH4 has been amended to seek dual aspect where ever possible, in line with the London Housing Design Guide.
3.62 For consistency with the London Housing Design, and to reflect the difficulties in achieving a good standard of accommodation in studios, in particular in conversions, the minimum size threshold for 1 person accommodation has been raised from 35 to 38sqm in Policy DMH6. Further clarification was also sought on amenity space and extensions, residential standards for private and grant-funded schemes. Minor changes to DMH5 and DMH7 have therefore been made to improve consistency between these two policies, and to DMH8 and DMH9 and supporting paragraphs. Minor changes to the contextual paragraphs have also been made throughout the chapter to improve clarification on these matters. Reference to the Building Regulations covering the needs of disabled people in new student housing schemes, and the quality/fitness standards of the Housing Act have also been made to the contextual paragraphs to better inform development and the assessment of such accommodation. For clarification, reference to the Building Regulations standards for providing wheelchair accessible student units has been added.
Chapter 3 - Housing
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
DMH1 - Protection of residential land and buildings
Sutherland Grove and Area Residents' 491359 118 Not specified Association
Greater London Authority 1407 241 Not specified
DMH2 - Conversions
28 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 3 - Housing
Sutherland Grove and Area Residents' 491359 119 Not specified Association
DMH3 - Unit mix in new housing
Mr Peter Carpenter 491438 126 1, 2, 3
National Grid Property 234008 68 Not specified
Covent Garden Market Authority 491216 85 2
Workspace Group Plc 397170 95 2
Royal Mail Group Limited 494648 157 2
Minerva 40433 165 Sound
UK Power Networks (EDF Energy) 1326 182 Sound
Ballymore Group 366691 197 & 198 1, 2
Greater London Authority 1407 242 Not specified
St James Group 495333 224 Not specified
REO (Powerstation) Ltd 49810 206 Not specified
Quality of Housing
Port of London Authority 1405 24 1,3
DMH4 - Residential development including conversions
Covent Garden Market Authority 491216 86 2
Workspace Group Plc 397170 96 2
UK Power Networks (EDF Energy) 1326 183 Not specified
REO (Powerstation) Ltd 49810 207 Not specified
DMH5 - Alterations and extensions
Mrs Isabel Wooller 204045 52 Not specified
Sutherland Grove and Area Residents' 491359 120 Not specified Association
DMH6 - Residential space standards
National Grid Property 234008 69 Not specified
Covent Garden Market Authority 491216 87 2
Workspace Group Plc 397170 97 2
29 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 3 - Housing
Sutherland Grove and Area Residents' 491359 121 Not specified Association
Royal Mail Group Limited 494648 158 Not specified
Minerva 40433 166 1
REO (Powerstation) Ltd 49810 208 Not specified
Greater London Authority 1407 244 Not specified
St James Group 495333 225 Not specified
DMH7 - Residential gardens and amenity space
Mrs Patricia Poulter 396982 13 Not specified
Mrs Isabel Wooller 204045 53 Not specified
National Grid Property 234008 70 Not specified
Covent Garden Market Authority 491216 88 2
Workspace Group Plc 397170 98 1, 2
Sutherland Grove and Area Residents' 491359 122 Not specified Association
Royal Mail Group Limited 494648 159 Not specified
UK Power Networks (EDF Energy) 1326 184 Not specified
Addition Land and Network Rail 222140 239 2
St James Group 495333 226 Not specified
BP and M Adams 404083 250 Not specified
DMH8 - Implementation of affordable housing
National Grid Property 234008 71 Not specified
Workspace Group Plc 397170 99 2
Royal Mail Group Limited 494648 160 Not specified
Minerva 40433 167 Not specified
UK Power Networks (EDF Energy) 1326 185 Not specified
REO (Powerstation) Ltd 49810 209 Not specified
Greater London Authority 1407 245 Not specified
St James Group 495333 227 Not specified
30 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 3 - Housing
Mr Peter Carpenter 491438 127 2
DMH9 - Hostels, staff and shared accommodation (including student housing), specialist and supported housing
Mr Peter Carpenter 491438 128 2
UK Power Networks (EDF Energy) 1326 186 Not specified
REO (Powerstation) Ltd 49810 210 2
Greater London Authority 1407 246 Not specified
Addition Land Ltd and Network Rail 222140 238 1
St James Group 495333 228 Not specified
31 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 4 – Town Centres and Shopping
Town centre development (DMTS1)
3.63 Mrs Patricia Poulter and Mrs Isabel Wooller consider that para 4.11 is too generalised in its consideration of evening uses in town centres, and in particular, that family housing near the Capsticks site in Putney, is not considered. Consideration of the evening economy is covered in paras 4.10 and 4.11. The latter does explain that it is necessary to consider the impact of increased concentrations of evening uses and that evening uses are also controlled through licencing and waste management legislation. Therefore no changes are proposed in response to these representations.
3.64 Covent Garden Market Authority support the policy, particularly the treatment of CAZ frontages in Nine Elms as designated centres, but request guidance on the classification of these centres in order for retail proposals for these sites to be assessed against PPS4. None of the LDF documents intend to identify additional local or town centres other than those identified in the Core Strategy, but these will be monitored and reviewed over the period of the LDF. Development proposals in the Nine Elms area are still at an early stage and until proposals at Nine Elms have been implemented, it is not appropriate to define a boundary within the DMPD. This will take place through regular monitoring and review of the plan. In addition, the SSAD identifies areas and sites where new retail will be appropriate and whether this retail should be significant in scale, whether it will be small-scale to provide for local day to day needs or whether it will be part of a mixed use area. PPS4 tests will apply to new retail proposals where relevant, having regard to what has been set out in the SSAD in terms of scale of retail development foreseen, but it is important to note that the Core Strategy and SSAD recognise that this retail development is co-dependent on completions of new housing that will provide the retail market. The text has been amended in DMTS1a to clarify that it is "potential" CAZ frontages, as referred to in the London Plan, the GLA's Town Centre Health Check report 2010, the Core Strategy and the SSAD.
3.65 Mr Carpenter requests amendment of the policy to allow amalgamation of units, to provide larger units for high street retailers. Clause c i. states that conditions may be used to control this in some cases, where it would be beneficial to retain smaller units or a mix of uses in perpetuity but no changes are required as the policy does not prevent amalgamation of units. In addition this is normally permitted development in high streets, unless the Council has sought to remove these rights which is more common in out-of-centre mixed use developments.
3.66 Minerva consider that the policy should not seek to unduly restrict any of the five town centres as it should be recognised that physically and economically, only certain centres in the borough are capable at this time of accommodating significant growth. This representation addresses Core Strategy Policy PL8 and the Council's Sustainable Development Strategy which set out the Council's vision for the five town centres. This does not mean that significant growth will be restricted: Core Strategy
32 DMPD & SSAD Proposed Submission Statement of Consultation
policies PL11 Nine Elms and the VNEB area, PL12 (Central Wandsworth), PL13 (Clapham Junction area) and PL14 (East Putney and Upper Richmond Road) set out the strategic direction for those town centres where significant growth or change is envisaged over the plan period which includes new housing development. Some of these areas are not restricted to town centres, and seek housing, offices and mixed use growth. It is only necessary to control the scale of town centre uses in out of centre locations, the scale of new retail floorspace outside the protected parades within town centres, and to ensure that growth within the town centres will not increase the relative attractiveness of any one centre, in line with town centre first objectives in PPS4, the London Plan and the Core Strategy. REO (Powerstation) Ltd request reference to CAZ frontages and sites identified for large-scale retail in the SSAD as locations where there will be a preference for A1 uses. This policy clause identifies designated shopping parades within the borough's shopping hierarchy. As the exact location of the CAZ frontages is not yet known it is inappropriate to make this change at this time.
Out-of-centre development (DMTS2)
3.67 UK Power Networks (EDF Energy) support the policy but request that the supporting text recognises that the provision of smaller shops can significantly enhance the character and vibrancy of an area, particularly as part of mixed-use developments. This is accepted and the context has been updated to reflect this representation.
3.68 Ballymore Group and Addition Land and Network Rail oppose part of c of the policy and consider it unsound on the basis that the 300 sq ms limit for out-of-centre retail units is unjustified. The main policy objective here is to ensure that retail uses are concentrated in existing centres or in areas identified in the development plan, to be in conformity with PPS4, the London Plan and the Core Strategy. New retail floorspace outside of these areas would only be acceptable if it catered for day to day needs to minimise trip generation and contribute to sustainability principles. A typical local convenience store to meet these needs can be accommodated in a unit within the range of 250-300 sq ms, but these needs may also be provided for by smaller units within this threshold. The wider role of small-scale local convenience shopping in meeting local needs and contributing to sustainability objectives is acknowledged, especially in the new areas of housing developments along the Riverside. Areas where some new retail floorspace would be acceptable as part of mixed use development are identified in the policies relating to MUFIEAs, Focal Points of Activity and in the SSAD to guide the types and scale of future development in Nine Elms. Within Nine Elms, significant retail development is envisaged within the potential CAZ frontages at Battersea Power Station and around Vauxhall. This will mean that no area within Nine Elms will be deficient in shoppping facilities, and this justifies setting a limit on new retail provision outside these two areas. Clarification has been added to the text in this respect, with additional text added to the policy clarifying that the limit will refer to overall floorspace, and that a retail impact assessment will be required for larger proposals in line with
33 DMPD & SSAD Proposed Submission Statement of Consultation
PPS4. In mixed use areas it is important that ensure that any one use does not dominate and that the variety of uses envisaged in these areas is protected. The policy has been updated accordingly.
Core shopping frontages (DMTS3)
3.69 Clapham Junction Town Centre Partnership consider clarification is needed regarding what constitutes an A1/A3 use. The current Use Classes Order provides the definitive distinction and tests for each Use Class. The text in the previous version on the DMPD which referred to mixed A1/A3 uses has been amended to explain the updated position on how planning applications for food and drink uses are determined. The principles behind whether a use is interpreted to be either A1 or A3 relates to whether the food or drink is mainly consumed on or off the premises, and this must be determined by the local planning authority on a case by case basis. Reference to the Use Classes Order and the main considerations that will be taken into account has been added to the text.
3.70 The percentage of A1 units is also considered to be arbitrary by the above respondents. As explained in the Preferred Options version of the DMPD, it is considered that a reduction in the protection of A1 units from 80% to 70% in core shopping frontages and from 60% to 50% in secondary shopping frontages is appropriate, acknowledging that these are not just shopping destinations and that complementary uses which enhance the retail function of the shopping parades in town centres can enhance vitality and viability. In respect of local centres, the Retail Needs Assessment (March 2008) identified a wider role than just local shopping in some local centres, for example following a trend towards eating out locally. As such, it is also considered appropriate to reduce the proportions of A1 use required to be protected in the local centre core and secondary shopping frontages. A summary of the Use Classes Order has been added to the Glossary in Appendix 3 for ease of reference.
Secondary shopping frontages (DMTS4)
3.71 Mrs Patricia Poulter and Mrs Isabel Wooller oppose the reduction in the proportion of A1 retail in the secondary frontages and consider it should remain 60% as it is in the Unitary Development Plan. The rational for reducing the percentages is set out above. The respondents also consider the frontages at 94-138 and 140-152 Upper Richmond Road should be one frontage. Options for defining the borough's protected shopping frontages were explored in the Preferred Options version of the DMPD. The frontage at 94-138 Upper Richmond Road is currently a secondary shopping frontage in Putney Town Centre, whilst 140-152 Upper Richmond Road is currently an other frontage where a wider range of uses is permitted. Core Strategy Policy PL14 and the supporting text identify that the focus for retail development in Putney will be in the High Street, including Putney Exchange shopping centre whilst the objective for this part of Upper Richmond Road is for replacement offices in an improved environment with active frontages. Active frontages do not necessarily mean shops (A1 use) but
34 DMPD & SSAD Proposed Submission Statement of Consultation
include those uses that would maintain a shopfront and generate pedestrian activity throughout the day or evening such as hairdressers, banks, estate agents and cafes. In an urban design context active frontages also mean principles of improving the streetscene by presenting a frontage in terms of orientation of the building, position of ground floor windows, doors, signage etc. No changes are made in response to these representations.
3.72 PPS4 defines 'economic development' which includes community and main town centre uses. 'Main town centre uses' is then separately defined and does not include community facilities. The Metropolitan Police service consider DMTS4 unsound, as it states that only main town centre uses are appropriate in the secondary shopping frontages. Whilst excluded from PPS4, the Council considers that community uses, particularly those drawing clients from a wider catchment, are appropriate in town centres, which benefit from good public transport accessibility and because uses which attract people into the centres can bring in trade for the shops and services. This has been clarified by including a list of town centre uses in the Glossary in Appendix 3 which will apply where policies in the DMPD refer to "town centre" uses. However, the focus of the protected shopping frontages is to maximise and protect A1 (retail) uses and allows other uses if they complement the main shopping function. This is likely to be within the range of A class uses and this has been clarified in criterion b and supporting text community facilities including policing facilities would therefore be appropriate in town centres, but outside the designated core and secondary shopping frontages.
Other shopping frontages (DMTS5) and Important Local Parades (DMTS6)
3.73 Metropolitan Police Service make the same representation as that discussed above in relation to DMTS4. The position of town centre uses as defined in Wandsworth, is covered in the response above. The whole range of town centre uses, as defined in the Glossary, are appropriate within the Other frontages, and this includes community uses.
Loss of shops outside protected parades (DMTS7)
3.74 No representations received.
Shopfronts and signs (DMTS8)
3.75 Mrs Patricia Poulter and Mrs Isabel Wooller consider the policy should also reference consideration of the impact of shopfronts and signs on residential amenity. Changes have been made to clarify that these considerations apply to all locations in the borough where shops and signs are located and the text includes a reference to Conservation Area Management Strategies.
Northcote Road area of special shopping character (DMTS9)
3.76 The policy is supported by Clapham Junction Town Centre Partnership.
35 DMPD & SSAD Proposed Submission Statement of Consultation
Markets (DMTS10)
3.77 The policy is supported by Covent Garden Market Authority.
Arts, culture and entertainment (DMTS11)
3.78 Theatres Trust find the policy sound but request minor amendments to enhance clarity. These include writing out the ACE acronym in full in part b of the policy, consideration of the adaptability of local facilities in part bii and adding a comma after arts in the title. The requested amendments have been made as they are considered to enhance clarity of the policy. Covent Garden Market Authority and REO (Powerstation) Ltd consider ACE uses are also appropriate within the CAZ frontages. As with DMTS1, for consistency and clarification additional text has been added to refer to the potential CAZ frontages within the Nine Elms/VNEB area, along with a reference to ensure that the scale is compatible with the location. A reference has also been added to clarify that an impact assessment may be required for large scale proposals in line with PPS4.
Hotel development (DMTS12)
3.79 REO (Powerstation) Ltd strongly supports the identification of the VNEB OA as suitable for hotels. UK Power Networks (EDF Energy) support that hotels are appropriate in areas with good public transport accessibility and close to town centres. However, the policy has been amended to clarify that large scale hotels are most appropriately located within town centres and Nine Elms to align with the Draft Replacement London Plan. The SSAD provides further site-specific guidance within the Nine Elms area where growth and change is anticipated in the medium to long term. Mrs Patricia Poulter and Mrs Isabel Wooller request reference to coach and guest parking requirements. Parking standards are set out in Appendix 1 and reference to this is now contained in the context.
Offices and town centres (DMTS13)
3.80 Threadneedle Property Services and Investments and Prices Securities Ltd consider that the policy will act as a disincentive for landlords to invest, resulting in smaller office unit sizes not coming forward, and conclude that the policy is unsound. They also consider that the steps required to demonstrate that particular options have been explored could lead to stagnation in some local office markets and that evidence ordinarily available to landlords is likely to prove insufficient to the Council, but that this will only be apparent at the end of the marketing period rather than at the outset. They consider that criteria b and d are too inflexible, the wording of the policy could be misinterpreted and the policy will result in significant cost to landlords through the engagement of surveyors of through the need to finance improvements and refurbishment. In line with PPS4, the London Plan, the Core Strategy, and evidence contained in the 2010 Employment Land Study, it is important that there is a policy to protect and attract new office development in town centres. The Employment Land
36 DMPD & SSAD Proposed Submission Statement of Consultation
Study does provide an up-to-date position on the office market in the borough, identifying a continuing demand for offices, so it is considered appropriate for the policy to require detailed marketing information to refute this evidence. Some flexibility has been included in the policy and context regarding the length of marketing information required.
3.81 Workspace Group Plc consider that Policy DMTS13 should also support the redevelopment of former purpose-built offices to provide new employment/business accommodation (particularly SME space) even where this would result in a reduction in the net business space. They suggest that new flexible business space for SMEs will help support local businesses, provide a greater number of local employment opportunities, and help strengthen the local economy - particularly when compared to a conventional office use. In line with PPS4, the London Plan, the Core Strategy, and evidence on office demand and supply contained in the 2010 Employment Land Study, it is important that there is a policy to protect and attract new office development in town centres as opposed to business generally. Provision of other types of employment provision including for SME firms is acknowledged within the Core Strategy and within the DMI, Business and Industry chapter of the DMPD. MUFIEAs, including those within town centres, are an example of a location where SME firms may locate where this would not otherwise prejudice the supply of existing offices.
3.82 Russell-Cook Solicitors support the marketing criteria set out in the policy. However, they consider that criterion a. should be expanded to clarify that high quality accommodation is needed to meet the needs of modern occupiers, in particular policy PL8 and PL14. They consider that windowless and basement office accommodation should be avoided. Changes to the explanatory text in the supporting paragraphs to provide more detail on quality of accommodation.
3.83 REO (Powerstation) Ltd consider that the current wording does not reflect the adopted and emerging policy in the London Plan, the Draft Replacement London Plan, the VNEB OAPF, the Core Strategy and the Site Specific Allocations Document which identify the Nine Elms area and BPS in particular for significant office development. As with DMTS1, for consistency and clarification, additional text has been added to DMTS13 to refer to the potential CAZ frontages within the Nine Elms area and the title of the policy has been amended to clarify that it does not just apply to town centres.
3.84 St James Group consider that the policy needs to be more flexible to reflect that site specific circumstances and modern working practises will affect the appropriate level of the reprovision of office floorspace. They wish to see mixed use development encouraged, and acknowledgement of the benefits that mixed use schemes can bring to town centres. This representation also considered that mixed-use development where compatible, will make more efficient uses of sites, ensuring a balance between economic development and new housing provision. To meet demand for offices identified in the 2010 Employment Land and Premises Survey, it is important that office space is not lost within the town centres, which are to be the focus for office development in the
37 DMPD & SSAD Proposed Submission Statement of Consultation
borough. In line with Core Strategy PL14, the objectives of this Policy include an overall reprovision of office floorspace. On a site by site basis, it has become apparent that to achieve all the other objectives that this policy seeks, including an improved environment at an appropriate scale, a reduction in office reprovision may be necessary in order to attract redevelopment and achieve the vision for this area. The requirements of current office occupiers and the design of modern offices mean that it is usually possible to achieve the same level of jobs in a reduced floorspace, and this is reflected in the amended policy wording and context. Policy DMI2 covers mixed-use areas, including MUFIEAs within town centres.
Internal Comments
3.85 Comments on the chapter have also been received from Development Management officers, mainly covering points of clarification or further information.
3.86 DMTS5 - Minor changes have been made to the criteria covering appropriate uses in Other frontages to clarify that the aims here are to ensure compatibility with the retail function of the centre and bring vitality and pedestrian activity the area. This may also assist in assessing which Sui Generis uses could be appropriate.
3.87 DMTS7 - Removal of the reference to town centres, local centres or ILPs has been made to clarify that alternative local shopping facilities outside these areas will be considered when assessing the acceptability of loss of shops outside protected parades. The criterion relating to marketing evidence has also been clarified to reflect the same requirements as those for loss of offices, to ensure consistency.
3.88 DMTS12 - For clarification, reference to the building regulations standards for providing wheelchair accessible hotel units has been added.
3.89 DMTS13 - Following discussions, it has become apparent that large-scale reprovision of office floorspace in the Upper Richmond Road area of East Putney can be difficult to provide at this scale, whilst trying to achieve all of the other policy objectives set out in Core Strategy Policy PL14. Further wording has been added to the policy and to the context as described above to take into account the ability of the scheme to meet other objectives set out in Policy PL14 as well as the number of jobs being provided through the scheme.
3.90 It is considered appropriate to divide the new shopping parades at Clapham South Local Centre (formerly an Important Local Parade) into two shorter parades. Other minor changes, mainly typographical, have been made to the list of protected shopping frontages.
38 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 4 - Town centres and Shopping
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
DMTS1 - Town centre development
Mrs Patricia Poulter 396982 5, 14 Not specified
Mrs Isabel Wooller 204045 54 Not specified
Covent Garden Market Authority 491216 89 1
Mr Peter Carpenter 491438 129 2
Minerva 40433 168 Not specified
REO (Powerstation) Ltd 49810 211 Not specified
DMTS2 - Out-of-centre development
UK Power Networks (EDF Energy) 1326 187 Not specified
Ballymore Group 366691 199 1, 3
Addition Land and Network Rail 222140 234 2
DMTS3 - Core shopping frontages
Clapham Junction Town Centre 1127 139 Not specified Partnership
DMTS4 - Secondary shopping frontages
Mrs Patricia Poulter 396982 15, 16 Not specified
Mrs Isabel Wooller 204045 55, 56 Not specified
Metropolitan Police Service 220011 144 3
DMTS5 - Other shopping frontages
Metropolitan Police Service 220011 145 3
DMTS6 - Important Local Parades
Metropolitan Police Service 220011 146 3
39 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 4 - Town centres and Shopping
DMTS7 - Loss of shops outside protected parades
No representations
DMTS8 - Shopfronts and signs
Mrs Patricia Poulter 396982 17 Not specified
Mrs Isabel Wooller 204045 57 Not specified
DMTS9 - Northcode Road area of special shopping character
Clapham Junction Town Centre 1127 141 Not specified Partnershop
DMTS10 - Markets
Covent Garden Market Authority 491216 90 Sound
DMTS11 - Arts, culture and entertainment
Theatres Trust 785 74 Sound
REO (Powerstation) Ltd 49810 212 & 213 Not specified
Covent Garden Market Authority 491216 91 2
DMTS12 - Hotel development
Mrs Patricia Poulter 396982 18 Not specified
Mrs Isabel Wooller 204045 58 Not specified
UK Power Networks (EDF Energy) 1326 188 Sound
REO (Powerstation) Ltd 49810 214 Sound
DMTS13 - Offices in town centres
Threadneedle Property Investments 495034 174 2 and Prices Securities
Workspace Group Plc 397170 100 2
Russell-Cook Solicitors 31152 136 1, 2, 3
REO (Powerstaton) Ltd 49810 215 Not specified
St James Group 495333 229 No specified
40 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 5 – Industry, Employment and Waste
3.91 Wandsworth Society request a heading in the chapter to signpost the protection of industrial uses in industrial areas. This is accepted and the section title has been amended to 'Protection and promotion of Employment Uses'. Ballymore find the chapter unsound, as it does not express support for offices in the Vauxhall Nine Elms Battersea Opportunity Area (VNEB OA). A policy clause on offices in Nine Elms has been included in the town centre chapter (DMTS13) to align with the Area Spatial Strategy for Nine Elms, which identifies the Power Station and Vauxhall/Embassy as the main locations for office floorspace, with smaller scale office developments appropriate elsewhere. The town centres chapter was considered the best location for this policy, as a new policy on VNEB in this chapter would have required several changes to policies in the town centres chapter (DMTS1, DMTS10, DMTS11, DMTS12).
Strategic Industrial Locations (SILs), Locally Significant Industrial Areas (LSIAs) (DMI1)
3.92 Costco Wholesale UK Limited request reference to the suitability of Sui Generis uses in SILs, LSIAs and MUFIEAs, where appropriate. Reference to the appropriateness of SG uses was provided in the Preferred Options version, but removed at Proposed Submission stage as the suitability of SG uses is always dependent on the nature of the scheme. To clarify this, a sentence to this effect has been added to the context at the beginning of the chapter. Workspace Group Plc request greater flexibility in terms of appropriate uses, where this accommodates small to medium enterprises (SMEs), and mixed use development to cross-subsidise the regeneration of industrial sites. Some flexibility has been included, to allow other uses (A1/A3 etc) where they are small scale to cater for the local needs of people working in the area. Further flexibility, for example, allowing residential uses as part of mixed-use development to cross-subsidise developments and encourage regeneration, would compromise the use of these areas for heavy industrial and waste management activity, for which they are designated. The principle of protection and promotion of acceptable uses within industrial areas has already been established within the Core Strategy and the policy has been amended to clarify this position.
