AGENDA PART A ITEM

Report of: Development Manager

Date of Committee: 6th December 2007

Site address : Leggatts Campus, Leggatts Way

Ref. no.: 07/01268/FULM

Description of development: Redevelopment of site, comprising 248 dwellings (172 2- bed flats, 17 3-bed houses and 59 4-bed houses) a neighbourhood centre, public open space and associated parking and