Mixed Use Former Industrial Employment Areas (MUFIEAs) (DMI2)
3.93 Costco Wholesale make the same comments as above, in relation to Sui Generis uses. As explained above, the context has been updated to reflect that the suitability of SG uses will be assessed on a case by case basis. Workspace Group Plc support the identification of the Wandsworth Business Village as a MUFIEA but consider further options for the regeneration and improvement of the Bendon Valley LSIA need to be explored and consider that this is likely to require a flexible approach towards new development within the Bendon Valley LSIA to secure the necessary regeneration. Bendon Valley is identified as a Locally Significant Industrial Area, and the policies which relate to LSIAs will apply to development in this location as recommended by the DTZ Employment Land and Premises Study. There is no evidence to suggest a special case
41 DMPD & SSAD Proposed Submission Statement of Consultation
should be made for this LSIA and the DTZ study identifies the site as one of good quality that should be retained for industrial employment use. The Metropolitan Police consider that policing facilities should be appropriate in MUFIEAs outside town centres and focal points of activity. Depending on the type and scale of policing facilities proposed (offices, stations or training facilities) this could either be SG, B1 or D1 use. B1a would be considered appropriate in these areas, SG would be assessed on a case by case basis and D1 would be inappropriate in line with the recommendations set out in the DTZ report.
3.94 Clause a of the policy allows for town centre uses in MUFIEAs in town centres and focal points of activity, however in order to ensure that a mixed use environment is created and maintained in these areas, provision for controlling the mix of uses through conditions has been included to avoiding large mono-uses and to ensure that in focal points of activity, potential impacts on town centres are considered. The limit of 300 sq ms of A1 floorspace that applies to out of centre retail and Focal Points of Activity (Policy DMO8) has also been included for consistency and to ensure that while a mix of uses is provided in these locations, that they don't become shopping destinations to the detriment of town centre viability.
Thames Policy Area (DMI3)
3.95 The policy is supported by Metropolitan Police. Port of London Authority request amendment to the text and policy to reference the boroughs safeguarded wharves. A cross reference to Core Strategy Policy PL9b has been included in the text. For clarity, a cross reference to policy applying to Focal Points of Activity in the TPA has also been provided. Bupa consider that the Employment Land and Premises Study prepared by DTZ is not sound as it is not backed up by facts. This is not accepted, as the DTZ study broadly accords with the advice contained in the 2004 Employment Land Reviews Guidance Note (produced by the ODPM - now DCLG) and the South East England Partnership Board Guidance on Employment Land Reviews (2009). REO (Powerstation) Ltd request greater flexibility due to a concern that the policy could prevent the redevelopment of existing employment sites, which could contribute towards the boroughs housing target. It is considered that the policy already provides sufficient flexibility for loss of business floorspace where it can be demonstrated that this is no longer in demand. St James Group request flexibility in the application of this policy, for sites within the VNEB OA. A sentence has been added to the context to clarify that the objectives of the VNEB OA take precedence over the Thames Policy Area policies, and that flexibility will be applied in this location.
3.96 Reference to how the Council would consider new applications for B1, B2 and B8 floorspace or provision of this floorspace over and above the re-provision of existing levels onsite has also been included in the context.
42 DMPD & SSAD Proposed Submission Statement of Consultation
Provision of flexible employment floorspace (DMI4)
3.97 Workspace Group Plc welcome the encouragement of flexible employment floorspace within the MUFIEAs and as part of developments on existing employment sites within a town centre, local centre or the Thames Policy Area, but consider greater flexibility is required to enable such floorspace to come forward as part of mixed-use developments. This representation is also made by REO (Powerstation ) Ltd. No changes to the policy have been made, as flexible employment floorspace would be appropriate as part of mixed-use developments, provided the policies for the area in which the development comes forward, allows residential floorspace. This would include all of the areas listed above apart from SILs and LSIAs, where residential development is inappropriate.
Allocated sites for waste management facilities (DMI5)
3.98 The Port of London Authority considers that their comments on the Site Specific Allocations Document need to be accepted to ensure that Policy DMI5 is acceptable. Cappagh consider that part b of the policy is unreasonably restrictive as it would prohibit a site being redeveloped for waste recycling or recovery use which would result in waste moving up the waste hierarchy. This is not accepted as the policy only requires that the capacity of the site is maintained, or additional compensatory provision is made, but does not specify the method by which this is achieved.
Development of waste management facilities on unallocated sites (DMI6)
3.99 Port of London Authority support the policy and consider it in accordance with the London Plan. Mr Peter Carpenter requests amendment to make it clear that sites required for Pyrolysis are not included in its definition of 'Waste Management Sites'. This is not accepted as the London Plan defines a waste management site, and this includes Pyrolysis.
Development criteria for waste sites (DMI7)
3.100 Port of London Authority support reference to assessing the impact of development on the transport network and the potential for use of sustainable transport, but consider reference should be made to maximising the potential for use of sustainable transport. This representation is accepted.
43 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 5 - Industry, Employment and Waste
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with national policy
Wandsworth Society 847 169 Not specified
Ballymore Group 366691 200 2
DMI1 - Strategic Industrial Locations (SILs) and Locally Significant Industrial Areas (LSIAs)
Costco Wholesale UK Limited 200084 76 Not specified
Workspace Group Plc 397170 101 2
DMI2 - Mixed Use Former Industrial Employment Areas (MUFIEAs)
Costco Wholesale UK Limited 200084 77 Not specified
Workspace Group Plc 397170 102 2
Metropolitan Police Service 220011 147 2, 3
DMI3 - Thames Policy Area
Port of London Authority 1405 25 1, 3
Bupa 398858 134 1
Metropolitan Police Service 220011 148 Not specified
REO (Powerstation) Ltd 49810 219 Not specified
St James Group 495333 230 Not specified
DMI4 - Provision of flexible employment floorspace
Workspace Group Plc 397170 103 2
REO (Powerstation) Ltd 49810 216 Not specified
DMI5 - Allocated sites for waste management facilities
Cappagh 406808 63 3
Port of London Authority 1405 26 1, 3
DMI6 - Development of waste management facilities on unallocated sites
44 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 5 - Industry, Employment and Waste
Port of London Authority 1405 27 Sound.
Mr Peter Carpenter 491438 130 2
DMI7 - Development criteria for waste sites
Port of London Authority 1405 28 1, 3
45 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 6 – Open Space, the Natural Environment and the Riverside
Protection and enhancement of open spaces (DMO1)
3.101 Thames Water support the recognition that utility infrastructure may be permitted in Metropolitan Open Land, subject to meeting certain criteria, however Thames Water object to the inclusion of the Falconbrook Sewage Pumping Station site within the York Gardens larger Protected Open Space. While it is acknowledged that this part of the site is not currently in open use, it is considered necessary to protect the larger park area from inappropriate development and to prioritise open space uses in the future. Mr Peter Carpenter considers that the policy needs to be amended to make specific reference to the fact that the use of the Barn Elms site as a main site for the proposed Thames Water Tunnel is not an acceptable use of Metropolitan Open Land (MOL). It is not appropriate to address specific projects in the policy and the Barn Elms site is not within the borough, however the policy has been amended to make it clear that there is a presumption against development on MOL unless for essential facilities that do not adversely impact the open land (to accord with PPG2, PPG17 and the London Plan). An explanation of engineering works has been added to the text. Part c of the policy has been amended to state that any replacement open space must take into account need and be in an appropriate location. A reference to the Council's Sports and Play Strategies has been added to the text to provide further context to the policies.
Playing fields and pitches, outdoor sport, play and informal recreation (DMO2)
3.102 Mr Peter Carpenter requests the policy is amended in the same way as DMO1 to state that the loss of playing fields for the Thames Tunnel Project is inappropriate. The same response applies.
3.103 For clarity the title has been changed from 'outdoor sport' to 'sport' as indoor sport is also included in the policy.
Open spaces in new development (DMO3)
3.104 REO (Powerstation) Ltd point out that the future Planning Obligations SPD/CIL charging schedule must accord with the Development Infrastructure Funding Study for the VNEB OA. This is noted and will be addressed through the SPD/charging schedule. It is the Council's intention to use the DIFS to inform the CIL charge(s) for Nine Elms. UK Power Networks (EDF Energy) request greater flexibility with respect to providing or contributions towards open space. No changes have been made to the policy as it is already considered sufficiently flexible.
46 DMPD & SSAD Proposed Submission Statement of Consultation
Nature conservation (DMO4)
3.105 No representations received.
Trees (DMO5)
3.106 Mrs Patricia Poulter, Mrs Isabel Wooller, BP and M Adams and Mr Peter Carpenter consider the policy should go further to protect trees outside conservation areas as well as those within conservation areas and those protected by Tree Preservation Order. The policy has been amended to afford protection to all trees with amenity value. Detail has been added to the second part of the policy in relation to protected trees.
Riverside development (DMO6) and Development in the river and on the foreshore (DMO7)
3.107 Thames Water request the policy make specific reference to support for the Thames Tunnel project. This is not considered necessary as it would duplicate Core Strategy Policy IS6d. Further detail regarding the Council's updated position on the Thames Tunnel is provided in response to Thames Water's representations on the SSAD. Workspace Group Plc support the broad approach to riverside development and the improvement of the Wandle Valley, but consider the policy should also encourage development in LSIAs neighbouring the River Wandle which positively improves and enhances the riverside area. Regeneration is encouraged in LSIAs subject to the policies regarding uses appropriate to this designation which are set out in the Industry, Employment and Waste chapter and relevant Core Strategy policies. UK Power Networks (EDF Energy) request reference is made to the viability of development when seeking contributions towards riverside infrastructure. This is not considered necessary as the policy merely references Core Strategy Policy IS7, which sets out the Council's adopted policy on planning obligations. It is clear in IS7 that planning obligations must be sought in terms of Circular 05/05. The policy has however been amended to clarify that the detailed mechanisms for requiring contributions will be set out in a forthcoming Planning Obligations SPD/CIL charging schedule (to be consistent with other policies).
3.108 The Port of London Authority (PLA) request paragraph 6.20 make reference to the important transport function that the river has for the transportation of people, and clarification that the wharves are safeguarded for cargo handling under Core Strategy Policy PL9. The PLA also request paragraph 6.23 and DMO6 are updated to clarify that moorings are most appropriately located where they do not have a detrimental impact on navigation, river regime and environment. The requested changes have been made. The PLA also request part av of the policy is updated to reflect the requirements of London Plan Policy 4C.9. Core Strategy Policy PL9 provides clear protection for safeguarded wharves and this is referenced in paragraph 6.20. It is not considered necessary to repeat this in DMO6 and 7. Thames Water are supportive of the policy. The Port of London Authority welcome a policy relating to development in
47 DMPD & SSAD Proposed Submission Statement of Consultation
the river and on the foreshore however consider there is a degree of overlap between DMO6 and DMO7. It is acknowledged that there many of the policy criteria are similar, but as DMO6 relates to development adjacent to the river, and DMO7 relates to development in the river on the foreshore, it is considered necessary for these criteria to be set out in both policies. The PLA also question why there is no specific policy relating to the protection of safeguarded wharves for cargo handling. The context has been amended to clarify that safeguarded wharves should not be harmed because of the important role they play in cargo handling and to refer to Core Strategy Policy PL9, however a specific policy on safeguarded wharves is not considered necessary as this would duplicate Policy PL9.
Focal points of activity (DMO8)
3.109 Covent Garden Market Authority request para 6.25 to be updated to recognise the potential CAZ frontage outside Vauxhall. The context has been updated to reference both potential CAZ frontages in Nine Elms. Workspace support the Council's approach towards encouraging a wider mix of uses at focal points of activity but consider the policy should also encourage the regeneration of other riverside areas, such as the Bendon Valley. The Bendon Valley is a Locally Significant Industrial Area and regeneration is encouraged, subject to the policies regarding uses appropriate to this designation which are set out in the Industry, Employment and Waste chapter and relevant Core Strategy policies. This is not relevant to the designation of a focal point of activity.
3.110 The limit of 300 sq ms town centre uses was considered to be too restrictive in the focal points of activity, where a range and mix of uses is sought. A limit of 300 for sq ms A1 uses has been retained, to be consistent with Policy DMTS2 on out of centre retail. It is more important to retain the ability to condition the mix of uses to ensure that an appropriate mix is maintained, and impacts on town centres can be controlled. The policy has been updated to reflect this.
Chapter 6 - Open Space, the Natural Environment and the Riverside
Representer Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
DMO1 - Protection and enhancement of open spaces
Thames Water 233792 36 2, 3
Mr Peter Carpenter 491438 131 2, 3
48 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 6 - Open Space, the Natural Environment and the Riverside
DMO2 - Playing fields and pitches, outdoor sport, play and information recreation
Mr Peter Carpenter 491438 132 2
DMO3 - Open spaces in new development
REO (Powerstation) Ltd 49810 217 Not specified
UK Power Networks (EDF Energy) 1326 189 Not specified
DMO4 - Nature conservation
No representations
DMO5 - Trees
Mrs Patricia Poulter 396982 19 Not specified
Mrs Isabel Wooller 204045 59 Not specified
Mr Peter Carpenter 491438 133 2
BP and M Adams 404083 251 Not specified
DMO6 - Riverside development
Port of London Authority 1405 29 1, 3
Thames Water 233792 37 2
Workspace Group Plc 397170 104 2
UK Power Networks (EDF Energy) 1326 190
DMO7 - Development in the river and on the foreshore
Port of London Authority 1405 30 Not specified
Thames Water 233792 38 Sound
DMO8 - Focal points of activity
Covent Garden Market Authority 491216 92 Sound
Workspace Group Plc 397170 105 2
49 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 7 – Community Facilities
3.111 The London Fire and Emergency Planning Authority generally support policy DMC1 but object to parts aiii and aiv considering that these remove the flexibility provided by parts ai and aii. This representation is accepted in part, as the clauses have been amended, rather than deleted as requested. An ‘or’ has been added to the end of clause aii to clarify that this is an alternative way community facilities may be lost, not an additional requirement to be demonstrated through a planning application. Clause iv has been moved to relate to clause ai, as marketing evidence would only be required by the Council to demonstrate that there is no longer a need or demand for the facility.
3.112 NHS Wandsworth request reference to the need to support future provision for health facilities through planning obligations, stating that as this is included in other policies in the DMPD it should also be included here. Core Strategy Policy IS7 provides the policy basis for S106 obligations, and signals the intent to develop a Community Infrastructure Levy Charging Schedule. IS7 provides a list of physical and social infrastructure that is likely to be funded through planning obligations. This explicitly includes health facilities. Reference to planning obligations has only been included in Policies DMS3 – Sustainable Design and Construction, and DMS6 Sustainable Drainage Systems as these are not specifically referenced in IS7, but come under the umbrella of ‘environmental enhancements’. As Policy IS7 adequately covers the funding of health facilities required to support new development through planning obligations, no changes to policy have been made.
Chapter 7 - Community Facilities
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
NHS Wandsworth 152395 193 Sound.
London Fire and Emergency 53009 194 Not specified. Planning Authority
50 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 8 – Transport
Transport Impacts of Development (DMT1)
3.113 The Port of London Authority is supportive of the encouragement of the use of the river for transportation of construction and demolition materials. UK Power Networks are supportive of Policy DMT1.
3.114 Mrs Patricia Poulter and Mrs Isabel Wooller consider the threshold for submission of transport assessments (TAs) is unusually low, express concern about small scale travel plans (TPs) not being subject to third party monitoring, that the cumulative impact of developments should be assessed and that financial contributions will not increase rail and underground capacity. The thresholds for the assessment of TAs and TPs are in line with Transport for London guidance on TAs and workplace and residential TPs apart from the standard relating to C3 development which has now been updated. No other changes have been made as a result of these representations as the requirement for independent third party monitoring is considered to be appropriate to the scale of development and it would be overly onerous and costly to require this for all developments. Cumulative impacts can also be assessed through TAs and TPs where the requirement to do so has been established at pre planning stage. Financial contributions towards transport improvements can directly increase capacity, by helping to fund longer platforms allowing trains with more carriages and enhanced services.
Parking and Servicing (DMT2)
3.115 Mrs Patricia Poulter and Mrs Isabel Wooller consider it unacceptable to encourage off-street servicing, as it should be required. The current wording of the policy is considered appropriate as while the Council and developers prefer off-street servicing it is not always possible to provide it and some locations a suitable solution can be worked through if carefully designed. Workspace Group Plc support the approach of maximum parking levels, but request greater flexibility for business centres accommodating Small to Medium Enterprises (SMEs). No changes to the threshold have been made, as the standards already take into account business needs and are in line with the Draft Replacement London Plan. AdditionLand and Network Rail Ltd consider that the allocation of parking spaces by tenure should not be a requirement of policy, but should be assessed on a site by site basis. The Preferred Options version of this policy required parking to be allocated proportionate to the tenure split. This was amended in the proposed submission version so that parking spaces are allocated in proportion to estimated demand, taking account of information on relative levels of car ownership. This is considered to be an equitable policy which has been retained in the Submission version.
51 DMPD & SSAD Proposed Submission Statement of Consultation
Transport Infrastructure (DMT3 and DMT4)
3.116 The Port of London Authority welcomes Policy DMT3. REO (Powerstation) Ltd object to the requirement for a riverside walk, stating that the required width should be assessed on a site by site basis. These representations are rejected, as the Council considers the continuous provision of riverside access vitally important to quality of life in the borough and a standard minimum width of 6m for the Thames and 3m for the Wandle has proven to be successful through its implementation in the Unitary Development Plan. Site circumstances are already taken into account in the policy, as an alternative route of equivalent width and equal amenity value around or through a site may be appropriate for safety, operational or nature conservation reasons.
Taxis and private hire (DMT5)
3.117 Mr Peter Carpenter requests a policy to state that taxi ranks in centre street locations will not be permitted. This is unnecessary as new centre street locations would be unlikely to comply with the policies set out in DMT5.
Chapter 8 - Transport
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
DMT1 - Transport impact of development
Mrs Patricia Poulter 396982 20 Not specified
Port of London Authority 1405 31 Sound
Mrs Isabel Wooller 204045 60 Not specified
UK Power Networks (EDF Energy) 1326 191 Sound
DMT2 - Parking and Servicing
Mrs Patricia Poulter 396982 21 Not specified
Mrs Isabel Wooller 204045 61 Not specified
Workspace Group Plc 397170 106 2
Addition Land Ltd and Network Rail 222140 235 2
DMT3 - Riverside walking and cycling routes
52 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 8 - Transport
Port of London Authority 1405 32 Sound
REO (Powerstaton) Ltd 49810 220 Not specified
St James Group 498333 231 Not specified
DMT4 - Land for transport functions
No representations
DMT5 - Taxi and private hire
Mr Peter Carpenter 491438 135 5
53 DMPD & SSAD Proposed Submission Statement of Consultation
Appendices
Appendix 1 Transport Standards
3.118 Refer to comments made in relation to transport policies.
Appendix 2 Proposals
3.119 Port of London Authority point out that that proposal 128. Ready Mix, Vauxhall is incorrect and should be RMC Vauxhall (Middle Wharf). This change has been made. Thames Water object to the Falconbrook Sewage Pumping Station being shown within the York Gardens Larger Protected Open Space (site 106). The Council's response is set out in the Open Space and Natural Environment chapter above.
Appendix 3 Glossary
3.120 No representations.
Appendix 4 Additional town centre boundary changes
3.121 The Putney town centre boundary change to include the whole of the Capsticks site is opposed by Mrs Patricia Poulter, Mrs Isabell Wooller, Mr and Mrs Clive and Gilda Rees, Suzanne Constanti-Taylor, James Taylor and Victoria Diamond who also request the buildings on the south side of Upper Richmond Road to be removed from the town centre boundary. It is acknowledged that Appendix 4 of the proposed submission DMPD should not have referred to the change involving a 'small part' of the site as this factually incorrect. Nevertheless, the justification contained within Appendix 3 still applies. This change reflects the continuation of the town centre boundary south of Upper Richmond Road, and supports the objectives of the site set out in the Site Specific Allocations Document. Hugh and Colleen Samuel request removal of the Sainsbury's site in Werter Road from Putney town centre. The additional boundary changes relating to the south side of Upper Richmond Road and Sainsbury's Werter Road cannot be made this late in the process, and are not supported as the sites currently form part of the active town centre.
3.122 The Clapham Junction town centre boundary change is supported by the Clapham Junction Town Centre Partnership, but opposed by the Wandsworth Society on the basis that this has been done to allow tall buildings in this location. The change has been made to encourage integration of the site into the town centre, by allowing town centre uses along the St John's Hill frontage. The site has been identified as 'sensitive' to tall buildings, with buildings being considered tall at 5 storeys and above.
3.123 The Wandsworth Society also oppose the inclusion of the Territorial Army site within Wandsworth town centre for the same reason while this is supported by Workspace Group. The inclusion of the Territorial Army site has been made for the
54 DMPD & SSAD Proposed Submission Statement of Consultation
reasons set out in Appendix 4 of the proposed submission DMPD, and not to allow tall buildings in this location. The site is identified as sensitive to tall buildings, with buildings of 5 storeys and above considered 'tall' in this location.
DMPD Appendices
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Port of London Authority 1405 33 1, 2
Thames Water 233792 35 2, 3
Mrs Patricia Poulter 396982 6 Not specified
Suzanne Constanti-Taylor 490768 42 Not specified
Mr James Taylor 490769 45 Not specified
Mrs Isabel Wooller 204045 62 Not specified
Clapham Junction Town Centre 1127 140 Not specified Management Office
Wandsworth Society 847 171 1
Hugh and Colleen Samuel 495053 175 Not specified
Mr and Mrs Clive and Gilda Rees 403058 253 Not specified
Victoria Diamond 397038 254 Not specified
Putney Society 802 255 Not specified
Workspace Group 397170 107 Sound
55 DMPD & SSAD Proposed Submission Statement of Consultation
Site Specific Allocations Document
General Comments on the SSAD as a whole
3.124 As set out in relation to the DMPD above, a number of introductory statements providing background to representations have been registered against the whole of the document, but for the purposes of this report, only those representations that relate to the content of the documents are addressed. General support for the SSAD was received from Natural England, English Heritage and Minerva (subject to other detailed reps addressed later in this report). The Coal Authority and the Highways Agency have confirmed they have no comments to make on the document at this stage. Issues with the consultation undertaken, LDF process and online consultation software were raised by a number of residents, including the Putney Society. The Council's response to these comments is set out above in relation to the DMPD.
3.125 Covent Garden Market Authority consider the document unsound as it is not clear what is policy and what is explanatory text. The introduction to the SSAD has been slightly amended to clarify that the design principles present the Council's aspriation for how new development could be carried out to realise the place specific objectives set out in the Core Strategy. The site allocation clearly sets out what each site has been allocated for. Other information contained for each site, such as policy context, PTAL rating etc is all factual information which will assist applicants in preparing schemes and the Council in assessing schemes when they come forward. London Fire and Emergency Planning Authority request addition of the Fire Station at 45 West Hill Road to the SSAD allocated flexibly for continued operation as a Fire Station or mixed use development including residential. This representation is made on the basis that the Council has taken this flexible approach to the Battersea Gasholders site. The Gasholders site has been allocated in this way as it is part of an area of comprehensive redevelopment and intensification but its allocation for residential is dependent on decommissioning of the Gasholder. Community Facilities have only been allocated for alternative uses elsewhere in the plan where the community use has already ceased and/or provided elsewhere or will be reprovided as part of comprehensive development of the site or where there is a clear commitment for this to take place within the plan period. There is currently insufficient evidence to allocate this site for residential however the future use of the site would be considered under Policy DMC2 if it were to come forward for redevelopment and would be acceptable provided tests of policy are passed.
3.126 NHS Wandsworth consider that it is not clear how the vision and proposals set out in Area Spatial Strategies relate and contribute to the overall vision for Wandsworth. NHS Wandsworth suggest that the area strategies link the design principles, issues and requirements of the Core Strategy objectives. It is not considered that the changes are necessary to make the document sound, as the Area Spatial Strategies already include a section on relevant policy considerations which sets the context for cohesive development in these areas.
56 DMPD & SSAD Proposed Submission Statement of Consultation
3.127 The Greater London Authority raise non conformity issues regarding waste. The GLA consider that the waste apportionment has not been clearly met by the allocated waste sites in the SSAD and therefore London Plan Policy 4A.25 has not been met. In order to ensure London's waste self-sufficiency targets are met, Policy 4A.24 of the London Plan requires that all existing waste sites be protected. The GLA identify four sites that they consider should be safeguarded in the SSAD. After meeting with the GLA staff it was considered appropriate to remove the Westminster Transerv site and the Garratt Lane depot site from the SSAD and three of the their four suggested sites were considered to be inappropriate for allocation. One of the sites, 2 Bendon Valley, is considered appropriate and has been included in the SSAD for waste management purposes. An appendix has been added to the SSAD setting out details of the sites safeguarded for waste management purposes and the related waste site selection evidence base document has been updated. A statement of common ground between the GLA and the Council is being prepared which sets out the agreed approach to meeting the waste apportionment figure.
3.128 Reference to consideration of art in the public realm has been added to the area spatial strategies where not already mentioned, to provide consistency throughout the document.
Site Specific Allocations Document
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Coal Authority 169659 5 Not specified
Mrs Patricia Poulter 396982 6 & 145 Not specified
Clapham Junction Action Group 364229 24 1, 2
Victoria Diamond 397038 36 Not specified
English Heritage 1415 98 Not specified
Highways Agency 223757 106 Not specified
Putney Society 802 108 1, 2
Covent Garden Market Authority 491216 135 2
Suzanne Constanti-Taylor 490768 143 Not specified
Mr James Taylor 490769 144 Not specified
57 DMPD & SSAD Proposed Submission Statement of Consultation
Site Specific Allocations Document
Natural England 1240 217 Sound
Minerva 40433 219 Sound
OCS Group UK Limited 495056 250 Not specified
London Fire and Emergency 53009 258 Not specified Planning Authority
NHS Wandsworth 152395 262 Sound
Greater London Authority 1407 299 1, 2, 3
Kent County Council 495470 306 Not specified
Introduction
3.129 Thames Water support reference to water supply and waste water infrastructure as it accords with representations made at preferred options stage.
3.130 National Grid consider that development should not be compromised or prevented from coming forward if a planned district-wide heating and cooling network is not in place. DMPD Policy DMS3 has been amended to take into account the technical feasibility and economic viability of creating new heat networks and this has been reflected throughout the SSAD.
3.131 Wandsworth Society state that while they support infrastructure improvements, their understanding is that they cannot be linked to contributions from specific sites from April 2010 as set out in the SSAD. The CIL regulations and associated changes to S106 planning obligations do change the current approach, however the reference to infrastructure requirements in the SSAD is considered to be consistent with this approach. The Infrastructure sections highlight items of infrastructure that should be considered as part of development proposals on individual sites (this has now been made clear in the Introduction section of the SSAD). Some of these will be site specific and linked to specific developments, in which case contributions towards them could be sought through a S106 agreement. In some cases the infrastructure requirements are on a larger scale and would require either pooled contributions (which are allowed for up to 5 developments) or funded through an Infrastructure Charging Schedule. The detail of this will be provided in a forthcoming Planning Obligations Supplementary Planning Document/Community Infrastructure Levy charging schedule.
58 DMPD & SSAD Proposed Submission Statement of Consultation
Introduction
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Thames Water 233792 80 Sound
National Grid Property 234008 95 Not specified
Wandsworth Society 847 225 Not specified
Chapter 2 - Nine Elms
Area Spatial Strategy for Nine Elms
3.132 The Port of London Authority have questioned the evidence base for suggested use of the the river space area in front of Battersea Power Station for moorings. This is accepted and has been replaced with the suggested passenger pier which has subsequently been approved as part of the application.
3.133 The PLA also question the accuracy of the 'existing riverside walk' as shown on the Area Spatial Strategy which is shown as a continuous line reflecting an existing riverside walk on the two safeguarded wharf sites of Cringle Dock and RMC Battersea (Metro Greenham). They say that this conflicts with the text which states that there will be an opportunity to complete the riverside walk when sites are redeveloped and that any development on the safeguarded wharves should be for cargo handling. It is accepted that the Area Spatial Strategy map is inaccurate but the Council considers the development of a riverside walk to be acceptable as long as it does not conflict with the use of the safeguarded wharf for cargo handling uses. The Area Spatial Strategy map has been amended to change the 'existing riverside walk' line to 'proposed riverside walk.' The associated text in the Area Spatial Strategy has been changed to reflect the non continuous link that exists at present. The appropriate use of the safeguarded wharves has already been established in Core Strategy Policy PL9 and the policy context sections of the wharf sites within the SSAD and it is considered that no change is necessary as this policy which will be taken into account when considering any development of a riverside walk.
59 DMPD & SSAD Proposed Submission Statement of Consultation
3.134 The PLA have also requested that early discussions will be needed with them regarding the proposed bridge over the Thames as referenced in the Area Spatial Strategy and text. It is accepted that discussions are needed and it is the Council's intention to contact the PLA on this matter. The PLA recommend the addition of text for clarification so that short term moorings would not have a detrimental impact on navigation, river regime or the Environment. This is no longer applicable as this area has been removed and is no longer considered appropriate due to the aspirations for the passenger pier. The PLA consider the proximity of the suggested children's play space to the safeguarded wharf is unacceptable due to amenity issues and suggests a reference in the text to highlight that the play space should be designed so that acceptable noise, air quality and lighting levels are experienced at the site. The Council agrees with this point but considers that amenity issues are covered in DMPD Policy DMS1 and would be considered as part of an application.
3.135 National Grid Property consider their site should be included within the area where tall buildings may be appropriate. This is rejected as the site is located outside the focal points of activity and considered likely to be inappropriate for tall buildings in accordance with Core Strategy Policy IS3. National Grid also does not support the 'suggested location for open space' in the centre of their site or the 'suggested primary driving route' which cuts through the site as they state that this is too prescriptive/inappropriate. The Area Specific Spatial Strategy maps are intended to be indicative so the location of routes, open space etc are flexible and subject to negotiation. This is stated in the introduction to the SSAD. Notwithstanding this the Council is supportive of both open space and vehicle access routes within the site to fulfil the wider strategic objectives of the Opportunity Area. National Grid also have concerns over the suggested new route to the Power Station in relation to the physical barrier of the eastern viaduct which could limit vehicular or pedestrian connection. This is one of the aspirations of the Area Spatial Strategy and the Council remains supportive.
3.136 National Grid support the principle of high density residential led mixed use development in the Battersea Parkside District. National grid have a number of concerns relating to flexibility of requirements in determining development and that the viability of development should not be compromised or prevented coming forward as a result of abnormal site costs that have been incurred in bringing sites forward or provision of extra public transport and improved pedestrian and cycling linkages. The ability for sites to accommodate the requirements was fully investigated as part of the DIFS.
3.137 National Grid state that a 1:1 building ratio is limiting and variation in the street enclosure ratio should be applied. This is already considered within the text on page 16 (Streets/street blocks) which states that some variation in the street enclosure will be encouraged, as this will be necessary to allow the occasional creation of focused vistas and the delivery of more generous open spaces associated with the linear park.
60 DMPD & SSAD Proposed Submission Statement of Consultation
3.138 National grid consider that the unacceptability of ground floor podiums may limit the potential of their site given its constrained nature. The Council maintains its position regarding ground floor podiums as stated in the text as being 'not normally acceptable' and any proposals for podiums would need to be justified.
3.139 National Grid considers that an average development height of 8-10 storeys is inappropriate for their site and is contrary to the London View Management Framework. This site is located outside a focal point of activity or a town centre and therefore considered likely to be inappropriate for tall buildings. This approach has been established in Core Strategy Policy IS3. Ballymore also object to maximum upper building heights as not being evidenced by the London View Management Framework and being overly prescriptive in the Area Spatial Strategy. Ballymore suggests adding text stating that any height stipulation represents guidance subject to a site specific assessment against Policy DMS4 of the DMPD and relevant national and regional policy guidance. Kish Six Ltd are supportive of the Council's identification of the site as being located within an area where tall buildings may be appropriate. However they consider that the document should not seek to prescribe specific heights but to leave flexibility for the ultimate height of buildings to be tested through appropriate modelling at the planning application stage. Applications for tall buildings will be assessed in accordance with Policy DMS 4 of the Development Management Policies Document to comply with Core Strategy Policy IS3d and IS3e. The Area Spatial Strategy map does not set design parameters. Specific information relating to design matters are contained within each site within the SSAD. Further detail on the Council's position regarding tall buildings is contained in the Council's response to individual SSAD site in Nine Elms, and the response to DMPD Policy DMS4.
3.140 National Grid support the principle that all pedestrian entrances for developments should be directed on to the street, but they consider access off public squares is also appropriate. This is rejected as no public squares are proposed. National Grid also states that other forms of public realm provision are appropriate other than small forecourt garden spaces and recommend the inclusion of larger landscaped areas. This is rejected as the linear park will fulfil a number of openspace functions as outlined in the text.
3.141 National Grid also have concerns on flexibility as to whether development would be compromised or prevented coming forward if planned district-wide heating or cooling network is not in place. The Council has already stated in the paragraph on Energy and Waste that that where networks do not exist than developments should should make provision to connect to any future network that may be developed. All developments in Nine Elms will be expected to contribute to the creation of a decentralised heating and cooling network. Some flexibility has been provided in DMPD Policy DMS3, where it can be demonstrated that it would not be technically feasible or economically viable to do so.
61 DMPD & SSAD Proposed Submission Statement of Consultation
3.142 National Grid and Addition Land Ltd & Network Rail and Kish Six Ltd object to limiting the provision of retail use on large sites outside the CAZ to 300sqm. The Council's position is reflected in the retail and leisure provision paragraphs. For the reasons stated, retail floorspace of over 300sqm outside the CAZ frontages will be subject to PPS4 sequential and impact testing.
3.143 Whilst supportive of the vision of the Market District, Covent Garden Market Authority have suggested the inclusion of the proposed residential element of their scheme on the western edge of their site to be included within the Thessaly District. This is considered acceptable and the districts map has been altered to reflect this change. Whist supportive of the Vauxhall/Embassy District being suitable for high density mixed use development, CGMA raise concerns over the justification for restricting retail development in the smaller CAZ frontage and request the deletion of the statement regarding the potential for a new large scale supermarket or the existing Sainsburys supermarket on Wandsworth Road. They also want clarification on where this centre will fit in the hierarchy. The smaller CAZ frontage is contained in the OAPF. Anything larger than a local centre would have to take account existing and proposed town centres including the Battersea Power Station Development. The need to provide a school within the Opportunity Area is accepted by CGMA, however clarification is sought on the basis for the proposed location and whether there is scope regarding the location. Royal Mail Group consider that pre application discussions have not been taken into account regarding redevelopment of their site and the site allocation, and that the site and the site allocation, and that the inclusion of the school site will affect the viability of their proposals. Reference to the school site has been amended in the text of the Area Spatial Strategy and individual sites (Market Entrance, Royal Mail Group site and Metropolitan Police warehouse garage) and the precise location will be subject to detailed negotiation with developers.
3.144 CGMA recognise the risks to the delivery of the Northern Line Extension and have requested that further analysis is provided regarding delivery of infrastructure options and priorities for each site in the event that the NLE does not come forward or is delayed. The main site to be significantly impacted by the lack of the Northern Line Extension is the Battersea Power Station site. The OAPF Scenario 3 indicates that a significant quantum of residential development may be supportive as long as the NLE is developed. The Council is determined to ensure the delivery of the Northern Line Extension.
3.145 CGMA have stated that whilst north/south pedestrian linkages are supported in principle, they may be limited by ensuring the continued operation of the Market. The linkages are sought in accordance with the wider aspirations of providing access with in the Opportunity Area to the riverside. Further analysis would be undertaken at application stage to determine whether linkages are achievable.
62 DMPD & SSAD Proposed Submission Statement of Consultation
3.146 CGMA have questioned the status of the proposed road which runs from the Market entrance site, along the railway line to the flower market site and are concerned that additional traffic would effect the viability and function of the operation of the Market. The road is intended to be a suggested primary driving route improving east/west linkages. The map is indicative and further analysis would be undertaken to justify any highway proposals.
3.147 CGMA support the approach to tall buildings at focal points and consider that there maybe opportunities for tall buildings at focal points along the linear park. The Council considers focal points to be areas where tall buildings maybe appropriate, however the focal points have been identified in Core Strategy Policy IS3 and there is no scope to include additional ones at this point in the process.
3.148 CGMA have concerns relating to flexibility over a number of issues including size restrictions for the linear park, location of children's play space, principles of sizes and forms of street blocks, growing place provision, education/primary school location and road locations. Addition Land Ltd & Network Rail also have concerns relating to lack of flexibility regarding street blocks. The Council expects the principles set out in the text to be followed, subject to viability and further analysis at the application stage.
3.149 CGMA consider that the levels of tariff proposed could make development unviable, the assumptions behind the levels need to be tested and an acknowledgement in the text should be added that the full tariff level may not be applicable to the Market site. Likewise, the Royal Mail Group advise that the tariff levels recommended in the DIFS report should be used as a guide for negotiations with developers and that any contribution will be subject to the overall viability and therefore deliverability of any development proposal, taking into account any benefits in kind and any other exceptional costs associated with the specific development. Royal Mail Group also state that the SSAD should recognise that any contributions sought will have to comply with all of the five tests set out within Government guidance Circular 05/05. As the ASS indicates, the tariff will be used as a guide and there are issues with the Market site. As indicated, the Council is intending to change the tariff to CIL and this viability will be tested through the CIL examination process. As from April 2010 three tests apply to developments that are not capable of being charged CIL.
3.150 Whilst supporting the need for community facilities, the Metropolitan Police Authority recommends the inclusion of a requirement to mitigate the impact of the development proposed in the Opportunity Area on Policing. The police infrastructure requirements have been included in the DIFS study. The Study considered that one Neighbourhood Team Base and one Transport Team base plus contribution towards the costs of the proposed Wandsworth Custody Centre and potentially a new patrol base will be required to support proposed growth. The assessment uses the proposed number of dwellings and commercial floorspace to derive a need, based on the average
63 DMPD & SSAD Proposed Submission Statement of Consultation
size of a police base and the standard number of officers required, as well as the overall impact of the increase in population will have on policing and custody requirements in the wider area.
3.151 Royal Mail Group Limited support the vision for the Nine Elms Parkside area however, clarification is requested regarding the location, size and possible layout of the school facility that is proposed. As well as Royal Mail Group, REO also state that the proposed school facility requirement is inconsistent with the findings of the DIFS study. The DIFS study recommends that six forms of primary school entry are required to support the growth in the VNEB area, two of which will be located in Lambeth and four in Wandsworth. No change is required as the text states that one state sector four form entry primary school is required.
3.152 Royal Mail Group also consider that their site is suitable for tall buildings and that the Nine Elms focal point should be extended to include the site. They propose changes to the text to reflect this change. This site is located outside a focal point of activity or a town centre and therefore considered likely to be inappropriate for tall buildings. This approach has been established in Core Strategy Policy IS3.
3.153 Royal Mail Group welcomes the text recognising that the need to maximise contributions from developments towards transport and infrastructure, is likely to result in a much lower level of affordable housing provision than set out in borough and Mayoral policy generally.
3.154 The London Borough of Lambeth consider that the Area Spatial Strategy is not justified, is based on lack of acknowledgement of the scale and form of development required, including employment levels and how this will be phased, delivered and managed. They also question the level of detail provided regarding the mechanisms for delivery on public transport provision, and more specifically community facilities and primary school provision. They also request that the provision for training and skills should be outlined in the Area Spatial Strategy and that contributions from developers will be sought for this through s106 agreements. Further consideration of a range of buildings and mix of building heights is also requested so that a continuum of buildings of 11 storeys is avoided. The London Borough of Lambeth also would like to see included an indication of where affordable housing is preferred and should be located. The design principles section for each site provides specific details on street blocks and public realm. It is the intension of the Council not to create canyon like development as stated in the paragraph relating to streets/street blocks. Further work on the delivery of public transport provision and phasing is being taken forward by the VNEB strategy board. The details of school provision are set out in the DIFS. The precise location will be subject to detailed negotiation with developers. It is accepted that a range of building heights may be appropriate and wording has been added to the text to reflect this recognition. The suggestion requesting an indication of where affordable housing is preffered is rejected as the delivery timetable for Nine Elms spans a period of at least
64 DMPD & SSAD Proposed Submission Statement of Consultation
20 years, and economic conditions are likely to change over this period. Therefore the approach taken is to regularly review the funding requirements and minimum level of affordable housing which is expected to be viable.
3.155 Ballymore consider that the reference of 'up to 16,000 new homes and 20,000 new jobs over a period of up to 20 years' contradicts the findings of the OAPF. The text has been amended to reflect the projections of the Wandsworth Area of the Opportunity Area. Table 1 has been updated to reflect revised population projections. The estimates of the future population are now based on constraining the number of units in the Opportunity Area as a whole to 16,000. This reflects the level of development tested in the DIFS study. Ballymore are also concerned with the specific reference to being unnecessarily prescriptive regarding the enclosure ratio, specified/permeable routes, width of the linear park, upper retail floorspace limits of 300sqm which they say may compromise delivery. The reference to enclosure ratio, routes, width of the linear park are all guidelines which the Council has proposed to be followed subject to detailed negotiation with developers. The retail floorspace concern has been considered and the wording has been amended to state that proposals for retail provision of over 300ms outside the potential CAZ frontages will be subject to PPS4 sequential and impact testing.
3.156 NHS Wandsworth welcome the commitment of collaborative working. They suggest additional emphasis on the implications for healthcare services and an assessment of current capacity. The Council will continue to work with NHS Wandsworth to identify funding and delivery opportunities and further detail will be set out in the section 106 agreement/planning obligations SPD/CIL charging schedule. The opening paragraph on Community Facilities places emphasis on supporting the needs of the population via the provision of community facilities including health infrastructure.
3.157 REO considers that the Area Spatial Strategy Diagram appears to specifically locate community facilities within a single development block and does not allow for future flexibility, contrary to the sufficient flexibility of the associated text on page 19. The Area Spatial Strategy Maps are indicative but have been amended to reflect s106 discussions. As previously stated, reference to the school site has been amended in the text and the precise location will be subject to detailed negotiation with developers.
3.158 REO also suggest including the designation of CAZ Frontage at the Battersea Power Station Site. This is rejected as the CAZ frontage boundary is not specifically identified and so is stated as being 'potential'.
3.159 REO suggest adding wording to the vision for Nine Elms to include provision of a new tube station as part of the proposed Northern Line Extension. This is rejected as the introduction to the Access section and the transport links map recognises the requirement for the new tube station.
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3.160 REO suggest changes to the wording regarding the linear park within the design principles section. The changes relate to the consideration of feasibility suggesting that ownership of the linear park by the Council may not be appropriate or necessary in all cases. REO also suggest that the width of the linear park should be subject to site specific constraints as some sites have a wider range of development constraints than others. The reference to Council ownership has been removed and the text has been amended to state that maintenance agreements will be detailed in planning obligation agreements negotiated on individual sites. The linear park suggestion is rejected as although it is recognised in the ASS that the 50m width may not be possible to achieve. The ASS states that within individual sites the linear park should have an average width of at least 40m and an absolute minimum width of 30m should be provided subject to the minimum width extending for a maximum length of 50m in any single stretch. The Council expects the principles set out in the text to be followed, subject to viability and further analysis at the application stage. Kish Six Ltd are supportive the overall concept of the linear park but with the proviso that the Area Spatial Strategy is changed as they do not consider that such a continuation of the linear park into the Vauxhall gyratory area is appropriate, justified, desirable or commercially deliverable. The alignment of the linear park has been amended to provide access onto Wandsworth Road through the flower market site. This has been reflected on the Area Spatial Strategy map. REO have also suggested that the proposed library, emergency services premises, and police offices be considered to be located adjacent to the Battersea Power Station CAZ frontage rather than the current wording which considers location of community services within the CAZ frontage. The location of the community facilities is yet to be determined and the wording of the Area Spatial Strategy has been amended to state that the facilities should be provided within or adjacent to the CAZ frontage at Battersea Power Station.
3.161 Addition Land Ltd and Network Rail seek amended wording to consider a degree of flexibility in the requirement for seeking a planning obligation or providing a lower proportion of affordable housing where contributions have been made for public transport. As is stated, this is the starting point in negotiations but if the level of funding for the level of infrastructure needed is not provided then the Council cannot support the proposal. Addition Land Ltd and Network Rail also request flexibility over potential office development in the Opportunity Area. They seek amendments to remove reference to support for smaller scale office developments at ground and lower ground and instead refer to general support for such uses. This comment is rejected as this part of the Opportunity Area is located outside town centres and therefore general support for offices is not considered appropriate unless are ground/lower floor use.
3.162 Addition Land Ltd and Network Rail propose that reference should be made in the paragraph to the role 'other' sites (meaning those other than Battersea Power Station, New Covent Garden Market and the US Embassy) within the Nine Elms and North East Battersea area will play in its regeneration. These three sites have been highlighted in the context as the sites which could act as a catalyst for regeneration. All major sites within the Opportunity Area are included in the SSAD and have been considered in the DIFS.
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3.163 Kish Six Ltd seek flexibility on stated proposed uses and recognition that such uses would be dependent on market testing. Further flexibility is also sought on access arrangements to street frontages so that wording is added to the text to encourage the location of entrances on the street frontage, but only where practical. This is not accepted as the text already gives an appropriate range of flexibility. Access arrangements to street frontages will be subject to detailed discussion at the planning application stage.
3.164 The Greater London Authority have made a number of suggested text changes concerning infrastructure level, density and tall buildings in the Opportunity Area within the Design Principles section of the Area Spatial Strategy. The Council have accepted these changes and amended the text as suggested. The GLA also propose making changes to the wording in the text for individual sites regarding the classification of the appropriateness for tall buildings. These proposed changes are rejected as the designations are in accordance with Core Strategy Policy IS3 which sets out which areas are considered appropriate for tall buildings. Reference to the Area Spatial Strategy has been included for all sites outside focal points, where tall buildings are likely to be considered inappropriate.
3.165 Anastasia Limited request that the suggested building frontages are removed from the Area Spatial Strategy diagram as they are overly prescriptive. The building frontages are indicative and subject to detailed negotiation with developers at the application so no change is necessary.
3.166 Reference to green/living roofs has now been included in the Area Spatial Strategy to reflect the the potential of the area for delivering green and living roofs reflecting DMPD Policy DMS3 and work on the All London Green Grid.
Sites
3.167 To be consistent with Policy 4C.9 of the London Plan, the Port of London Authority seek a change in the streets and access paragraph of the Battersea Power Station site, US Embassy, Main Ballymore site, Royal Mail Group site, Tideway Industrial Estate, RMC Vauxhall and new Covent Garden Market to further recognise access to the safeguarded wharves. Similarly, for the infrastructure paragraph the PLA seek changes to the text to more accurately reflect Policy 4C.9 of the London Plan. The PLA also seek a reference to the proposed passenger pier within the Design Principles paragraph and inclusion of the pier as part of the Area Spatial Strategy map. The PLA also seek reference to safeguarded wharves in respect of their role in cargo handling and the need to minimise conflicts of use and disturbance in the text for the Depot, Kirtling Street, Warehouse, 88 Kirtling Street, Tideway Industrial Estate, Cable and Wireless Site, Securicor site, Royal Mail Group site and New Covent Garden market sites. The Greater London Authority also seek to ensure that redevelopment at 88 Kirtling Street does not adversely impact the RMC Battersea working wharf. It is considered that sufficient protection for the working wharves has been established in
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the Core Strategy Policy PL9 and no further changes are needed. The sites located adjacent to the Safeguarded Wharves (Battersea Power Station/Warehouse, 88 Kirtling Street, Tideway Industrial Estate and Securicor Site 80 Kirtling Street) have acknowledged that their function must not be prejudiced by any development. The passenger pier has been included in the Area Spatial Strategy map and referenced in the text of the strategy and individual site. The PLA request changes to the text for Cringle Dock and RMC Battersea to acknowledge that the two sites are separate working wharves. It is recognised the sites are distinct and they have separate site allocations. They also request that the area for RMC Battersea (Metro Greenham) should be amended to 0.68ha, RMC Vauxhall to 0.1ha and it's current use amended to state that it was previously an aggregates wharf and is currently in Thames Water use/ownership. It is accepted that the site area and use should be amended and this has been reflected in the text. The PLA also request clarification with regard to the ambitions for the dock area at Tideway Industrial Estate. Clarification has been added to the text to state that the suggested public space is adjacent to the dock.
3.168 Thames Water have set out which sites conflict with their proposals for the Thames Tunnel project and have stated that for the SSAD to be found sound and legally compliant, reference should be made in support for the principle of the Thames Tunnel and this should be reflected in all site allocations that correspond to Thames Water's identified preferred and shortlisted sites under consideration. Core Strategy Policy IS6 states that the Council will work with Thames water to support the implementation of the tunnel. However, after having scrutinised their Phase 1 consultation report, it became apparent that there are elements of the project that the Council had to oppose. The Council has submitted it's representation as agreed on the 18th January at the Strategic Planning and Transportation Overview and Scrutiny Committee. Whilst recognising the need for investment in the capital's sewage system and the benefits of improved water quality in the Thames, the response challenges the need for six sites and registers serious reservations about the huge financial and environmental cost of the Thames Tunnel scheme. The full response can be viewed in the appendix to Strategic Planning and Transportation Overview and Scrutiny Committee paper 11-112.
3.169 In response to Thames Water's concerns text has been added to the introduction of the SSAD to state the context of the project and that the Council is working with Thames Water to deliver a scheme which is considered acceptable by the Council. As part of this process local matters such as design, construction, traffic management, remediation and mitigation will need to be resolved. For each of the sites affected by Thames Water's preferred or short listed sites, reference has been made to the site being subject to consultation and is currently under review as an option to be considered for part of the Thames Tunnel development.
3.170 St James Group object to the allocation of the Heathwall pumping station as a part of the Thames Tunnel project and suggest the reference is premature. The Heathwall Pumping Station is owned by Thames Water who requested the site be added including reference that the site forms part of their formal consultation.
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3.171 In relation to the Battersea Gasholder site, National grid support the site allocation as being suitable for mixed use development including residential. National Grid have provided an updated site boundary to replace the individual site map and have provided clarification that the south east corner of the site is currently in charitable use. The map and text has been amended in response to this request. Whilst noting the opportunity to improve the pedestrian links across the site between Battersea Park and Battersea Power Station, National Grid state impracticalities of providing pedestrian and cycle access due to the presence of railway lines at different heights. As a result National Grid have requested that if links cannot be created this should not prevent the site from coming forward for development. The Council accepts this position but the allocation's text is an indication of the Councils preferred approach and accepts that through the application process such matters are negotiated and therefore would not prevent the site from coming forward. Each diagram and associated text represents the aspirations for how new development could be linked and accessed to realise the place specific objectives set out in the Core Strategy.
3.172 National Grid considers the word 'preferred' should be used in place of 'required' in the sentence regarding a built frontage along the Prince of Wales Drive. The Council expects the principles set out in the text to be followed, subject to viability and further analysis at the application stage and therefore considers the existing text to be appropriate. National Grid also seek acknowledgement that any delays in improvements to the urban boulevard cannot prevent sites coming forward for development and that this should be an aspiration rather than a requirement. Again, the details of the delivery of the urban boulevard are subject to viability and further analysis at application stage. Similarly, the same request has been made for the Council to adopt a flexible approach regarding meeting infrastructure requirements, and the same approach is considered applicable.
3.173 REO propose a change to the relevant planning history paragraph regarding an updated position for the Battersea Power Station site. This is considered acceptable and has been amended. REO also request a change to the site allocation to include reference to the site providing a new tube station. This is accepted and wording has been included to reflect this change. A request is also made to remove the text in the tall buildings section regarding the height in metres and storeys which REO feel is inaccurate and unnecessary. This is not accepted as the height up to the base of the chimneys is shown in the drawing submitted with the Battersea Planning Application to be an elevation of approximately up to 53 metres. This equates to approximately 17 storeys using the assumption that an average storey height is of 3 metres set out in the context to DMPD Policy DMS4.
3.174 REO propose a change in the text regarding subjecting the linear park to site specific constraints. This is rejected as the Council expects the principles set out in the text to be followed, subject to viability and further analysis at the application stage. REO also suggest changing the text regarding hazard zones. This is considered
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acceptable and the text has been amended to reflect National Grid's position that winter testing is currently underway to see if the gas network can cope without the gasholders with a view to decommissioning.
3.175 REO seek additional wording in relation to the infrastructure section on safeguarded wharves. The response proposes that adjacent development to safeguarded wharves will be subject to appropriate design and mitigation; collaborative working with wharf owners; operators should employ up to date modern practises and machinery and potential to reconfigure wharves as recognised in the OAPF. The principle of this is accepted and the Council would provide support on any discussions regarding possible reconfiguration but no change in the text is considered necessary as is considered not to be a planning matter.
3.176 Kish Six Ltd support the designation for Market Towers as potentially appropriate for tall buildings, but request that suggested maximum heights are not imposed and are allowed to be tested through the planning application process. No changes are necessary, as the suggested maximum heights that were proposed in the preferred options SSAD were removed at proposed submission stage. This site is identified as appropriate for tall buildings, and any building of 11 storeys and above would be assessed against the detailed criteria in DMPD Policy DMS4.
3.177 Anastasia Limited request that the height at which a building on the Marco Polo House site is considered tall should be raised. St James Group also oppose the principle that tall buildings on Tideway Industrial Estate are inappropriate and state that the building heights are overly prescriptive. Kent County Council do not consider there is sufficient justification to restrict tall buildings on the Booker Cash & Carry site and 49-59 Battersea Park Road. The Sleaford Street Management Company make the same comment in regard to the Sleaford Street site. Royal Mail Group also object to the restriction of tall buildings on the Royal Mail Group site. REO request that the text is amended to refer to an 'assessment against the criteria' in DMPD Policy DMS4 for assessing suitability of tall buildings for the Depot, Kirtling Street and Former filling station, 2 Battersea Park Road, Warehouse, 88 Kirtling Street.
3.178 All of these representations seek to remove restrictions on tall buildings in Nine Elms on sites identified as 'likely to be inappropriate for tall buildings'. The Council's justification for tall buildings policy is contained in the Stage 2 Urban Design Study - Tall Buildings (S2UDS). In summary, a key principle of the VNEB OA is that the supported form of development will be 8-10 storey high development with tall buildings on key sites (at either ends of Nine Elms in focal points of activity). In the remainder of Nine Elms, it is considered that in order to accommodate the scale of development anticipated, taller buildings than the predominantly low rise residential nature of the rest of the borough will be required. Therefore, within these areas, buildings of 11 storeys and above will be considered tall, and will be subject to detailed assessment against DMPD Policy DMS4. The Development Infrastructure Funding Study has also been prepared on this basis that buildings will be predominantly 8-10 storeys throughout Nine Elms,
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and taller buildings could give rise to a significantly higher number of new residential properties in the area, meaning that the infrastructure requirements of higher dwellings numbers would have not been assessed. To take account of this the Area Spatial Strategy for Nine Elms has been amended to state that on the basis of Core Strategy Policy, development proposals which include a variety of building heights may be appropriate and would add variety to the structure of townscape and that where these include proposals for buildings of 11 storeys or above, the developer to demonstrate a rationale for tall buildings as required by DMPD Policy DMS4, and these would need to be balanced out by lower forms of development elsewhere. Reference to this wording has been made on all sites in Nine Elms outside focal points of activity (where tall buildings are likely to be considered inappropriate). Further detail on the Council's position regarding tall buildings is contained in the response to DMPD Policy DMS4.
3.179 Anastasia Limited request a change to the Site Allocation for Marco Polo House to 'residential-led development including a mix of uses' as they do not think the site is suitable for significant employment floorspace. This is rejected as the site is located within the Thames Policy Area and DMPD Policy DMI3 applies, protecting B1-B8 floorspace. However, the context to DMI3 has been amended to state that within the VNEB OA, the strategic objectives for Nine Elms will be a key consideration, and flexibility in the application of Policy DMI3 will be applied.
3.180 Anastasia Limited also raise concerns over the 'mansion block' concept of the design principles for the site as they feel this is overly prescriptive and potentially out of context with the surrounding new developments. This is rejected as the text sets out the Councils aspirations and the detailed design arrangements will be subject to detailed discussion at the planning application stage.
3.181 Anastasia Limited consider that the wording of the text relating to infrastructure for the Marco Polo House site pre-determines the outcome of any S106 requirement that might be required and is therefore unsound in relation to the tests of 05/05. This is rejected as the infrastructure section contains the Council's aspiration and the DIFS will be used to inform the level of funding required and any Planning Obligations will be sought in accordance with the tests contained within Circular 05/05.
3.182 St James Group object to the reference to the Council's guidelines for the Thames path as overly prescriptive for the Tideway Industrial Estate site. This is rejected as the incorporation of a riverside walk is required in accordance with DMPD Policy DMT3.
3.183 Kish Six Ltd request amendments to the proposals for the linear park in relation to the Market Towers site as they feel current proposals cover too large a proportion of developable land at the site. Kish Six Ltd also request that hotel use should be included in the site designation as a potential appropriate use and object to overly specific references to residential entrance points. In reference to potential retail provision at Market Towers, Kish Six Ltd request flexibility on the size of units. CGMA object to
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retail floorspace limits for the NCGM Flower Market site on the grounds of insufficient justification. The alignment of the linear park has been amended to provide access onto Wandsworth Road through the flower market site. This has been reflected on the Area Spatial Strategy map. The Council considers it unnecessary to include reference to hotel development in the site allocation as hotel development is considered appropriate to the Opportunity Area in accordance with DMPD Policy DMTS12. The references in the text concerning residential entrance points are aspirational and the detailed design arrangements will be subject to detailed discussion at the planning application stage. The retail floorspace concern has been considered and the wording has been amended to state that proposals for retail provision of over 300ms outside the potential CAZ frontages will be subject to PPS4 sequential and impact testing.
3.184 Kent County Council are supportive of the mixed-use designation for the Booker Cash and Carry site and 49-59 Battersea Park Road site. However they object the amount of land from the Booker Cash and Carry site that would be required to facilitate the proposed green link. Ballymore Group and Royal Mail Group also object to prescriptive width requirements for the proposed linear park in respect of the Main Ballymore site and Royal Mail Group site respectively. Kent County Council are also concerned that development of neighbouring sites, in particular New Covent Garden Market, could cause access and amenity problems which have not been properly considered. The concern over the linear park is rejected as although it is recognised that the 50m width may not be possible to achieve the Council expects the principles set out in the text to be followed, subject to viability and further analysis at the application stage. Likewise the concern over access and amenity will be subject to further analysis at the application stage in accordance with DMPD Policy DMS1.
3.185 The Sleaford Street Management Company support the removal of a reference to social infrastructure provision for the Sleaford Street site. They also request that the site designation is amended to mainly residential use with limited commercial space. This is considered unacceptable as further detailed detailed negotiation will take place at the application stage. Employment floorspace is required in accordance with Core Strategy Policies PL6 and PL11. Sleaford Street Management Company consider that there is not a sound justification for the proposed layouts and access routes, and object to the development density being linked to existing PTAL ratings. The Council expects the principles set out in the text to be followed, subject to viability and further analysis at the application stage. Likewise the concern over access and amenity will be subject to further analysis at the application stage in accordance with DMPD Policy DMS1. PTAL ratings would always be confirmed at the time an application is submitted as set out in the introduction.
3.186 The Metropolitan Police Service object to a change in designation for the Police Warehouse Garage from the preferred options version of the SSAD to include more specific requirements for a primary school and sports pitches and request this allocation is removed and replaced with a less-specific mixed use allocation. NCGM also oppose provision of a primary school on the NCGM Entrance site due to uncertainty arising
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from different site ownerships for the proposed location and state that this provision, coupled with route and access requirements would impact on the viability of the redevelopment. These points are rejected as the precise location of the school, whilst proposed for this area, will be subject to detailed negotiation with developers.
3.187 Covent Garden Market Authority request clarification on contributions to infrastructure with regard to the re-provision of market floorspace for the New Covent Garden Market (NCGM) site. As the Area Spatial Strategy indicates, the tariff will be used as a guide for infrastructre contributions and there are issues with the Market site. As indicated, the Council is intending to change the tariff to CIL and this viability will be tested through the CIL examination process. Given the delivery timetable spanning 20 years or more, the funding requirements, related tariff/charging schedule and level of affordable housing to be provided will need to be regularly reviewed. Network Rail support the principle of opening up of the railway arches at New Covent Garden Market. NCGA also support this with some caveats.
3.188 St James Group object to the removal of the preferred option of residential-led mixed-use development from the NCGM site. At preferred options stage, the three CGM sites had not been separated, so that aspirations for the market site, entrance site and flower market sites were all contained within the one allocation. The sites have now been separated and the site allocations amended accordingly. Residential-led mixed use development applies to the entrance and flower market sites, whilst the site allocation for the main market site remains the retention, consolidation and intensification of the wholesale market as supported in the Core Strategy.
3.189 The Battersea Society raise concern about the lack of reference to 177-179 Battersea Park Road, as they are positive buildings within the conservation area. This is accepted and the text in the historic environment section has been amended accordingly. It has also been clarified that the railway bridge, proposed for inclusion in the local list at proposed submission stage, has now been added to the list.
3.190 Additon Land Ltd & Network Rail request that the site description for Patcham Terrace is amended to include reference to light industrial as well as office use. This is considered unnecessary as Core Strategy Policy PL6 seeks new employment floorspace including office development as part of mixed use development within this area. Light industrial development is not sought outside the designated industrial locations, however if an application for this type of use was proposed then it would be considered in accordance with Core Strategy Policy PL11 and the Area Spatial Strategy for Nine Elms.
3.191 Network rail request the site allocation for Silverthorne Road is amended to remove the parcel of railway operational land facing Dickens Street from the area of developable land and to include B8 as an appropriate use to ensure flexibility. This is accepted and has been removed from all of the maps concerned.
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3.192 Network Rail also object to the waste management allocation for the Westminster Transerv site, requesting that flexibility to include B2 and B8 uses should also be considered acceptable. The Westminster Transerv site has been removed from the SSAD. After detailed discussions with the GLA the Council considers that the site is no longer needed as a waste management site.
3.193 Network Rail object to the principle of a new link road from Battersea Park Road into the Westminster Transerv site for funding and safety reasons and request this is removed from the allocation. The new route has been suggested in the Stewarts Road Study. The link is indicative and subject to further negotiation with developers.
Chapter 2 - Nine Elms
Representor Representor Representation Soundness reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Area Spatial Strategy for Nine Elms
Port of London Authority (2) 1405 38 & 39 1, 3 and 1,2
National Grid 234008 96 Not specified
Covent Garden Market Authority 491216 136 1
Metropolitan Police Service (2) 220011 187 & 196 Not Specified
Royal Mail Group Limited 494648 199 1,3
London Borough of Lambeth (2) 1001 228 & 236 1, 2 and 3
Ballymore 366691 260 1, 2 and 3
NHS Wandsworth 152395 263 Sound
REO (Powerstation) Ltd 49810 269 Not Specified
Addition Land Ltd & Network Rail (5) 222140 290-292, 294 & 2 and not specified. 295
Kish Six Ltd 393084 297 Not Specified
Sites
Port of London Authority (13) 1405 40-52 1, 3
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Chapter 2 - Nine Elms
Thames Water (8) 233792 81-88 1, 2 and 3
National Grid Property 234008 97 Not Specified
REO (Powerstation) Ltd (4) 49810 279-282 Not Specified
Network Rail (5) 491077 107, 127, 128, Sound, 2 and 3 130, 131
Anastasia Limited (5) 38522 180-184 1, 2 and 3
Greater London Authority 1407 301 Not Specified
St James Group (3) 495333 270-272 Not Specified
Kish Six Ltd 383084 298 Not Specified
Kent County Council 495470 283 & 284 Not Specified
Sleaford Street Management 401115 268 1, 2 and 3 Company
Ballymore Group 366691 261 1 and 3
Royal Mail Group Limited 494648 200 1 and 2
Metropolitan Police Service 220011 188 1 and 2
Covent Garden Market Authority (3) 491216 137-139 1
Battersea Society 999 194 Not Specified
Addition Land Ltd & Network Rail 222140 293 Not Specified
Chapter 3 - Central Wandsworth and the Wandle Delta
Area Spatial Strategy for Central Wandsworth
3.194 Mr Ralph is supportive of the Area Spatial Strategy for Central Wandsworth. Minerva are also supportive, but seek inclusion of the town centre boundary on the Area Spatial Strategy diagram, and flexibility in the text to explain that the diagram represents a possible solution in relation to site layout and public space and not a definitive solution. The town centre boundary has been included on the Area Spatial Strategy for Central Wandsworth and the Area Spatial Strategies for Clapham Junction and Putney for consistency. The introduction to the SSAD already states that the maps and diagrams in relation to SSAD sites are indicative, but a minor change has been made also to state that 'each diagram and associated text represents the aspirations for how new development could be linked and accessed to realise the place specific
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objectives set out in the Core Strategy'.The Wandsworth Society quote references from the Stage 2 Urban Design Study - Tall buildings, however it is not clear what changes have been requested in relation to this. NHS Wandsworth query what the implications of additional homes in Central Wandsworth will be on social infrastructure. The Core Strategy sets out an infrastructure delivery schedule at Appendix 1 and Policy IS7 of the Core Strategy IS7 commits the Council to the preparation of a Planning Obligations SPD/CIL charging schedule, which will set out more information on infrastructure requirements to support development in Wandsworth, and how this will be funded. The Council will liaise with NHS Wandsworth in the preparation of this document. NHS Wandsworth also state that no figures are set out for the number of homes to be provided in the Wandle Delta. The text in the Area Spatial Strategy for Wandle Delta, land north of the railway has been amended to clarify that the target of 2,000 new homes applies to Central Wandsworth and the Wandle Delta collectively.
Sites
3.195 Workspace Group welcome and support the identification of the former Wandsworth Business Village and Territorial Army site within the Site Specific Allocations Document however the identification of the Territorial Army site as inappropriate for tall buildings is opposed, and reference to Planning Obligations having to accord to Circular 05/2005 is sought. As mentioned in response to similar representations, the Introduction to the SSAD has been updated to state that any Planning Obligations will be sought in accordance with the Circular. It is considered acceptable to change the Territorial Army site from 'inappropriate' to 'sensitive' as the strip of 'inappropriate' bordering the Business Village/Cockpen House site correlates with proximity to the Conservation Area. There is also an opportunity to incorporate the site into the adjoining Business Village site and achieve a comprehensive redevelopment including access improvements as a result. The 5 storey height at which a building will be considered 'tall' is still considered to be appropriate. Map A2 and the associated text in the tall building section of the Wandsworth business village site has been updated to reflect this change.
3.196 Wandsworth Society state a building should be considered tall at 5 storeys rather than 9 storeys on the Cockpen House site as it is closer to King Georges Park MOL and has lower existing hinterland buildings. This is rejected as the characterisation of building height in the area (taking into account the taller buildings at Southside as well as the lower hinterland buildings) justifies a height of 9 storeys in this location.
3.197 Minerva oppose the identification of the whole of the Ram Brewery site as sensitive to tall buildings on the basis that the conservation area has many distinct sub-areas of which the Ram Brewery is one and they consider the majority of this sub area is not of a character that is sensitive to tall buildings. This is not accepted as the whole of the site is within a Conservation Area and contains listed buildings and it would not therefore be appropriate to identify the site as suitable for tall buildings, taking into account these sensitivities. Wandsworth Society consider that the identified heights of
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5, 8 and 12 storeys (south to north) are unjustified when looking at the local context. It is accepted that the heights should be 5 storeys overall and Map A2 and the associated text in the tall building section of the Ram Brewery site has been updated to reflect this change. The GLA consider the requirements for the site should include specific reference to the need to restore/naturalise the river corridor through the site. This is accepted and the text has been modified to acknowledge restoration of the river corridor.
Area Spatial Strategy for Land between Armoury Way and the Railway
3.198 The PLA request early discussions with the Council regarding the new bridge crossing referred to in the Area Spatial Strategy, to ensure that anything proposed is suitable in terms of navigation, river regime and the environment. The Council would always consult the PLA on such matters and it is not considered necessary to refer to this in the text.
3.199 Tesco Stores Ltd consider the Area Spatial Strategy is not justified, effective or consistent with National Policy. Tesco oppose the land uses identified for the Hunts Trucks site, stating that although it is within a Locally Significant Industrial Area (LSIA), it forms a logical extension to Wandsworth Town Centre and therefore town centre uses should be appropriate to regenerate the area. The approach to the protection of Strategic Industrial Locations and LSIAs is established through adopted Core Strategy Policies PL6 and PL7, which make it clear that these areas form the strategic reservoir for industry and waste management in the borough. As such, town centre uses are inappropriate as they would erode the stock of land for industry, logistics and waste, and introduce uses which are potentially incompatible with heavy industrial activity. Tesco also oppose the identification of part of this site for road widening/realignment, in the event the one way system is removed. Tesco consider this approach is unjustified and unacceptably blights the site/area. Transport for London (TfL) and Wandsworth Council have investigated the feasibility of removing the Wandsworth One-way System and believe there to be a workable scheme, subject to detailed design and consultation. This would seek to restrict Wandsworth High Street to buses only and local access traffic with west bound traffic being re-routed via Armoury Way. If a scheme is approved and taken forward to implementation it is expected to require a significant part of the southern end of the site as Armoury Way is widened and realigned to the north of its current route. The progression of a detailed design for the scheme is dependent upon the redevelopment of the nearby Ram Brewery site. The scheme is not currently identified in the TfL business plan, but would be funded through Section 106 payments or via the Community Infrastructure Levy. The road alignment has therefore been retained on the Area Spatial Strategy diagram and the updated position reflected in the text of the Hunts Trucks site.
3.200 Tesco also state that the design principles are considered to be overly prescriptive. As explained above, the Introduction to the SSAD has been slightly amended to clarify that the design principles are not definitive but are to be used as a guide. Wandsworth Society quote Core Strategy policies that relate to the area, but it is not
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clear what changes are sought in relation to this. UK Power Networks (EDF Energy) support the allocation of the sites for redevelopment and the proposal to create links between the town centre, the Thames riverside and the River Wandle, however, reference to S106 Planning Obligations being related to Circular 05/2005 is sought. As explained above, the introduction to the SSAD has been updated to state that Planning Obligations will be sought in accordance with the Circular. Reference to the feasibility and viability of development is sought in relation to the provision of infrastructure (such as riverbank improvements) and connection to decentralised energy networks. As a result of changes described above and in relation to the DMPD policies, both areas will be sufficiently flexible, as the Introduction acknowledges that the Area Spatial Strategies and associated text are to be used as a guide and the section on decentralised energy networks states that connections will be expected "unless demonstrated unfeasible". UK Power Networks support the identification of site 3.3.7 for mixed use development including residential, but consider the 'existing route' section of the Area Spatial Strategy should be updated to reflect the allocation for this site. This is accepted and the text has been updated to recognise the development potential of the site.
Sites
3.201 The PLA make the same comment as above regarding early discussions about any future bridge crossing at Causeway Island/Keltbray site.
3.202 The Wandsworth Society consider the level at which a building is considered tall at Causeway Island should be lowered from 5 to 3. Tesco Stores Ltd make the same comments as set out above in relation to the Hunts Trucks site and Wandsworth Society consider a building should be tall at 3 storeys on the site. At the Keltbray site, the Wandsworth Society consider a building should be tall at 4 storeys. It is not accepted that buildings of 3 and 4 storeys in this location would be tall (i.e. Would be substantially taller than the prevailing height of neighbouring buildings and/or would significantly change the skyline).
Area Spatial Strategy for Wandle Delta, land north of the Railway
3.203 PLA request the addition of the Western Riverside Waste Transfer station on the diagram and amendment to the wording that relates to the safeguarded wharf so that it more closely aligns with the requirements of the London Plan. It is considered that the text adequately reflects the requirements of the London Plan and no changes to the text are considered necessary. The diagram has been amended to include the safegurded wharf. The PLA also question why an area of open space extends out over the water. This has been corrected on the plan and no longer extends over the water.
3.204 The Wandsworth Society consider the Core Strategy intention to form a new focal point at the Wandle Delta is inherently flawed as the area does not have good road and public-transport connections. The Wandsworth Society consider that Council owned undeveloped sites in the area should not be urbanised, if environmental and
78 DMPD & SSAD Proposed Submission Statement of Consultation
recreational improvements along the River Wandle are to be effective and achievable. The location of focal points is set out in the Core Strategy, and cannot be changed through the DMPD and SSAD. No changes are considered necessary as where development is proposed at the Causeway Island and Feather's Wharf sites, open space will be required as shown on the diagram with requirements for environmental enhancements set out for each site.
3.205 NHS Wandsworth make the same comment as that expressed regarding the Central Wandsworth Area Spatial Strategy. UK Power Networks (EDF Energy) reiterate comments made above in relation to the Area Spatial Strategy for Land between Armoury Way and the Railway. The Council's response to these representations is set out above.
Sites
3.206 PLA support references to the Western Riverside safeguarded wharf in the text, but state that amendments are required in order to properly reflect the London Plan. It is considered that the text adequately reflects the requirements of the London Plan and no changes are considered necessary. The Wandsworth Society consider buildings should be tall at 5 storeys at this site. This point is rejected as the height at which buildings are considered to be tall within the Thames Policy Area is 9 storeys as set out in DMS4 (Tall buildings) of the Development Management Policies Document.
3.207 At the Enterprise Way Industrial state and the Linton Fuels site, the PLA make the same comment as above regarding discussions on a new bridge crossing and riverbank enhancements. The Council would always consult the PLA on such matters and it is not considered necessary to refer to this in the text. The Wandsworth Society consider a building should be tall at 4 storeys in these locations. It is not accepted that a building of 4 storeys in this location would be tall (i.e. would be substantially taller than the prevailing height of neighbouring buildings and/or would significantly change the skyline).
3.208 The PLA make the same comment as above in relation to the Feather's Wharf site, and also state that any improvements to the pedestrian and cycle link through the waste transfer site should not impact on the safeguarded wharf and its viability for cargo handling. It is not considered necessary to change existing text as reference is already made of the importance of the safeguarded wharf. The Wandsworth Society consider the allocation is unjustified and undeliverable because of conflicting aims and policies relating to the site and other Wandle/Creek frontage sites. It is accepted that reference to the riverside walk and riverside enhancements should be consistent throughout all riverside sites. Where relevant the requirement has been updated to refer to the 3m riverside walk with an additional allowance for riverside enhancements to be considered. The tall buildings policies for these sites do differ, and this is justified in the Council's S2UDS.
79 DMPD & SSAD Proposed Submission Statement of Consultation
3.209 The Wandsworth Society also state that it is unjustified to avoid referencing the environmental sensitivity of the River Wandle on the Feather's Wharf site. This is infact referenced under the heading 'biodiversity'. For consistency with other sites the text under biodiversity has been moved to the design principles section. Wandsworth Society also consider it is unsustainable to have new residential development placed next door to the waste transfer station. The GLA consider that the site is better suited, at least temporarily, for wharf uses due to local concern regarding the scale of proposed development and the aspirations regarding open space, the relative shortage of wharf land to the west of central London, and the likely impact of the Thames Tideway Sewer on at least two wharves within Wandsworth. Residential development would have to be in accordance with our general development principles set out in DMS1 of the Development Management Policies Document and public open space should be included at the mouth of the river Wandle as identified in the site allocation. The importance of the safeguarded wharf has been reflected in the text on infrastructure. At the time of writing the Council has expressed opposition to some of the proposed sites set out in Thames Water's phase one consultation report and is seeking evidence of the consideration of alternative sites and a comprehensive and convincing justification from Thames Water for all of the preferred sites.
3.210 The Wandsworth Society consider the reference to tall buildings at the 'Land at the Causeway' site to be contradictory. This is not the case. The policy relating to the Switch House and Head House differs. The justification is set out in the S2UDS. UK Power Networks (EDF Energy) support the site allocation, the principle of a new route, riverside walk and enhancement of the riverbanks, but request explicit reference to the feasibility and viability of development and that any Section 106 contributions should be fair, reasonable and proportionate and comply with Circular 05/05. As set out above, the Introduction has been updated to make reference to Circular 05/05. UK Power Networks oppose the tall buildings policies on the site and request amendment to state that tall buildings with a minimum of 17 storeys would be considered acceptable on the site. It is considered that the appropriateness for tall buildings should be changed to 'sensitive to' but the height at which a development in this location will be considered to be tall will remain at 5 storeys due to the potential impact on environmental sensitivity of the River Wandle and Bell Lane Creek. This has been reflected in the tall building section of the text and associated map change.
3.211 Port of London Authority request the diagram of the Cory Environmental Materials Recycling Facility to be amended to accurately reflect the boundary of the safeguarded wharf. This is rejected as the map of the Western Riverside Waste Transfer Station represents the accurate safeguarded wharf boundary. For clarification, the boundary for the MRF represents the allocated waste site. The Wandsworth Society question why the tall buildings height has been raised from 5 to 9 storeys in this location. This is to correct an error in the previous version, as it is in the Thames Policy Area it falls within Area B of Policy DMS4.
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3.212 Wandsworth Society make the same comment as above regarding the height increase to 9 storeys, however the Western Riverside Waste Transfer Station is a new site that was added at Proposed Submission stage.
3.213 St James Group oppose reference that the Homebase site is likely to be inappropriate for tall buildings on the basis that there is no evidence to support this. The site is outside a town centre or focal point, and is therefore likely to be inappropriate for tall buildings in accordance with Core Strategy Policy IS3, and further supported by DMPD Policy DMS4. Stargas Nominees support the site allocation but oppose the identification of the site being inappropraite for tall buildings on the basis that it is part of the Wandle Delta focal point. This is not accepted, however it is accepted that the site should fall within the Thames Policy Area. The policy context, justification and tall buildings information have been updated accordingly, however the site allocation remains unchanged. The approach to S106 agreements is also requested to be in accordance with Circular 05/05. This has been reflected in the Introduction as discussed above.
3.214 B&Q request the B&Q site, Smugglers Way should acknowledge the existing retail use of the site as an acceptable use as part of any future mixed use redevelopment of the site. This is not accepted as retail warehouses/DIY stores provide a specialist shopping role. The nature and their operation requires large plots with good access to the main road network. To reflect these specialist circumstances conditions are attached to planning permissions to restrict the type of goods sold and prevent changes to any other type of retail use. Redevelopment of the site involving a different type of retail offer would be considered under DMPD Policy DMTS2 Out-of-centre retail. It has also been clarified in the policy context and allocation, that as the site is within the Thames Policy Area but outside a focal point of activity, and replacement employment floorspace is not required in this location, residential only development is appropriate.
Chapter 3 - Central Wandsworth and the Wandle Delta
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Area Spatial Strategy for Central Wandsworth
Mr Ralph 490121 34 Sound
Minerva 40433 220 2
81 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 3 - Central Wandsworth and the Wandle Delta
Wandsworth Society 847 227 Not specified
NHS Wandsworth 152395 264 Not specified
Sites
Workspace Group 397170 148 1, 2, 3
Wandsworth Society (2) 847 229 & 230 Not specified
Minerva 40433 221 1
Greater London Authority 1407 303 Not specified
Area Spatial Strategy for Land between Armoury Way and the Railway
Port of London Authority 1405 53 1, 3
Tesco Stores Ltd 1131 216 1, 2, 3
Wandsworth Society 847 231 Not specified
UK Power Networks (EDF Energy) 1326 253 Not specified
Sites
Port of London Authority (2) 1405 54 & 55 1, 3
Wandsworth Society (3) 847 232-234 Not specified
Tesco Stores Ltd 1131 208 1, 2, 3
Area Spatial Strategy for Wandle Delta, land north of the Railway
Port of London Authority 1405 58 1, 3
Wandsworth Society 847 235 Not specified
UK Power Networks (EDF Energy) 1326 254 Not specified
NHS Wandsworth 152395 265
Sites
Port of London Authority (5) 1405 56, 57, 59-61 1, 3
Wandsworth Society (7) 847 237-239, 241, 243, 1 & 1, 2, 3 245, 246
Greater London Authority 1407 302 Not specified
UK Power Networks (EDF Energy) 1326 255 Not specified
St James Group 495333 273 Not specified
82 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 3 - Central Wandsworth and the Wandle Delta
Stargas Nominess Ltd 404263 285 3
B&Q 486614 31 1
Chapter 4 - Clapham Junction
3.215 During the consultation period the Clapham Junction Action Group (CJAG) sent the Council a series of questions relating to the documents. CJAG then submitted their letter, with Council's response and some additional comments as a representation. Where these comments have resulted in changes to the document they are addressed below. In relation to building heights, CJAG queried why heights are expressed in storeys rather than metres. The Council responded that the S2UDS describes at para 2.1 that the heights are expressed in storeys and this assumes an average storey height of 3m, based on a middle ground between average residential floor to ceiling heights which are generally 2.5m, and an average commercial floor to ceiling height which are generally 3-4m. This has now been included in the context to DMS4 for clarity, along with a requirement for developers to express their building heights in storeys as well as metres in planning applications.
3.216 The Clapham Junction Town Centre Partnership express support for comprehensive modernisation of Clapham Junction station and the adjoining shopping centre as crucial to the future success of the town centre. The Lavender Hill Business Association consider "upper Lavender Hill" (from Latchmere Road to Queenstown Road) should be part of the Core town centre to enable considerable improvement. It is too late in the process to consider town centre boundary changes at this stage, however environmental enhancements would still be supported in accordance with other policies.
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Area Spatial Strategy for Clapham Junction
3.217 NHS Wandsworth consider that the area spatial strategy should attempt to provide a vision for the area and set out broad infrastructure requirements, including healthcare. The Council intends to build on the infrastructure requirements already set out in Appendix 1 of the Core Strategy, through a Planning Obligations SPD/Community Infrastructure Charging Schedule and will work with the NHS to identify infrastructure requirements to support new development, and how these will be funded.
3.218 The Battersea Society welcome the inclusion of an Area Spatial Strategy for Clapham Junction, but feel that it does not adequately respond to the three major challenges facing Clapham Junction, including its marginally viable position as a shopping centre, the poor conditions for travellers at Clapham Junction Station and issues regarding the interchange between rail and other transport modes. The Society consider that in order for this to be overcome, a co-ordinated approach for the two sites allocated for retail development, the Station Approach and the ASDA/Lidl/Boots site, should be taken to achieve the critical scale that will attract retailers and shoppers. The Battersea Society consider that the proposals for retail development on these sites largely mirror the retail space at St John's road, which fails to meet modern retailing requirements.
3.219 The Council consider that the requirement to respect the contextual grain of the area does not mean this will be a mirror image of St John's Road. Every major new retail development requires smaller as well as larger units. It is appropriate to wrap the smaller units around the 'dead space' of the larger units to ensure active street frontages. Those smaller units should respect the grain of the shopping frontages of the town centre, as opposed to the footprint of the retail sheds in Falcon Lane and their lack of integration with the street frontage. The Society consider more extensive modifications are required to remedy the problems at the station, including longer platforms and have put forward detailed arguments elsewhere for a bus interchange on a site over the railway tracks to link directly with the planned upper level entrance to the station. It is noted that the extension of platforms three and four to accommodate 10 car trains is at prior-approval stage (2010/0825).
3.220 The Council is in discussion with Network Rail and substantial further improvements are expected both in terms of the station infrastructure and the services operating from the station over the life of the LDF. While it is considered that certain parts of the station are unsatisfactory, we would not accept that it is “actually dangerous”, as the Railways Inspectorate would intervene if this were the case. The Council accepts the scale of the challenges faced at Clapham Junction, which is dominated by the railway station and the associated interchange issues. It is still envisaged that further substantial improvements will be made to the station, but that this will take longer than originally envisaged, due to the delay in any major redevelopment of the St John’s Hill station entrance. The Area Spatial Strategy provides the wider approach linking the sites, but the Council must then ensure that the overall strategy is applied as the individual sites come forward. It is clearly a long term project
84 DMPD & SSAD Proposed Submission Statement of Consultation
and the individual sites will come forward at different stage. At present the Council considers that the relatively narrow site located between the railway lines is currently inaccessible and there are a number of obstacles to its development. It the present time Network Rail has not indicated its intention to develop the site, but the Council would engage in discussions if this were to take place. The Council will seek to improve bus facilities in the Clapham Junction Area, but considers that it is highly unlikely that a suitable location will be identified for a formal bus station. However, the Area Spatial Strategy seeks improvements to bus and rail interchange facilities. There remain a number of large sites that can be developed during the life of the plan. Given the high public transport accessibility it is expected that such sites will be developed at a relatively high density and as such the targets of 1,500 new homes and 30,000 sq ms of employment floorspace can still be achieved.
3.221 The Society also put forward comments in relation to building heights in the area, which are addressed in relation to Appendix 4 of the DMPD.
Sites
3.222 The Clapham Junction Town Centre Partnership support the encouragement of viable development at the ASDA/LIDL/Boots sites. CJAG and Oak Trading Ltd consider that reference to the realignment of Falcon Lane has not considered feasibility and that costs and the impact of reducing the size of the ASDA/Boots/Lidl site on the deliverability of development have not been considered. The proposal to realign Falcon Lane would allow an active frontage to be provided on both sides of Falcon Lane. At present it is a two way road providing access and egress to three retail units that are directed at least in part to car-bourne customers and carrying a variable level of through traffic. Falcon Lane has a relatively small pedestrian movement along it and in fact has only a footway on its northern side. On the southern side it has a narrow strip of green space. It is considered that a realignment of Falcon Lane would permit the active frontage on the southside and with any realignment, tree planting could be provided to mitigate against the loss of the existing trees and green space. The realignment would clearly need to be undertaken in conjunction with the owners of the Boots and Lidl sites and the resultant scheme would need to be of a scale to achieve economic viability. There has been no cost consideration applied to this approach and the intention is to flag up a potential improvement. The Council currently has no plans to realign the road. If a developer were to come forward it would be for them to undertake the necessary assessments of viability in the first instance. It is unclear as to the likelihood of such a scheme coming forward in the next 15 years with the existing economic uncertainties, however it is possible that one of the sites may come forward for development, and identification of the SSAD for a potential wider redevelopment is considered worthwhile.
3.223 Representations on Lanner and Griffon House were received from Clapham Junction Action Group, Battersea Society and St James Group. As construction has started on the site for student accommodation (2009/2279) it has been removed from the Site Specific Allocations Document.
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3.224 CJAG want the Car park adjacent to Sendall Court, Grant Road to be allocated entirely for public open space, in view of the consented developments at Lanner and Griffon House. This is not accepted as the site is not within an area of open space deficiency and is within 300m of York Gardens. Allocation of the site entirely for open space would therefore not be a priority use of the site.
3.225 CJAG acknowledge the mention of the Clapham Junction Station Approach site being sensitive to tall buildings and agree that the site provides a real opportunity to provide the type of retail unit suited to larger chain stores, however CJAG consider that the issue of circulation between the two sides of the railway still needs to be addressed. The Council acknowledge that this is a key issue facing Clapham Junction. When the St John's Hill entrance to the station is opened and greater use is made of the overbridge, passenger movements will need to be monitored and any further improvements that may be required to address circulation issues will need to be considered against a background where further growth in passenger numbers is envisaged with the provision of additional services (East London Line). The Council acknowledge that further investment in Clapham Junction station is both necessary and desirable. CJAG also consider that the 'Land at Clapham Junction Station site' should be allocated for mixed use development. As the site is outside the town centre it is more appropriately allocated for high density housing development.
3.226 CJAG consider that the inclusion of part of the Peabody site within the town centre has been carried out to ease the passage to consent for tall buildings, and not the promotion of the St John's Hill frontage. This is not accepted. Part of the site has been included in the town centre to promote active town centre uses along the St John's Hill frontage allowing better integration into the town centre. The part of the site within the town centre is sensitive to tall buildings, and the part outside the town centre is inappropriate for tall buildings. The height at which a building is considered tall in both locations is 5 storeys.
Chapter 4 - Clapham Junction
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Clapham Junction Area Spatial Strategy
Clapham Junction Action Group 364229 100 Not specified
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Chapter 4 - Clapham Junction
Clapham Junction Town Centre 1127 186 Not specified Partnership
NHS Wandsworth 152395 266 Not specified
Battersea Society 999 195 1
Sites
Clapham Junction Action Group (9) 364229 25-30, 101-103 Not specified &1, 2
Clapham Junction Town Centre 1127 185 Not specified Partnership
Oak Trading Company 406933 287 2
Battersea Society 999 201 1
St James Group 495333 274 Not specified
Chapter 5 - Tooting
3.227 Barrowfen Properties Ltd support the allocation for 180-218 Upper Tooting Road (Dadu's Parade) and the fact that their previous consultation responses at preferred options stage have been taken into account. Regarding the RACS building, it is acknowledged that since the publication of the preferred options SSAD, the building has been locally listed, as such, reference to this has now been included in the Historic Environment section.
3.228 Mrs Libby Lawson raises various concerns that could result from redevelopment of the site involving a 5 storey building, including loss of views, light, and heritage impacts. As these are all considerations set out in Policy DMS4, to which a tall building have to comply, no changes to the allocation or design principles are considered necessary. A concern regarding over-provision of retail space is also raised, but as this is a town centre site, retail growth is acceptable in accordance with Core Strategy Policy PL8.
Chapter 5 - Tooting
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
87 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 5 - Tooting
Barrowfen Properties Ltd 398758 129 Sound
Mrs Libby Lawson 493962 179 Sound
Chapter 6 - Putney
3.229 Mrs Poulter opposes the wording set out in the planning policy context of the Area Spatial Strategy. As this wording is taken directly from Core Strategy Policy PL8, there is no scope to change it here. It is also not accepted that the policy contradicts the reduction in the percentage of A1 units in secondary frontages as suggested by Mrs Poulter, as the policy will actually promote a greater range of town centre uses, enhancing town centre viability and vitality.
3.230 The remainder of representations registered against Putney overall related to opposition to tall buildings (see table below for list of representors). This is largely on the basis of the potential impacts on the character of Putney, overlooking, overbearing and privacy, local services, transport and parking (including public transport). Mixed views were received in relation to removal of the upper height limits. Putney Society are supportive of the removal of upper limits, but remain concerned the Council is still supportive of the upper heights, despite the words being removed and state that they will watch the application of DMPD Policy DMS4 to tall buildings proposals very closely. Several respondents consider the removal of these upper limits implies general support for even taller buildings in Putney. As set out in the response to DMPD Policy DMS4 the upper limits were removed, as it was clear that developers were seeing this as a target or starting point rather than a limit and there was much opposition to the height at which they were set. The imposition of maximum heights would also limit the ability to achieve a variation in the skyline. The evidence base to support the maximum heights was also not considered to be sufficiently robust. The Council consider the most robust tall buildings policy to be the retention of the definition of what is regarded as 'tall' in different locations, which would trigger assessment of tall buildings against the detailed criteria in DMS4. As such, the Council will not be imposing maximum heights on buildings in Putney, however it should be noted that none of the policies in the DMPD or the SSAD propose tall buildings in Putney. The intention of the policy is to clarify what is considered 'tall' in different contexts, and to ensure that when tall buildings are proposed, they are rigorously assessed to determine whether they justify themselves in terms of the benefits they bring for regeneration, townscape and the public realm and are of high architectural quality, respecting local contact and the historic environment (Core Strategy Policy IS3). For the purposes of this report a summary of concerns at Area Spatial Strategy and site specific level is provided, but where this requests maximum heights or raises issues about the potential impacts of tall buildings, the Council's position is not repeated in every case.
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Area Spatial Strategy for Putney Town Centre North
3.231 Mrs Poulter illustrates variation in the treatment of existing residential neighbours next to SSAD sites. This representation is accepted, and a standard sentence related to the protection of residential amenity has been included for Putney sites directly adjacent to residential areas (includes sites 6.3, 6.1.3, 6.1.4, 6.2.1-6, 6.3-4). Mrs Poulter also considers that the identification of sites as 'sensitive to' or 'inappropriate for' tall buildings in this area is not justified and that buildings in this location should be no higher than existing. The justification is set out in the Council's Stage 2 Urban Design Study - Tall buildings (S2UDS) which forms part of the evidence base for the SSAD. The comment regarding buildings being no higher than existing relates to the upper buildings limits, which is discussed above. Victoria Diamond also questions the evidence for the policies and thinks the policy is confusing as the heights are minimums. This is not the case. The heights are not minima, but 'heights at which buildings will be considered tall'. This is clearly set out in relation to each site, and in Appendix 2 of the SSAD.
3.232 Lesley Stockell is opposed to major developments in the area that would comprise tall buildings. The Putney Society consider there is little evidence to justify the sites being identified as acceptable for tall buildings. None of the Putney sites have been identified as suitable for tall buildings, in fact the sites are either 'inappropriate for' or 'sensitive to' tall buildings. Mr Peter Carpenter states that the Putney Bus Garage should be included in the SSAD for redevelopment. This was considered at the initial scoping stage, but not included in the SSAD as it is a bus garage protected by London Plan policy for continued transportation use. It was not considered that the site has scope for any additional development. Threadneedle Property Investments and Prices Securities Ltd identify an error on map 6.1 in relation to the labelling of site 2 which has now been corrected. They also state that as the site includes third party land ownership that is not likely to come forward holistically or at the same time as Threadneedle/Prices Securities Land holdings, and because agreed principles regarding building footprints, routes and space are not included in the map, the strategy is undeliverable and unsound. The Area Spatial Strategy is flexible, sets out long term objectives and is capable of providing broad guidance for the development of the area, despite multiple land ownerships and problems with site assembly. This should not necessarily preclude development of individual sites so long as development takes account of the broad principles set out in the Area Spatial Strategy.
89 DMPD & SSAD Proposed Submission Statement of Consultation
Sites
3.233 Mrs Patricia Poulter, Victoria Diamond, Mr Peter Carpenter, Choong Kwang and Putney Society oppose tall buildings on the Wereldhave site, 56-66 Putney High Street. Mrs Poulter and Victoria Diamond consider that development on the site should remain within the general roofline of the neighbouring Putney Exchange. Reasons for this relate to overbearing, over-development, impact on heritage assets, impact on air quality and impact on local services and infrastructure. The policy in relation to this site states that a building of 6 storeys in this location would be tall, and the site is identified as sensitive to tall buildings. Any building of 6 storeys and above would therefore be rigorously assessed against Policy DMS4 to ensure the impacts listed above are properly assessed. Mr Peter Carpenter suggests the use of plot ratios if maximum heights are not imposed. The use of plot ratios has been addressed in response to comments on DMPD Policy DMS4.
3.234 Mrs Patricia Poulter states that it is important that any new development on the Jubliee House and Cinema site allows views from a greater angle than at present onto St Mary's Church. The Design Principles section states that "The layout and massing of buildings should be carefully arranged to ensure that new views of St. Mary's Church are opened up from the public square and that existing views of the Church from Putney High Street are enhanced." Given this, no changes to the text are considered necessary. Mrs Poulter also considers reference to a higher element is unjustified. The Design Principles are not saying that a higher element will be acceptable, but that if a higher element were to be located on the site, the location that would be most sensible and cause least harm to surroundings would be backing up against the Putney Wharf tower. Victoria Diamond would like to know that a Police presence would be maintained in the area, and considers the height of the building should be no higher than existing. The police station is a community facility that would be protected by DMPD Policy DMC1. Text has been added to include retention/replacement of community facility unless relocated elsewhere. The Putney Society also consider that development should be no higher than existing as anything higher would create a canyon like effect in an area which suffers from pollution. Putney Society consider the cinema should be no higher than 3 storeys. Concerns about the height are expressed in terms of heritage impacts and pressure on services and infrastructure. Mr Peter Carpenter makes the same comment as above in relation to plot ratios and Choong Kwang is opposed to tall buildings on the site. As set out in the tall buildings information for the site, the cinema site is inappropriate for tall buildings and the height at which a building would be considered tall is 3 storeys. Jubilee House is sensitive to tall buildings and a building will be tall at 6 storeys in this location. Any building of 3 storeys or more would therefore be inappropriate on the cinema site, and any building of 6 storeys or more would be rigorously assessed against policy DMS4 to address potential impacts on heritage impacts, services and infrastructure.
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3.235 Victoria Diamond and Mrs Patricia Poulter consider that the close proximity of the Corner and Putney Bridge Road and Putney High Street site to residential development at the rear and the Oxford Road conservation area, means that any proposed redevelopment should not be higher than existing. Additional reasons for opposing tall buildings discussed above, such as the impact on services and infrastructure, are also expressed in relation to this site. Mr Peter Carpenter and Choong Kwang make the same comments as above. As discussed above, the Council has chosen not to impose maximum heights, but to ensure that tall buildings (in this location buildings for 6 storeys and above) will be subject to assessment against DMPD Policy DMS4. Threadneedle Property Investments and Prices Securities Ltd state that the red line extent of the allocation should be amended to make it effective and thus sound. This is rejected as the Area Spatial Strategy remains flexible enough to accommodate change that my result from site assembly problems. An agreed building footprint incorporating a public route and open space accessed from Putney Bridge Road, which also provides a development break against the end of the Burstock Road curtilages, is also sought to be reflected in the site information. This is rejected, the agreed principles align with the broad objectives for openspace/access shown on the Area Spatial Strategy.
3.236 Mrs Patricia Poulter states that as the Putney Telephone Exchange, Monserrat Road adjoins residential gardens on Burstock Road and Monserrat Road, the site is not one where tall buildings should be acceptable. It is not stated anywhere in the SSAD that tall buildings are acceptable on this site. The site has been identified as 'sensitive' to tall buildings, taking account of the local context, including the Victorian residential character, listed buidings and Conservation Areas. Concerns regarding the proposed access onto Monserrat Road are also raised. This entrance already acts as an existing service entrance to the telephone exchange building and any development proposals would have to be in accordance with DMT1 and assessed at the planning application stage. This has been reflected in the text. As part of the application stage, applicants would have to demonstrate adequate servicing arrangements and may explore options to develop servicing arrangements with adjacent sites leading onto the high street to the east, and to explore possibilities of joint arrangements with any development of the SSAD site 'Corner of Putney Bridge Road and Putney High Street' to the north. The Area Spatial Strategy has been extended to show the connection at the southern end of the site to Monserrat Road. Mr Tim Ewart, Mrs Victoria Diamond, Putney Society, Mrs Susan Held and Mrs J Crawshaw also raise concerns about tall buildings on the site. Reasons for concern include potential impacts on privacy, excessive noise in the evenings and at night from entertainment uses and from servicing/delivery vehicles, parking stress, traffic effects, loss of light, over-development, safety of the proposed access, and wind speeds at ground level. As explained above in relation to other Putney sites, these effects would be carefully considered for any building of 6 storeys and above. Mr Peter Carpenter states that as the site is in a residential street the maximum height should be 3 storeys, and again states that plot ratios should be used if maximum heights are not. The Council's position on maximum heights, as well as ratios is set out
91 DMPD & SSAD Proposed Submission Statement of Consultation
above and in relation to DMPD Policy DMS4. Threadneedle Property Investments and Prices Securities Ltd support the identification of a potential linkage between the Telephone Exchange site to their site (6.1.3) which is located to the north.
Area Spatial Strategy for Putney Town Centre South (Upper Richmond Road)
3.237 Mrs Poulter makes the same comment as that in relation to the Area Spatial Strategy for Putney Town Centre North, regarding variation in the treatment of existing residential neighbours next to SSAD sites. The response to this representation is provided above. Mrs Poulter, Victoria Diamond and the Putney Society consider the building heights should be reduced, or alternatively not exceed the height of existing buildings. Mr Jonathan Hart seeks the imposition of set building height restrictions along Upper Richmond Road. Again this is due to concerns over capacity of services and infrastructure, crime issues and others expressed above in relation to other sites. The Council's position on maximum heights, is set out above. Victoria Diamond queries why all sites within Putney town centre north are identified for mixed-use development, while all the sites in Putney town centre south are identified for high-density mixed use development. As all sites are located within the town centre with good public transport accessibility, high density mixed use development is appropriate (subject to other policies), and this has now been updated on all Putney sites. Russell Cook Solicitors consider that the site allocations for all of the Putney town centre south sites should be amended to ensure awareness of the relevant requirements and consistency with adopted Core Strategy Policy PL14. It is considered that the policy context and justification already provide sufficient clarity regarding policy requirements for the replacement of office floorspace. St James Group object to the reference that tall buildings are unattractive due to their height, stating that they are unattractive due to their architecture and that introducing variation such as a 2-3 storey building is not necessary to address the attractiveness as high quality design is more important. This is rejected as in this case the height of buildings is in itself an unattractive feature of the street and one that we are seeking to address with the guidance given. Introducing variation to the height of buildings is an important contributor to improving the attractiveness of the street.
Sites
3.238 Mrs Patricia Poulter and Victoria Diamond oppose reference to 'high density' mixed use development at Tileman House, 131-133 Upper Richmond Road. As explained above, the site is located within a town centre with good public transport accessibility, and high density development is therefore appropriate in accordance with the London Plan density matrix. Victoria Diamond also requests reference to protection of the amenity of residents at St John's Ave. As stated above, reference to protection of residential amenity has been standardised across all Putney sites where particularly relevant. Putney Society, Mrs Poulter and CR Atkins are opposed to tall buildings on the site, for reasons expressed above in relation to other sites. The reference to active frontages at ground level is also opposed. As the site is a town centre site, active uses,
92 DMPD & SSAD Proposed Submission Statement of Consultation
including those within the A use classes, are appropriate in this location. Mr Peter Carpenter makes the same comments as those in relation to plot ratios above. Russell Cooke Solicitors make the same comment as above in relation to replacement office floorspace. Tileman House Investments are generally supportive of the site allocation, but consider that the requirements for a mix of uses should not be overly prescriptive, viability of development should be considered, design principles should be more flexible and the mechanisms for requiring developer contributions should be set out. As explained in response to other representations of this nature, the Introduction to the SSAD has been updated to clarify that the design principles and associated map are indicative and that obligations will be sought in accordance with the circular.
3.239 Mrs Patricia Poulter and Victoria Diamond query why the existing permission for 11 storeys at 113 Upper Richmond Road is not reflected in the site information and also state that redevelopment on the site should be no higher than existing. The planning history does in fact include this permission. The issues expressed in relation to other sites regarding transport, public disorder and sensitivity to neighbours are repeated in relation to this site. Mr Peter Carpenter and Russell Cooke make the same comments as above.
3.240 The Putney Town Centre Partnership recommend that the definition of 'infrastructure' in relation to contributions sought at 86-88 Upper Richmond Road and 84 East Putney House is broad enough to ensure that S106 funds from major developments are allocated to both townscape and transport interchange/improvements. The details of this will be set out in a forthcoming S106 SPD/CIL charging schedule, and consideration of funding for these items will be set out in this document. Mrs Poulter considers the suggested access to the site via Woodlands Way is unacceptable and comments in relation to other sites are repeated here. This is rejected as this access is part of the overall strategy of enhancing pedestrian connectivity in the area as set out in the Area Spatial Strategy Diagram. Victoria Diamond opposes reference in the site allocation for high density. Mr Peter Carpenter and Russell Cook Solicitors make the same comments as above. Putney Society, Cortes and Catherine Baylis oppose tall buildings at the site due to proximity to East Putney and Oxford Road Conservation Areas and low-rise residential development. Concerns expressed in relation to other sites regarding transport, parking and neighbours amenities (lighting, privacy) are repeated here. Orchid (Putney) Limited, the owner of the site, clarify the correct site area, which has been updated. Specific reference to the range of uses that are appropriate is sought, however this is not considered necessary as the site is in a town centre, and therefore the full range of town centre sites would be appropriate in principle (subject to meeting other policy requirements on retention of offices/active frontages etc). The policy context has however, been updated to reflect this and this has also been applied to other sites along Upper Richmond Road for consistency.
3.241 A request has been made to update the PTAL rating for the site. It is set out as 5-6 in the SSAD, and Orchid (Putney) Limited state that through discussions with Transport for London it has been confirmed that the PTAL rating is 6a. As explained
93 DMPD & SSAD Proposed Submission Statement of Consultation
elsewhere in this document, the PTAL rating information in the SSAD is obtained from the Council's GIS layer, and the Introduction to the SSAD explains that this is only to be used as a guide and accurate information on the actual PTAL value should be calculated individually for each site. It is up to the applicant to carry this out at planning application stage as part of their transport assessment. In the design principles section the reference to public realm is opposed, with amended wording suggested. It is accepted that it is not appropriate to insist on the size of the space being proportional to the height of buildings as this has not been required for other sites in the SSAD. The wording has been amended. The reference to residents being 'very close' to the site is opposed on the basis that this reference is not made for other sites along Upper Richmond Road and that this site is separated from residential by three railway lines. In saying this Orchid (Putney) Limited fully accepts that the design of new building accommodation will need to be carefully considered, particularly in the context of its impact on amenity of neighbouring residents and occupiers. This is accepted and the reference to protection of residential amenity has been standardised for Putney sites as mentioned earlier in this report. In the infrastructure section a request for reference to the tests of Circular 05/05 is sought, and amended wording is sought in relation to cycle route improvements. This is accepted and the text has been amended to reflect flexibility in the requirement for cycle improvements. Reference to Circular 05/05 is included in the Introduction.
3.242 The Putney Town Centre Partnership, Mr Peter Carpenter and Russell Cook Solicitors make the same comments in relation to the Capsticks site, 77-83 Upper Richmond Road, as other sites along Upper Richmond Road. St James Group object to the reference of 6 storeys being considered tall in this location stating that the suitability of building heights should be subject to visual assessment and each proposal should be judged on its merits. The Putney Society consider that any building taller than existing is unjustified for the same reasons expressed in relation to other sites. Comments from the above parties were also received objecting to the town centre boundary change to include the rear of the site within the town centre. The Council's response to this is included in the DMPD Appendices section of this document. Mrs Poulter set out objections relating to the identification of the site for high density mixed use development including active frontages at ground floor level, reference to a pedestrian link to Woodlands Way, low car/car free development and access/egress to and from the site. Issues expressed in relation to transport, public disorder, and sensitivity to neighbours are also expressed in relation to the Capsticks site. Victoria Diamond also objects to the reference to a pedestrian link via Woodlands Way. As above, this is rejected as this access is part of the overall strategy of enhancing pedestrian connectivity in the area as set out in the Area Spatial Strategy Diagram. The Council's response to these issues is set out earlier in this document.
3.243 Mrs Patricia Poulter opposes reference to high density mixed use development of 72-74 Tote House, Upper Richmond Road with active frontages at ground floor level. Clarification of what is meant by the site 'turning the corner' is sought by Mrs Poulter and Victoria Diamond, as well as careful consideration of traffic and parking effects on
94 DMPD & SSAD Proposed Submission Statement of Consultation
Woodlands Way. In this instance 'turning the corner' is not meant to suggest that the use of the building should turn around the corner of Upper Richmond Road and extend along the frontage with Woodlands Way. This is a design comment and meant to suggest that the building could be designed with an architectural feature that responds to and enhances this corner location. The wording has been clarified in the document to explain what is meant by a 'turning the corner'. Mrs Poulter also repeats the concerns expressed above in relation to other sites. Victoria Diamond requests reference to the amenity of residents in St John's Avenue. As explained above, reference to residential amenity has been standardised for Putney sites. Putney Society considers any replacement building should be no higher than existing for the same reasons as set out above. Mr Peter Carpenter and Russell Cook Solicitors repeat the same comments as above.
3.244 Putney Society, Mrs Poulter and Victoria Diamond query why 85-99 Upper Richmond Road is identified for a reduction in height when other buildings along Upper Richmond Road are not. It was considered appropriate to require reduction in the height of this building at the preferred options stage in the context of the tall buildings policies at that time. As the approach has now changed it is not appropriate to refer to appropriate building heights. This has been removed. Putney Society consider neighbours amenities have not been considered, and raise the same concerns as above in relation to local services and infrastructure. Mrs Poulter's concerns regarding transport, public disorder, sensitive to neighbours and traffic/parking issues are repeated here. Russell Cook make the same comment as above.
3.245 Opposition to the Sainbury's Supermarket, 2-6 Werter Road, Putney was received from Mrs Patricia Poulter, Mr Tim Luckham, Victoria Diamond, Mrs and Mrs Simon Fenn, Putney Society, Werter Road Residents (submitted by Sue Rolfe), Mr Stephen Weaver, Mr Jonathan Cornwell, Mr Jeff Dale, Jenny Scribbins, Mr Peter Carpenter, Mr and Mrs David and Karen Thompson, Councillor Rosemary Torrington, Catherine Baylis, Mr and Mrs Brendan and Samatha Moore, Councillor Maddan, Mr Adrian Harpertee, Lorna Harper, Hugh and Colleen Samuel and Catherine McDermott. Concerns about the site allocation included; potential height, overlooking, privacy, scale and massing, adequacy of infrastructure and services, traffic, parking, impact on Conservation Area and listed buildings, impact on quality of life for Werter Road residents, light and noise and disturbance, pollution, servicing, delivery and waste disposal. The site is located within a town centre and is therefore appropriate for the uses identified in the allocation in planning policy terms, whether the site is allocated in the SSAD or not. The reference to 'active frontages' merely expresses an intention to improve the currently dead frontage along Werter Road, and as explained in the Introduction to the SSAD reference to 'active frontages' in this context, relates to broad urban design principles of improving the streetscene by presenting a frontage in terms of orientation of the building, position of ground floor windows, doors, signage etc, rather than any type of use class. The extensive concerns expressed above would be assessed in detail if a proposal for a tall building (5 storeys or above) were to come forward on this site.
95 DMPD & SSAD Proposed Submission Statement of Consultation
3.246 Comments on Former South Thames College, Putney Hill were received from Mrs Patricia Poulter, Victoria Diamond and Mr Peter Carpenter. As construction of the site is underway, the site has been removed from the SSAD.
3.247 Mr Peter Carpenter states that as the NHS has announced its intention not to proceed with development for which is has planning permission at Putney Hospital, Lower Richmond Road, this provides the opportunity to review the use of the site, including uses from community and educational purposes. This is what the site is allocated for, and no changes are therefore required within the site allocation. Mr Peter Carpenter makes the same comment as above regarding plot ratios and considers a designation of 3 storeys would be appropriate on this site. Mrs Victoria Diamond says 'the saga continues'. The Putney Society request clarification on the use of the site, for a free school or for residential development. Putney Society also consider the site unsuitable for tall buildings for a number of reasons including those set out above and the importance of the Commondale Cottages and open space (common land) adjacent to the site. As the site is identified as unlikely to be suitable for tall buildings, no changes are necessary to address this representation.
Chapter 6 - Putney
Representor Representor Representation Soudness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Mrs Patricia Poulter (2) 396982 6 & 146 Not specified
Michelle Bailey 489884 32 Not specified
Victoria Diamond 397038 62 Not specified
Kate Coyle 490504 78
Suzanne Constanti-Taylor 490768 91 Not specified
James Taylor 490769 92 Not specified
Mr LL Waterston 407796 104 Not specified
Putney Society 802 109 1, 2
CR Atkins 404674 142 Not specified
Mr and Mrs Clive and Gilda Rees 403058 222 Not specified
Area Spatial Strategy for Putney Town Centre North
96 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 6 - Putney
Mrs Patricia Poulter (2) 396982 8 & 10 Not specified
Victoria Diamond 397038 63 Not specified
Lesley Stockell 490508 79 Not specified
Putney Society 802 110 1, 2
Mr Peter Carpenter 491438 154 2
Threadneedle Property Investments 495034 244 2 and Prices Securities Ltd
Sites
Mrs Patricia Poulter (4) 396982 11-14 Not specified
Victoria Diamond (4) 397038 64-67 Not specified
Putney Society (4) 802 111-114 1, 2
Mr Peter Carpenter (4) 491438 155, 156, 158, 2 159
Choong Kwan (3) 494843 205-207 Not specified
Threadneedle Property Investments 495034 247, 248 2 and Prices Securities Ltd (2)
Mr Tim Ewart 489890 33 Not specified
Mrs Susan Held 481232 2 1, 2
Mrs J Crawshaw 490923 133 1, 2
Area Spatial Strategy for Putney Town Centre South (Upper Richmond Road)
Mrs Patricia Poulter (2) 396982 9, 15 Not specified
Victoria Diamond 397038 68 Not specified
Putney Society 802 116 1, 2
Russell-Cooke Solicitors 31152 172 1, 3
Jonathan Hart 495086 257 Not specified
St James Group 495333 275 Not specified
Sites
Mrs Patricia Poulter (9) 396982 16-23, 147 Not specified
Victoria Diamond (9) 397038 69-77 Not specified
97 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 6 - Putney
Putney Society (8) 802 115, 117-123 1, 2
CR Atkins 404674 141 Not specified
Mr Peter Carpenter (8) 491438 160-167 2
Russell-Cooke Solicitors (6) 31152 173-178 2
Tileman House Investments (Putney) 494570 193 Not specified Ltd
Putney Town Centre Partnership (2) 872 3 & 4 Sound
Cortes 491167 132 1, 2
Orchid (Putney) Ltd 494542 191 Not specified
Catherine Baylis (2) 494831 203 & 204 Not specified
St James Group 495333 276
Mr Tim Luckham 490169 37 1, 2, 3
Mr and Mrs Simon Fenn 491083 105 Not specified
Werter Road residents (Mrs Sue 489162 140 Not specified Rolfe)
Mr Stephen Weaver 491387 149 Not specified
Mr Jonathan Cornwell 491388 150 Not specified
Mr Jeff Dale 491394 151 Not specified
Jenny Scribbins 491396 152 Not specified
Mr and Mrs David and Karen 494522 190 Not specified Thompson
Councillor Rosemary Torrington 494553 192 Not specified
Mr and Mrs Brendan and Samantha 494819 218 Not specified Moore
Councillor Maddan 495011 223 Not specified
Mr Adrian Harpertee 495014 224 Not specified
Lorna Harper 495018 226 Not specified
Hugh and Colleen Samuel 495053 251 Not specified
Catherine McDermott 495842 289 Not specified
98 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 6 - Putney
Mrs and Miss BP and M Adams 404083 304 Not specified
Chapter 7 - Balham
3.248 OCS Group Ltd request the addition of 18-20 Boundaries Road to the SSAD, to allow continued use as a laundry facility, with ancillary offices and residential. The site owners have had several opportunities to raise addition of the site in earlier consultation rounds and the site has not been included as it is too late in the process to add a site at this stage, without carrying out additional consultation.
Chapter 7 - Balham
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
OCS Group Ltd 495056 250 Not specified
Chapter 8 - Roehampton
3.249 The Putney Society and Mr Peter Carpenter consider that the evidence shows that through the various consultation exercises carried out into the Council's proposals for Roehampton, Danebury Avenue (site 8.1), the public want the Library/Allbrook House and the adjoining open space to be retained in any redevelopment. A report of the Economic Development Officer to Strategic Planning and Transportation Overview and Scrutiny Committee on 18 January 2011 (No. 11-119) provided an update on proposals to improve the centre of Roehampton. The report states that it is considered that Allbrook House has a continued useful life as housing accommodation and should continue to be used and that the future of the library is not part of the current consultation exercise on the future of libraries in the borough. Therefore no action is taken at this time in relation to this site and the position will be kept under review as market conditions improve. The design principles section of the site information states that a new public space as a focal point for the community is required. This has been amended to 'retain and/or provide public space' so that when the details of a future scheme are considered, the merits of retaining the current open space and/or providing additional open space can be properly considered. Mr Peter Carpenter also thinks that
99 DMPD & SSAD Proposed Submission Statement of Consultation
buildings should be considered tall at 3 storeys rather than 5, and that if maximum heights are not provided, plot ratios should be used instead. The site is identified as an area where tall buildings are likely to be considered inappropriate. Therefore, any building of 5 storeys or more is likely to be considered inappropriate and must justify itself in terms of the criteria set out in Policy DMS4. A review of the context surrounding the site justifies a height of 5 storeys in this location. The comment relating to plot ratios was also raised in relation to Policy DMS4 and is addressed there.
3.250 Mr Peter Carpenter considers that as the Arton Wilson (NHS) site is currently under development, and that no further development is appropriate for the site, it should be removed from the SSAD. The application is subject to legal agreement and therefore a decision notice is yet to be issued. Sites are only to be removed from the SSAD if construction has commenced. The Putney Society state that the policies were shown to be unsound and inadequate when the Council recently granted planning permission for the site to be redeveloped with a scheme which has highly unsatisfactory design features. Design details are agreed as part of the application process. No details have been provided by the Putney Society offering an explanation of their view in relation to the site allocation. A relevant planning history section has been added to clarify the planning status of the site. St James Group support the allocation of the site for residential development, and make various detailed comments relating to PTAL levels, height and massing and amenity space provision. The PTAL level of the site in the Council's GIS systems is levels 1-2 so this has been retained in the document, however as explained in the introduction of the SSAD, the PTAL information should be used as a guide and accurate information on the actual PTAL rating for a site should be calculated separately for each site as part of a transport assessment to accompany an application. It is considered that the design principles are already flexible enough in the reference to amenity space provision, and no changes are made in response to this representation. Any future development would have to provide amenity space in accordance with DMPD Policy DMH7. The request for reference to tall buildings to be removed is not accepted. The site is located within an area where tall buildings are likely to be considered inappropriate, and it is necessary reflect this in the site information.
3.251 The Putney Society and Mr Peter Carpenter oppose reference to 5 storeys on the ASDA, Roehampton Vale site and Mr Carpenter makes the same comment as above, regarding plot ratios. The site is located in an area where tall buildings are likely to be considered inappropriate and is within area D set out in Policy DMS4. As explained in the policy context to DMS4, this means that buildings of 5 storeys and above in this location must justify themselves in terms of the criteria in DMS4, but buildings lower than this will still be subject to rigorous development management assessment against policies DMS1, DMS2 and other relevant policies dependent on the nature of proposals. The site allocation and policy context have also been amended to clarify that retention of the exiting retail facility on-site would be acceptable, but that any amended retail offer will be assessed against DMPD Policy DMTS2 Out-of-centre retail.
100 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 8 - Roehampton
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Putney Society (3) 802 124-126 1, 2
Mr Peter Carpenter (3) 491438 168-170 1, 2 & 2
St James Group 495333 278 Not specified
Chapter 9 - Other sites
3.252 St James Group state that as the former Bolingbroke Hospital facility has relocated and reprovision of healthcare facilities is not viable, the allocation for the site should be C3 residential only. While it is accepted that the former hospital has relocated, the consideration of the site for alternative community facility provision, be it healthcare or education provision for example, should be the first consideration of reuse of the building in accordance with Core Strategy Policy IS6 and DMPD Policy DMC1. The Council accepts the principle of residential development at the site, provided consideration is given to reprovision of community facilities in accordance with this policy. No changes are proposed as it is considered the policy context, site allocation and justification are already clear in this regard.
3.253 Cappagh object to the requirement for a riverside walk on the Cappagh waste recycling facility site, Riverside Way, as the site adjoins a nationally important electricity sub-station and the provision of a riverside walk would not be feasible because of site constraints or desirable in terms of national security. This is accepted and an amendment to the text has been made so that a riverside walk should be 'considered' as part of an application rather than 'required' subject to the considerations in DMPD Policy DMT3.
Chapter 9 - Other sites
Representor Representor Representation Soundness test reference number reference number (1) Justified
(2) Effective
101 DMPD & SSAD Proposed Submission Statement of Consultation
Chapter 9 - Other sites
(3) Consistent with national policy
St James Group 495333 277 Not specified
Cappagh 406808 93 2
Chapter 10 - Other Thames Riverside sites
3.254 Thames Water object to the site allocations for 110 York Road and Pier Wharf, stating that the Thames Tunnel development should be reflected in all allocations that correspond to their identified preferred and short listed sites under consideration. Since the publications of the proposed submission version of the SSAD the Council has responded to Thames Water's phase 1 consultation on the proposed Thames Tunnel development. Whilst recognising the need for investment in the Capital's sewage system and the benefits of improved water quality in the Thames, the Council has serious reservations about the huge financial and environmental cost of the Thames Tunnel scheme. The Council's response was agreed at the Strategic Planning and Transportation Overview and Scrutiny Committee (Paper No. 11-112) on the 18th January 2011. For clarification purposes, the Council accepts that reference should be made to Thames Water's consideration of these proposed sites and wording to reflect this consideration has been included in the policy context for each site (includes Feathers Wharf, Pier Wharf, Former Prices Candle factory, Battersea Power Station, Metro Greenham Wharf, 88 Kirtling Street, Securior Site 80 Kirtling Street, Tideway, Heathwall Pumping Station, Middle Wharf, Main site Ballymore). Senex Capital Ltd, the owners of 110 York Road support the allocation of the site, but state that as the candle shop on the site is still in use, and not vacant as stated in the SSAD, replacement of A1 retail on the site should be appropriate in principle. The existing retail unit was ancillary to the candle factory and any amended retail offer would be considered against DMPD Policy DMTS2. This has been referred to in the policy context. Senex also make representations in relation to the height at which a building will be considered tall on this site, and the Council's response is provided in relation to Policy DMS4.
3.255 Lookers support the allocation of the Dovercourt site for redevelopment but raise concerns over the detail. Specifically, Lookers would like clarification that parts of the site could be bought forward for development, and that comprehensive redevelopment of the site is not required. The introduction to the SSAD already states that the maps and diagrams do not prejudice individual parts of a larger allocation coming forward for development independently, but opportunities to develop sites cohesively should be explored. Reference to the appropriateness of the site for A1-A5 as well as D1 and D2 uses is sought, however, as the site is located within the Thames
102 DMPD & SSAD Proposed Submission Statement of Consultation
Policy Area, but is outside a focal point of activity, the replacement appropriate uses, which are outlined in the site allocation, include Residential, B1-B8 or related SG uses, subject to the tests set out in the policy. A1-A5, D1 and D2 uses would be considered out of centre town centre uses, and would be assessed against Policy DMTS2. As these uses are not the preferred uses for the site, reference to them in them in the allocation is not considered appropriate. Further flexibility is sought in relation to the building heights, to state that buildings of more than 9 storeys may be appropriate subject to detailed design. The site is location in an area where tall buildings are likely to be considered inappropriate as set out in the Core Strategy, and this change would therefore not be appropriate. The site area in the allocation has been corrected as requested.
3.256 Hives confirm on behalf of the owners of 12-14 Lombard Road that this land can be made available for development and can deliver the form of development envisaged during the Plan period. Bupa consider that the policy context and site allocation for 12-14 Lombard Road does not correctly interpret DMI3, as replacement of B1-B8 and related Sui Generis use is not required if relevant policy tests are met. This is accepted and the policy context has been updated on all relevant sites where the policy applies. The site allocation has not been updated, as this is the Council's preferred use(s) of the site, but will be subject to the detail set out in the policy context. Bupa also consider that the allocation should reference the requirement for such uses to consider their impact on the amenity of nearby occupiers/uses and residents. The general amenity considerations that apply to all development are set out in DMPD Policy DMS1, and do not need to be repeated here.
Chapter 10 - Other Thames Riverside sites
Representor Representor Representation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Thames Water (2) 233792 89 & 90 1, 2, 3
Senex Capital Ltd 1471 209 1
Lookers 490939 99 Not specified
Bupa 398858 153 1
Hives 493925 157 Sound
103 DMPD & SSAD Proposed Submission Statement of Consultation
Appendices
Gypsy and Traveller provision (Appendix 1)
3.257 Mr Carpenter considers that no provision is made for Gypsies and that this is inconsistent with current national policy. As Appendix 1 explains, the borough's allocation of Gypsy and Traveller site(s) will be revised through the Core Strategy review of overall housing requirements, to align with any review of the Draft Replacement London Plan. Further work will be undertaken at that time, to review need and justify any site allocation.
Tall buildings maps (Appendix 2)
3.258 Barton Wilmore consider that the policy relating to the Thames Policy Area would mean that reserved matters applications for the Battersea Reach site would technically be a departure from policy. Threadneedle Property Investments and Prices Securities Ltd consider that it is inappropriate to refer to the Stage 2 Urban Design Study with any suggestion that it will be important in development control decision making. The Council's response to these representation is addressed in under the Tall buildings policy (DMS4) of this document.
3.259 The Battersea Society consider the tall buildings policy that relates to Clapham Junction confusing and unhelpful as the Core Strategy identifies the town centre as an area where tall buildings 'may be appropriate' and then the SSAD identifies the town centre as 'sensitive' to tall buildings, with a height of 5 storeys being the height at which buildings are considered to be 'tall' and trigger assessment against the tall buildings policy. No changes are proposed in response to this representation, as while Core Strategy Policy IS3 did identify town centres generally, as locations where tall buildings may be appropriate, it went on to say that some locations within these areas will be sensitive to, or inappropriate for, tall buildings. The further work that has been carried out as part of the Stage 2 Urban Design Study has resulted in the identification of the town centre as sensitive to tall buildings, because of its rich historic heritage. The S2UDS acknowledges the different characteristics of the town centre in the 'Urban Characterisation' section and while a building will be considered 'tall' at 5 storeys, buildings below this height will always be subject to other policies in the development plan, such as DMS1 and DMS2, which require consideration of amenity impacts and effects on the historic environment.
3.260 UK Power Networks (EDF Energy) consider the key to the maps should be changed so that the numbers are the minimum acceptable height where tall buildings are proposed. This is on the basis that planning permission has been granted for 8 buildings ranging from 2 to 21 storeys in the vicinity of their site. This is not accepted, as a planning permission for an adjacent site is not justification for tall building in any
104 DMPD & SSAD Proposed Submission Statement of Consultation
location. The policy base needs to be in place for the Council to assess future applications for tall buildings in this location. Any building of 9 storeys and above would need to be justified in terms of DMPD Policy DMS4.
SSAD Appendices
Representor Representor Repersentation Soundness test reference number number (1) Justified
(2) Effective
(3) Consistent with National Policy
Appendix 1 - Gypsy and Traveller provision
Mr Peter Carpenter 491438 171 1, 2, 3
Appendix 2 - Tall buildings maps
Barton Willmore 491197 134 1, 2
Threadneedle Property Investments and 495034 249 Not specified Prices Securities Ltd
Battersea Society 999 202 Not specified
UK Power Networks (EDF Energy) 1326 256 Not specified
Appendix 3 - Housing Trajectory
No representations received.
Appendix 4 - Proposals Map site references
No representations received.
105 DMPD & SSAD Proposed Submission Statement of Consultation
4 Next steps
4.1 The changes described throughout the document have been included in the Submission versions of the Development Management Policies Document and Site Specific Allocations Document. The DMPD and SSAD will be submitted to the Secretary of State in May 2011. All representations received will be considered at an Examination in Public to be conducted by an Independent Planning Inspector. The Inspector's report will be binding on the Council. Adoption of the documents is anticipated in April 2012.
4.2 For further information:
Phone: (020) 8871 6647, 6649, 6650 Email: [email protected] View our website at: www.wandsworth.gov.uk/planning Write to us at: Planning Policy, Town Hall, Wandsworth High Street, London SW18 2PU
106 DMPD & SSAD Proposed Submission Statement of Consultation
Appendices Appendix 1 Statutory letter and list of Statutory Consultees
Statutory Letter
Wandsworth Council Technical Services Department The Town Hall Wandsworth High Street London SW18 2PU
Please contact: Planning Policy Telephone: (020) 8871 6649/6650 Fax: (020) 8871 6003 Email: [email protected] Web: www.wandsworth.gov.uk Minicom: (020) 8871 8403
Our ref: LDFOct10 Date: 28 October 2010
Dear Sir/Madam
Wandsworth Local Development Framework
Core Strategy: Notice of Adoption
Wandsworth Council is pleased to announce that its Core Strategy Development Plan Document (DPD) was formally adopted by the Council on 20 October 2010. The Core Strategy sets out the Council's spatial vision, strategic objectives and spatial strategy on how the Borough should develop over the next fifteen years along with core policies and information on monitoring and implementation. The Core Strategy is part of the Local Development Framework (LDF), which will eventually replace the Unitary Development Plan (UDP) adopted August 2003.
Copies of the Core Strategy along with the associated supporting documents are available for inspection at the Technical Services reception at Wandsworth Town Hall and the Borough’s libraries during normal opening hours.
For further information please see the attached Adoption Notice for the Core Strategy.
Development Management Policies Document (DMPD) and Site Specific Allocations Document (SSAD) Proposed Submission: Notice of publication
Wandsworth Council is also publishing the proposed submission versions of the Development Management Policies Document (DMPD) and Site Specific Allocations Document (SSAD), which are also part of the emerging Local Development Framework (LDF) and support the Core Strategy.
Extensive consultation on the DMPD and SSAD has already taken place, which you may well have taken part in. We have considered all representations submitted, carried out a Sustainability Appraisal on all options and have now produced the proposed submission versions of the DMPD and SSAD which we consider meet the tests of soundness set out in the regulations.
We are now publishing the proposed submission versions to allow stakeholders to make comments regarding the soundness of the DMPD and SSAD. This stage differs from previous consultation stages in that representations should relate only to the soundness of the plan. The issues and policies in the DMPD and SSAD have already been extensively discussed and consulted on and it is intended that only very minor changes will be made before the documents are submitted to the Secretary of State.
I enclose a copy of the DMPD and SSAD and associated Proposals Map, Statement of Consultation and response form and Sustainability Appraisal Reports incorporating Equalities Impact Assessment. Further supporting documents and the wider evidence base can be viewed on our website www.wandsworth.gov.uk/planning
The documents are also available for inspection at local libraries and the One-Stop Reception at the 5th Floor, New Town Hall, Wandsworth High Street, SW18. For further information or to request a copy of the supporting documents visit our website www.wandsworth.gov.uk/planning or phone 020 8871 6647, 6649 or 6650 or e-mail the [email protected] or write to the Planning Policy, The Town Hall, Wandsworth High Street, London SW18 2PU.
We are encouraging the use of electronic responses, which saves paper, speeds up the process of recording and analysing comments and enables you to see your previous responses in later consultations. Our LDF webpage will take you directly through to this on-line consultation system. It will be helpful to us if you can use it to submit your response. However if you do not use the electronic form then there is a paper response form which can be used, further copies can be requested from the above contact sources. Please note that your responses and name (but not your contact details) will be made available for public inspection and as such cannot be treated as confidential.
Consultation will begin on Friday 29 October 2010. All representations must be received by Friday 10 December 2010.
Representations may be accompanied by a request to be notified at a specified address that the DMPD and SSAD have been submitted to the Secretary of State for independent examination, and of the adoption of the DMPD and SSAD.
I look forward to receiving your views.
Yours sincerely
Martin Howell for Director of Technical Services
Statutory Consultees
British Gas plc Cable & Wireless Coal Authority Department for Transport E.ON EDF Energy EDF Energy c/o BNP Paribas Real Estate English Heritage Environment Agency Greater London Authority Highways Agency London Borough of Hammersmith London Borough of Lambeth London Borough of Merton London Borough of Richmond London Development Agency London Electricity Metropolitan Police Service c/o CgMs Consulting Mobile Operators Association National Grid Natural England Network Rail Royal Borough of Kensington & Chelsea Royal Borough of Kingston-upon-Thames Scotia Gas Network South West London NHS Support Services Partnership Thames Water Transport for London Virgin Media Vodaphone Ltd Wandsworth PCT Wandsworth Teaching Primary Care Trust Westminster City Council
Appendix 2 Non-statutory letter and list of Consultees
Non-statutory letter
Wandsworth Council Technical Services Department The Town Hall Wandsworth High Street London SW18 2PU
Please contact: Planning Policy Telephone: (020) 8871 6649/6650 Fax: (020) 8871 6003 Email: [email protected] Web: www.wandsworth.gov.uk Minicom: (020) 8871 8403
Our ref: LDFOct10 Date: 28 October 2010
Dear Sir/Madam
Wandsworth Local Development Framework
Core Strategy: Notice of Adoption
Wandsworth Council is pleased to announce that its Core Strategy Development Plan Document (DPD) was formally adopted by the Council on 20 October 2010. The Core Strategy sets out the Council's spatial vision, strategic objectives and spatial strategy on how the Borough should develop over the next fifteen years along with core policies and information on monitoring and implementation. The Core Strategy is part of the Local Development Framework (LDF), which will eventually replace the Unitary Development Plan (UDP) adopted August 2003.
Copies of the Core Strategy along with the associated supporting documents are available for inspection at the Technical Services reception at Wandsworth Town Hall and the Borough’s libraries during normal opening hours.
For further information please see the attached Adoption Notice for the Core Strategy.
Development Management Policies Document (DMPD) and Site Specific Allocations Document (SSAD) Proposed Submission: Notice of publication
Wandsworth Council is also publishing the proposed submission versions of the Development Management Policies Document (DMPD) and Site Specific Allocations Document (SSAD), which are also part of the emerging Local Development Framework (LDF) and support the Core Strategy.
Extensive consultation on the DMPD and SSAD has already taken place, which you may well have taken part in. We have considered all representations submitted, carried out a Sustainability Appraisal on all options and have now produced the proposed submission versions of the DMPD and SSAD which we consider meet the tests of soundness set out in the regulations.
We are now publishing the proposed submission versions to allow stakeholders to make comments regarding the soundness of the DMPD and SSAD. This stage differs from previous consultation stages in that representations should relate only to the soundness of the plan. The issues and policies in the DMPD and SSAD have already been extensively discussed and consulted on and it is intended that only very minor changes will be made before the documents are submitted to the Secretary of State.
Copies of the DMPD and SSAD and associated Proposals Map, Statement of Consultation and response form and Sustainability Appraisal Reports incorporating Equalities Impact Assessment are available for inspection at local libraries and the One-Stop Reception at the 5th Floor, New Town Hall, Wandsworth High Street, SW18. All documents and the wider evidence base are available on our website www.wandsworth.gov.uk/planning. For further information or to request copies of the documents phone 020 8871 6647, 6649 or 6650 or e-mail the [email protected] or write to the Planning Policy, The Town Hall, Wandsworth High Street, London SW18 2PU.
We are encouraging the use of electronic responses, which saves paper, speeds up the process of recording and analysing comments and enables you to see your previous responses in later consultations. Our LDF webpage will take you directly through to this on-line consultation system. It will be helpful to us if you can use it to submit your response. However if you do not use the electronic form then there is a paper response form which can be used, further copies can be requested from the above contact sources. Please note that your responses and name (but not your contact details) will be made available for public inspection and as such cannot be treated as confidential.
Consultation will begin on Friday 29 October 2010. All representations must be received by Friday 10 December 2010.
Representations may be accompanied by a request to be notified at a specified address that the DMPD and SSAD have been submitted to the Secretary of State for independent examination, and of the adoption of the DMPD and SSAD.
I look forward to receiving your views.
Yours sincerely
Martin Howell for Director of Technical Services
Non-Stat (groups)
Company / Organisation 5th Putney Sea Scouts 6H Design Abbotsleigh Road Residents' Association Ackroydon Residents' Association Action Space London Events Ltd Addition Land Ltd & Network Rail Age Activity Centre Ahmadiyya Muslim Association Akzo Nobel (CPS) Pension Scheme Alex Imlach Architects All Saints C of E Church All Saints C of E Church Allen Briegel New Homes & Development Alliance Environment and Planning Al-Muzzammmil Mosque & Community Centre Alsop Verrill LLP Alsop Zogolovitch ANA Architecture Anastasia Limited Anchor Congregational Church Ancient Monuments Society Antler Homes Architects Journal Architectural Practise Architecure PLB Arndale Estate Residents Association Arnold Gilpin Associates Ltd Arqiva Arriva London Art in the Open Ashcroft Technology Academy Asian Muslim Community Centre Assael Architecture B&Q Plc Balham & Tooting Sports & Social Club Balham Baptist Church Balham Mosque Balham Seventh Day Adventist Church Balham Society Balham Town Centre Management Office Ballymore Group Barratt Homes Limited Barratt West London Barrowfen Properties Ltd Bartlett School of Planning Battersea Arts Centre Battersea Central Methodist Mission Battersea Civic Society Battersea Conservation Concern Battersea Dogs and Cats Home Battersea Fields Resdients' Organisation Battersea Islamic Cultural and Educational Centre Battersea Methodist Mission Battersea Police Battersea Power Station Community Group Battersea Society Battersea Society/Friends of Battersea Park Battersea Spritualist Church Battersea Village Residents' Association Baylight Properties Plc. Behrens Sharp Bellevue Road Residents Association Bellway Homes (SE) Ltd Berkeley First Berkeley Group Ltd Berkeley Homes (Central London) Ltd Berkeley Homes (Urban Developments) Ltd Binley & Winchfield Houses Tenants' Association Black Rights Group BNP Paribas Real Estate Boldfort Ltd Bolingbroke Hospital Bonsor Penningtons Commercial Borough Residents' Forum BP Oil (uk) Branston & Company Architects Briargrove Ltd (Upper Richmond Rd) Brindle Developments British Gas British Motorcylists Federation British Red Cross British Wind Energy Association Brooksplace PLC Broomwood Methodist Church Buddapadipa Temple Bupa Burgess Mean Architects Business Link 4 London C.E.P Developments Ltd CABE Calor Gas Ltd Campaign for Real Ale Campaign for Real Ale SW London Branch Capital Studios Cappagh Care Quality Commission Careline Information Centre for Wandsworth Carey Gardens Co-operative Ltd Carmalt Gardens Residents' Association Carr-Gomm Society CB Richard Ellis CBRE CDC 2020 CEMEX Cemex UK Materials Ltd Central Caspian Holdings Centre Academy School Centre for Accessible Environments CgMs Consulting Charles Church Southern Chartered Architects Charterhouse Chas Newens Marine Co Ltd Chatham Road Residents' Association Chelsea Estates Ltd Chelsea Society Chesterton Primary School Childrens Flower Society Childrens Society Christ Church C of E Church Christie's Christopher Wickham Associates Church Commissioners Church of Our Lady and St Peter Church of the Sacred Heart (RC) Citizens Advice Bureau Civil Aviation Authority Clapham Antiquarian Society Clapham Junction Action Group Clapham Junction T C Management Office Clapham Society Client of Iceni Projects Ltd Cluttons LLP CMW (Property Preservation) Ltd Coal Authority Colliers CRE Communities & Local Government Community Safety Network Company of Watermen and Lightermen Confederation of British Industry Confederation of Indian Organisations UK Congregational Union of Ethnic Churches Conservation Architecture & Planning Conservation Dept, The Garden History Society Conservation for British Archaeology Contact a Family Corporation of London Costco Wholesale Uk Limited Council for British Archaeology Council for the Protection of Rural England Courtney Joyce Covent Co-operative Ltd Covent Garden Market Authority Covent Garden Tenants' Association Ltd Craftwork Interiors Crest Nicholson Residential (South) Ltd Croatian Centre Curatus Trust (Mauritius) Ltd Cushman & Wakefield Cushman and Wakefield LLP Cyril Mansions Residents' Association Dalton Warner Davis Dandara Danemere St/Ashlone Road Residents' Assoc. Danul Amaan Islamic Centre David & Miriam Howitt Architects David L Walker Chartered Surveyors David Le Lay Ltd Dean & Co. Defence Estates (MOD) DEFRA Delancy and Land Securities (Clapham Junction) Deodar, Merivale & Florian Roads Residents' Assoc. Department for Culture, Media & Sport Department of Health Design Group Nine Development Planning Partnership DevPlan Dialogue Diamond Conservation Area and Heathbrook Park Residents Diocese of Southwark Property Department District Valuer Wimbledon Doddington & Rollo Community Associtaion Doddington (West) Residents' Association Doddington Resource Centre Dover House Residents' Association DP9 DPDS Consulting Group Drivers Jonas LLP DTZ Consulting and Research Du Cane Court Residents' Association Earlsfield Baptist Church Earlsfield Police Station East Hill Baptist Church Eclipse Hotels Economic Development Office Edward Potter Associates Architects Edwin Evans EKAYA Housing Association Ellisons Elsynge Road Residents' Association Empty Homes Agency English Hertiage (GLAAS) English Sports Council Environment Agency Equality and Human Rights Commission Esher Gardens & Bisley House Residents' Assoc. Ethelburga Estate Residents' Association Ethelburga Tower Residents Association European Metal Recycling Limited Evangelical Church of Yahweh Evolve F J Keen & Son Ltd Fairview New Homes Ltd. Fairview New Homes Plc Fashion Street Regeneration Faylands Area Residents' Association Federal Express Inc (FEDEX) Felsham Road Co-op Ltd Fields in Trust Firstplan Fitzhugh Grove Residents' Association Forestry Commission Forward Planning & Transportation, L B Newham Foster and Partners Frasers Riverside Quarter Ltd Freight Transport Association Frendcastle Friends of Battersea Park Friends of Clapham Common Friends of the Earth (London Region) Friends of the Tooting Commons Fulham Society Fusion Fusion Online Limited Gander & White Shipping Ltd Garden History Society Garfield Community Centre Gargoyle Wharf Community Action Group Garratt Business Park Geoffrey Reid Associates George Wimpey City Ltd Georgian Group Gerald Eve GLE Properties Goldcrest Graham Hatt & Partners Granit Architects Greater London Archaeology Advisory Service Greater London Authority Greater London Enterprise Greek Church of St Nectarios Green Party Groundwork UK (London & SERegional Offices) GVA Grimley LLP GVA Grimley Ltd Gwendolen Avenue Residents' Association Hamilton Associates Architects Hamilton Ice Sculptors Hamptons International Hanover Housing Association Hayward & Pullman Gardens Residents' Association Hazlehurst Estate Residents' Association Health & Safety Executive Helical Bar (Silverthorne Road) Helical Bar and National Grid Helical Bar/Lattice Pension Fund (Tideway) Her Majesty's Court Service Hightrees House (Clapham Common) Ltd. Highways Agency Hilsea Residents' Association Hindu Society HM Prison Service Headquarters Holden & Partners Holy Trinity C of E Church Home Builders Federation Homes and Communities Agency Hook Consultancy House Builders Federation Houston Lawrence Ltd Iceni Projects Imani Project Indigo Planning Ltd Inland Waterways Association (London Region) Investate Ipcress Limited Islamic Community J C Francis & Partners James Fisher & Son JCMBP Jehovah's Witnesses Jensen Tyrrell Job Centre Plus Jobcentre Plus Jonathan Smith Digital Architects Jones Lang Lasalle Katherine Low Settlement Keildon Road Residents' Action Group Khalsa Centre King Sturge LLP Kingsley Associates (Architects) Kingston University Kinleigh Folkard & Hayward Kish Six Ltd KSP Building Design Consultants Ltd Kumara Developments Ltd Labour Party Lafarge Aggregates Ltd Lambeth Primary Care Trust Lammas Motors Langdon Investments Lascelles Antiques Lavender Hill Traders Association Lawn Tennis Association LB Wandsworth LCCI/CBI London Manufacturing Group Learning and Skills Council, London Central Lennon Planning Ltd Lennox Estate Residents' Association Levvel Consulting Ltd Lewis Hickey Planning Ltd Lidl Uk GmbH Life Tabernacle Church Linden Homes (Chiltern) Lipinski Pates Architects Local Government Associtaion Local Spiritual Assesmbly of the Baha'is of Wandsworth London & Central European Investments London & Quadrant Housing Trust London & Quadrant Threshold Homes London Biodiversity Partnership London Borough of Barnet London Borough of Bexley London Borough of Brent London Borough of Bromley London Borough of Camden London Borough of Croydon London Borough of Enfield London Borough of Hackney London Borough of Haringey London Borough of Harrow London Borough of Havering London Borough of Hillingdon London Borough of Hounslow London Borough of Islington London Borough of Lambeth London Borough of Lewisham London Borough of Richmond London Borough of Southwark London Borough of Sutton London Borough of Tower Hamlets London Borough of Waltham Forest London Central/General Buses London Councils London Cycling Campaign London Fire and Emergency Planning Authority London Fire and Emergency Planning Authority London First London Forum of Amenity & Civic Societies London General Transport Services Ltd London Heritage Ltd London Historic Parks & Gardens Trust London Housing Federation London Mosque London Planning & Development Forum London Port Health Authority London Rivers Association London Society London South Bank University London Tideway Harbour Co. Ltd London Transport Users Committee London TravelWatch London Underground Ltd London Wildlife Trust Long & Co Lord Foster & Partners Louvaine Area Residents' Association Ludo Press MacKenzie Wheeler Architects Malcolm Judd & Partners Manifest Marinezone Ltd Mark Jordan Architecture Martineau McCarthy and Stone UK Ltd MDR Associates Metro Shopping Fund LP MetroFund LLP Metropolitan Housing Partnership Metropolitan Police Service Metropolitan Support Trust Michael Aukett Architects Michael Evans Architects Michael Shanly Homes Milland House Residents' Association Minerva Plc Ministry of Defence Montagu Evans Morrisons Supermarkets PLC Motorcycle Action Group Mr Carpet Ltd Museum of London Archaeology Service Mushkil Aasaan Project National Air Traffic Services Ltd National Family & Parenting Institute National Grid Company Plc National Grid Property National Offender Management Service Neighbourhoods Initiative Foundation Network Rail Network Rail Infrastructure Limited NHS London Healthy Urban Development Unit NHS Wandsworth Nightingale Area Conservation Society Nightingale House Northcote Business Network Northcote Road Residents' Action Group Notting Hill Home Ownership Notting Hill Housing Group Oak Trading Ltd Object Architecture Ltd Oily Cart Theatre Company Older Persons Forum Wandsworth Oliver Colvile Oracle Group Ormeley Road Residents' Association Outer Space Oxygen Estates P D A Partnership London P D Elkins Drawing Services Ltd P W Lee & Associates Parkinsons Disease Society Wandsworth Parkside Community Project Patmore Co-operative Ltd Peabody Trust Peacock & Smith Peacock and Smith Limited Persimmon Homes Ltd Peter Pendleton Associates Pike Practice Planning Aid for London Planning Bureau Ltd Planning Inspectorate Planning Magazine Planning Potential Plantation Wharf Association Plowden & Smith Pocklington Resource Centre Polish Benevolent Fund Balham Parish Port of London Authority Post Office Property Holdings PRC Fewster Architects Price Partnership Primrose Mansions Ltd Prince of Wales Drive Environmental Committee Public & Commercial Services Union Puppet Centre Trust Pure Package Putney Evangelical Church Putney Labour Party Putney Partnership Board Putney Society Putney Town Centre Partnership Board Putney Vale Youth Group Quinton Scott & Co R J Associates Raglan Housing Association Ramblers Association (Hammersmith, Fulham&W'worth) Ranelagh Sailing Club Ltd (The Embankment) RB Kensington & Chelsea REO (Powerstation) Ltd Resinvest IOM Two Limited Rich Investments Ltd Richard Rogers Architects Ltd River Thames Society Riverhaven Riverside Plaza Residents' Association Riverside Quarters Residents Association Road Haulage Association Robert Beeby Architects Rockspring Hanover Property Unit Trust (RHPUT) Roehampton Club Ltd Roehampton Partnership Roehampton Quadrant Residents' Association Roehampton University Roger Khoryati T/A McDonalds Roger Tym & Partners Rolfe Judd Planning Rotary Club Tooting Royal College of Art Royal Mail Group Plc Royal Mail London South Mail Centre Royal Parks Estate Management RPS RPS Planning and Development Russell-Cooke Solicitors Rydevale Day Nursery Sainsbury's Stores Ltd Sainsbury's Supermarkets Ltd Saloria Architects Salvation Army Sapcote Property Developers Savills Commercial Ltd Scotts Scotts Surveyors Secondsite Property Senex Capital Ltd Service Developments Holdings Limited Servite Thames Seymour Road SW18 Residents' Association Share a Family Sheppard Robson Sikh Gurwara Simon Smith & Michael Brooks Sir James Barrie School SITA UK Sleaford Street Management Company Ltd Smech Management Company Ltd Society for the Protection of Ancient Buildings Solid State Design Ltd Solon Design Somerfield Stores Ltd. Somerset Residents' Association South London Business South London Catholic Caribbean Association South London Guardian Newspaper South London Islamic Centre South London Land & The Haywoods Group South London Partnership South London Press South Thames College South West London Community NHS Trust Estates South West London Health Authority Southern Southern Properties Ltd (Oyster Wharf) Southfield Group Practice Southfields Baptist Church Southfields Grid Residents' Association Southfields Triangle Residents' Association Southwark Diocesan Advisory Committee Space Design Consultants Ltd Spacia Business Centre Sport England London Region St Alban's C of E Church St Barnabas C of E Church St Boniface R C Church St George (South London) Ltd St George's Healthcare NHS Trust St Georges Hospital St James Investments St James's Investments & Keltbray Ltd St Joseph's R C Church St Luke's C of E Church St Margaret's Church Office St Mary Magdalene C of E Church St Mary's C of E Church St Mary's Primary School St Nicholas C of E Church St Paul's C of E Church St Paul's Church of England St Stephen's C of E Church St Thomas A Becket R C Church St Vincent de Paul Presbytery St. Georges Hospital Stargas Nominees Limited Steer Davies Gleave Stewart Ross Associates Summerstown Mission Evangelical Church Support and Housing for People with Disabilities Sustrans Sustrans-National Cycle Network Sutherland Grove & Area Residents' Association SW London & St George's Mental Health NHS Trust Tara Arts Director Taylor Williams Daley Partnership Tenant Services Authority Tesco Stores Ltd TfL Surface Transport Thames Angling Preservation Society Thames Water Theatres Trust Tonsley Residents' Association Tooting Liberal Democrats Tooting Methodist Church Tooting Police Station Tooting Town Centre Partnership Board Tooting United Reformed Church Top Flight Loft Conversions Total Healthcare Solutions Totteridge House Co-operative Ltd Totting Islamic Centre Tower Housing Association tp bennett TR Property Investment Trust PLC Traffic Transport and Parking sub-committee Transformer Properties Ltd Transport for London Transport for London Land Use Planning Transport for London Street Management Tranwood Properties Treasury Holdings (Battersea Power Station) Trident Business Centre Trinity Fields Trust Trovecroft Trust Planning ltd Tunworth Cresent Residents' Association Turley Associates Twentieth Century Society Unite Group Plc United Response Upper Tooting Methodist Church Urban-Link Valiant House Properties Ltd Vanik Association of the UK Vauxhall Society Victoria Drive Conservation Area Residents Association Victorian Society Visit London Volume 3 Ltd W J Marston & Son Ltd Walsh Wandle Heritage Ltd Wandle Trust Wandsworth Access Association Wandsworth Asian Community Centre Wandsworth Bereavement Service Wandsworth Borough Police Wandsworth CABX Wandsworth Care Alliance Wandsworth Chamber of Commerce Wandsworth Common Management Advisory Committee Wandsworth Community Empowerment Network Wandsworth Community Transport Wandsworth Council Wandsworth Cycling Campaign Wandsworth Cyclists Wandsworth Environment Forum Wandsworth Friends of the Earth Wandsworth Mencap Wandsworth Mind Wandsworth Older People's Forum Wandsworth Primary Care Trust Wandsworth Riverside Quarter Ltd Wandsworth Society Wandsworth Town Centre Partnership Wandsworth Voluntary Sector Development Agency Wandsworth, Chelsea & Fulham Sea Cadets Watson Woods Partnership WEF/Putney Society Welcare in Wandsworth Wereldhave Property Management Company Ltd West London River Group West Side Church Western Riverside Transfer Station Western Riverside Waste Authority Westmark Point Residents' Association Westminster Kingsway College Weston Aviation Weston Aviation Ltd Westside Residents' Associaton Wimbledon and District Synagogue Wimbledon and Putney Commons Conservators Wimbledon Park Co-operative Ltd WISH Women's Design Service Woodland Trust Workspace Glebe Ltd Workspace Group PLC Young & Co Youngs Brewery Zurich Assurance Ltd and Princess Securities Ltd
Non-Stat (individuals)
Grace Abbott Mrs and Miss BP and M Adams Jessica Adams Irene Adams Miss Tammy Adams Mr J Adams Mr James Adutt John Ager Robert Allen Dr Ghazwa Alwani-Starr MR David Annett Mr John Archer Mr Matthew Armstrong C R Atkins Mr Marco Baldini Dr David Bamber Mrs Sonia Barbero David Barttelot Mrs Sarah Basden Mr David Bellamy J Belle mr colin beswick Mr Paul Birtwistle Iona Bowen Mr Rob Bowen Mr Box Philip Bradley Duncan Braithwaite Margaret Brett Chris Brodie Mr Alistair Brown Georgia Brown Jonathan Brown Brown Mr Andrew Brown Liz Bryant Fiona Bunker Mr Mike Burkard Mr Adrian Burn Mr Gareth Campbell Colin Campbell Miss D G Carr Mr Andrew Catto Mrs Evelyn Caulcott Ms Vanessa Celosse Chapman Mr James Cheverton Mrs D G Clark Gemma Clarke Mr Ben Clarke Mrs S A Clerk Mrs E Clifton Olivia Collier Elizabeth Collingridge Joanna Cook Ms Sarah Cooke Mr Martin Coombs Dee and Chris Cooper Henry G Copeman Mr & Mrs Cox Mr Tim Cutts Mr James Dalton Zal Davar Councillor Peter Dawson Kim Dewdney Victoria Diamond Carol Dodds Mr Colin Doherty Ms Lesley Donegan Janet Duff Jane Eades Tim Edmundson Sally Ellaway Jonathan Ellerbeck Mrs Margaret Engering Phil Errington Ms Lynne Evans Lynne Evans Kathy Everett Featherstone Mrs Mary Ffrench Kristina Fitzsimmons Mr Greg Fletcher Siobhan Fox and B Roberts Rev G Fraser Mr Garry Hutchinson Helen Giblin Ms Alexandra Gillam mrs jean gilmore Mr Phillip Giraud D Glazebrook Edward Goodchild Gorton Mr Michael Graubart Ian Green Justine Greening Mr Nathan Hardman Mr Keith Hawkins Paul Henry Margaret Heriot Mr Farrokh Hessamian Charles Hickie Fiona and Andrew Higgins Ben Hirschfeld Simon Ho Miss M Hogan Mabel and Bob Holl Robert Hollamby Mr Michael Howie Mrs and Miss G.C. & A Hughes mr adam hutchings Garry Hutchinson M Illand David Irwin Mr Jon Irwin Mr Paul Jackson Yvonne and Mr and Mrs Tom James Mr Tom Jestico D A Johnson Julian Berry Ms Ailis Kane Muhammad Kashif Kelly Phillips Mr Moiz Khanbhai P J King Dr T Krakowska Miss Anna Kruczkowska Mr Henry Latin Caroline Law Mrs Barbara Lees Michael Leigh Alexis Leonidou H.P Libby Victoria Lloyd-Roberts Kate Lody Mrs S Luce Stephen Luxford Gregor Mackie Mr Christopher Maddock Mr William Manser Ben Marks Mr Mattinson Soumaya Mauthoor Andrea Maynard Mr Alan McDermott Patrick McGurk Carolyn McMillan Councillor Charles McNaught-Davis Mr Tom Michie Mr Lennox Moore Jane Morley Oliver Murray H J Mylchreest Mr Clive Narrainen Anna Newey Mr Sydney Newman Mr Niazi Miss Gemma Nicholls Miss Kathryn Oakley Mr Craig O'Brien Janet Odden Roy O'Flanagan Andrew Ottley Miss Elizabeth Owen Jackie Parker John Parmiter Sarah Parr Mrs Shirley Passmore Mrs Rozie Pether Moray Pike Ms Amma Poku Caroline Porter Mr M Poulter Mrs Patricia Poulter Mr Andrew Pringle Mr Michael Radcliffe Jane Ratcliffe Mr Hugo Raworth Mrs Mary Rees Mr Clive Rees Ms Meshel Rhooms Mr R S Rihal Mr Roberts Mr John Robertson Mrs Karen Robinson Gavin Robinson Charlie Roe Bridget Rosewell Mr Gordon Ross Mr Paul Rossiter Melissa Royde Mr S J Ryan Ms P Ryan Mr Iqbal Sacranie Ms Nicola Sanderson Nick Satornetti-Portway Veronica Saunders Mrs S P Schwimmer Ms C.M Sewell Mr Sewell Pamela Shaikh Ms Harriet Shelton Ms Lauren Simpson Ms Susie Smith Miss Jenny Stafford Sharon Stewart Mr Stewart Ruth Stuart Ms Yuko Suganuma Simon Tarasiuk Mr Rowan Taylor Mr Nicky Thompson Carol Tibbs Mr Simon Tod Mrs A Todorova Mrs Barbara Traill Mr John Turner F I M Vandenberg Simon Vince Mrs Viney Mr Mario Vlachakis Miss Helen Wada Mr Harry Waddingham Mrs Liz Walton Waters Mr L L Waterston Mr Henry Welch Mr george whalley Ms Gillian Wightnick Mr Gerald R Williams Mr Bernd Max Williams Helen Williams Glyn Williams Gail Wilson Nicholas Wilson Mrs Isabel Wooller Professor James Woudhuysen Walter Xerri Emma Young
Appendix 3 – Waste Site Letters and Recipients
Letter regarding allocated sites
Wandsworth Council Technical Services Department The Town Hall Wandsworth High Street London SW18 2PU
Please contact: Adam Hutchings Telephone: (020) 8871 6650 Fax: (020) 8871 6003 Email: [email protected] Web: www.wandsworth.gov.uk Minicom: (020) 8871 8403
Date: 28 October 2010
Dear Sir/Madam
Wandsworth Local Development Document Consultation on the Site Specific Allocations Document – Proposed Submission
Wandsworth Council is seeking your views on the Proposed Submission version of the Site Specific Allocations Document (SSAD). This document complements the Council’s Core Strategy by setting out the main sites where development or other change is anticipated in the Borough, where the Council has particular objectives or is promoting specific proposals. The document forms part of the emerging Local Development Framework (LDF) that will eventually replace the adopted Unitary Development Plan (UDP).
We are specifically writing to you as your site [insert relevant site name] has been identified as a site which is allocated for waste management facilities. The site is allocated in order to meet the Borough’s waste apportionment figure set out in the London Plan.
The allocation of this site has been justified in the Council’s Waste Site Selection evidence base document which is enclosed for your information, along with a copy of the SSAD.
The Council will shortly be undertaking consultation on the Proposed Submission Versions of its SSAD and is offering to hold meetings with landowners of allocated waste management sites to discuss the content of the documents, and process from here.
If you are interested in discussing this with the Council please contact Adam Hutchings on 020 8871 6650 or [email protected].
The proposed submission SSAD will be published for consultation for a six week period, from 29th October to 10th December 2010, to allow stakeholders to make comments regarding the soundness of the plan. This stage differs from previous consultation stages in that representations should relate only to the soundness of the plan (see enclosed guidance). The issues and policies in the SSAD have already been extensively discussed and consulted on and it is intended that only very minor changes will be made before the document is submitted to the Secretary of State.
The Site Specific Allocations Document, together with the associated Sustainability Appraisal Reports, can be viewed on our website www.wandsworth.gov.uk/planning The documents are also available for inspection at local libraries and the Technical Services Reception at the 5th Floor, Town Hall Extension, Wandsworth High Street, SW18 2PU. For further information visit our website www.wandsworth.gov.uk/planning or phone Planning Policy on 020 8871 6649/6650 or e-mail [email protected] or write to Planning Policy, Planning Service, The Town Hall, Wandsworth High Street, London SW18 2PU.
To make comments on the document, we are encouraging the use of the Council’s on-line consultation system, which saves paper, speeds up the process of recording and analysing comments and enables you to see your previous responses in later consultations. To use the online consultation system, please go to our LDF consultation portal: http://wandsworth-consult.limehouse.co.uk. If you have any problems using the system please contact Rhian Williams on 020 8871 6649 or [email protected].
If you do not wish to use the online consultation portal, please complete the paper response form. Please note that your responses will be made available for public inspection and as such cannot be treated as confidential. If you do not wish your telephone number and e-mail address to be made public, please provide these separately rather than including them on the form.
All representations must be received by Friday 10th December 2010.
We look forward to hearing from you.
Yours faithfully
Martin Howell for Director of Technical Services
Letter regarding allocated sites – Recipients
Recipient Site Nick Emery, Regional Property Manager, Biffa Waste Services, Pensbury Place Biffa Waste Limited Bob Hurcomb, Cappagh Head Office Cappagh Waste, The Willows, Riverside Road, SW17 Kevin Coleby, Estates Manager, Cory Cory Environmental Materials Recycling Environmental Limited Facility, Smugglers Way; Cory Environmental Waste Transfer Site, Pensbury Place Simon Dodd, Property Group Manager, European Metals Recycling, Pensbury European Metal Recycling Limited Place Kenny Hill, Westminster Transerv, Westminster Transfer, Silverthorne Road Stewarts Lane Depot
Letter regarding non allocated sites
Wandsworth Council Technical Services Department The Town Hall Wandsworth High Street London SW18 2PU
Please contact: Mr Adam Hutchings Telephone: (020) 8871 6650 Fax: (020) 8871 6003 Email: [email protected] Web: www.wandsworth.gov.uk Minicom: (020) 8871 8403
Our ref: DTS Date: 2 November 2010
Dear Sir/Madam
Wandsworth Local Development Document Consultation on the Site Specific Allocations Document – Proposed Submission
Wandsworth Borough Council has produced a waste site selection document as part of its evidence base for the allocation of sites in the Borough for waste management purposes.
As you may recall, we wrote to you in December 2009 seeking your views on whether your site may have potential for the location of waste management facilities identified within the preferred options version of the Site Specific Allocations Document (SSAD). After the consideration of responses received during the consultation period and analysis of sites contained in the waste site selection document, your site has not been allocated for waste management facilities.
If you would like to view the revised SSAD we are now publishing the proposed submission version to allow stakeholders to make comments regarding the soundness of the SSAD. This stage differs from previous consultation stages in that representations should relate only to the soundness of the plan. The issues and policies in the SSAD have already been extensively discussed and consulted on and it is intended that only very minor changes will be made before the documents are submitted to the Secretary of State.
Copies of the SSAD, Statement of Consultation and response form and Sustainability Appraisal Reports incorporating Equalities Impact Assessment are available for inspection at local libraries and the One-Stop Reception at the 5th Floor, New Town Hall, Wandsworth High Street, SW18. All documents and the wider evidence base are available on our website www.wandsworth.gov.uk/planning. For further information or to
request copies of the documents phone 020 8871 6649 or 6650 or e-mail [email protected] or write to Planning Policy, The Town Hall, Wandsworth High Street, London SW18 2PU.
We are encouraging the use of electronic responses, which saves paper, speeds up the process of recording and analysing comments and enables you to see your previous responses in later consultations. Our LDF webpage will take you directly through to this on-line consultation system. It will be helpful to us if you can use it to submit your response. However if you do not use the electronic form then there is a paper response form which can be used, and copies can be requested from the above contact sources. Please note that your responses and name (but not your contact details) will be made available for public inspection and as such cannot be treated as confidential.
Consultation will begin on Friday 29 October 2010. All representations must be received by Friday 10 December 2010.
Representations may be accompanied by a request to be notified at a specified address that the SSAD has been submitted to the Secretary of State for independent examination, and of the adoption of the SSAD.
I look forward to receiving your views.
Yours sincerely
Yours faithfully
Martin Howell for Borough Planner
Letter regarding non allocated sites – Recipients
Site Letter sent to 1 St Martins Way, SW17 Gander and White Shipping Export and Import Agents Unit 1 & Unit 2 St Martin’s Way Wimbledon London SW17 0JB
Riverside Yard, Riverside Road, SW17 Barbara Lascelles Lascelles Antiques 11 Riverside Road, London SW17 0BA
James Carr Concord Lifting Equipment 53 Riverside Road London SW17 0BA
Mahesh Rawal Essential Sales Products 38-39 Riverside Road, London SW17 0BA
Derek Smith Holman & Williams Packaging Riverside Yard London SW17 0BA
2-6 St Martins Way, SW17 The Big Bus Company Limited 48 Buckingham Place Rd London SW1W 0RN
National Grid Site, Riverside Road No correspondence. 100 Silverthorne Road Day Group Ltd Transport Avenue Brentford Middlesex TW8 9HF
London Concrete Ltd London House 77 Boston Manor Road Brentford
TW8 9JQ Network Rail Kings Place 90 York Way London N1 9AG
GENERAL Summerstown SIL Keith Stringer M&S Supplies 1 The Swan Centre Rosemary Road London SW17 0BA
Mike Powell CPS Supply Company 5 Lyndon Yard London SW17 0BA
Mr Lee Ingenious Productions 16 Riverside Road, London SW17 0BA
Peter Schwartz Bramfield Garage 32-34 The Swan Centre Rosemary Road London SW17 0BA
Susan Smith M Development 1-3 Riverside Road, London SW17 0BA
Jamie Hamilton Duncan Hamilton Ice Sculptor 54 Riverside Road London SW17 0BA
Luke Ryan Malcolm Ryan Studios 42-51 Riverside Road London SW17 0BA
Martyn Haines Compass Glass 25 Riverside Road, London SW17 0BA
Mr Carpet, 32 Riverside Road, London SW17 0BA
Nicholas Moll The Ludo Press 18 Riverside Road, London SW17 0BA
Sue Holding Boldfort 59-60 Riverside Road, London SW17 0BA
Appendix 4 – Letter to owner of Lammas Motors
Wandsworth Council Technical Services Department The Town Hall Wandsworth High Street London SW18 2PU
Please contact: Kristen McGavock Lammas Motors Telephone: (020) 8871 6650 Garratt Mills Fax: (020) 8871 6003 Trewint Street Email: Wandsworth [email protected] London Web: www.wandsworth.gov.uk SW18 4HD Minicom: (020) 8871 8403
Date: 21 October 2010
Dear Sir/Madam
Consultation on Site Specific Allocations Document - Proposed Submission
We wrote to you in December last year consulting on the allocation of your site for Gypsy and Traveller provision in the Preferred Options version of the Site Specific Allocations Document. We have now prepared the next version of the document, referred to as the Proposed Submission version, and this letter is to advise that the allocation of the Garratt Mills site for Gypsy and Traveller provision has now been removed.
The Garratt Mills site was proposed to be allocated in order to meet the need for additional gypsy and traveller pitches identified in the London Plan. The Mayor has indicated in “Minor Alterations to the consultation draft replacement London Plan September 2010, Gypsies and Travellers (including Travelling Show People) and Aggregates” that he proposes to replace policies on Gypsy and Traveller provision and associated targets with a different policy approach, to enable boroughs to address their requirements most effectively in light of local circumstances.
The Core Strategy; the Council’s overarching planning policy document, contains a commitment to review the Borough’s housing and affordable housing targets in light of changes to housing figures in the London Plan. The allocation of the Garratt Mills site for Gypsy and traveller provision has been removed from the Proposed Submission version of the SSAD, and the Borough’s requirements for additional Gypsy and Traveller pitches/site(s) will be reviewed as part of the Core Strategy review of housing requirements, to align with the published replacement London Plan. Further work will be undertaken at that time to review need and justify any site allocation.
We are now publishing the proposed submission version to allow stakeholders to make comments regarding the soundness of the plan. This stage differs from previous consultation stages in that representations should relate only to the soundness of the plan (see enclosed guidance). The issues and policies in the SSAD have already been extensively discussed and consulted on
and it is intended that only very minor changes will be made before the document is submitted to the Secretary of State.
The Site Specific Allocations Document, together with the associated Sustainability Appraisal Reports, can be viewed on our website www.wandsworth.gov.uk/planning
The documents are also available for inspection at local libraries and the Technical Services Reception at the 5th Floor, Town Hall Extension, Wandsworth High Street, SW18 2PU.
For further information visit our website www.wandsworth.gov.uk/planning or phone Planning Policy on 020 8871 6649/6650 or e-mail [email protected] or write to Planning Policy, Planning Service, The Town Hall, Wandsworth High Street, London SW18 2PU.
To make comments on the document, we are encouraging the use of the Council’s on-line consultation system, which saves paper, speeds up the process of recording and analysing comments and enables you to see your previous responses in later consultations. To use the online consultation system, please go to our LDF consultation portal: http://wandsworth- consult.limehouse.co.uk. If you have any problems using the system please contact Rhian Williams on 020 8871 6649 or [email protected].
If you do not wish to use the online consultation portal, please complete the paper response form. Please note that your responses will be made available for public inspection and as such cannot be treated as confidential. If you do not wish your telephone number and e-mail address to be made public, please provide these separately rather than including them on the form.
All representations must be received by Friday 10th December 2010.
We look forward to receiving your views
Yours sincerely
Kristen McGavock for Director of Technical Services
Appendix 5 – Brightside Advertisements
November Edition
Consultation Deadline Reminder in Brightside December/January Edition
Appendix 6 – Statutory Notice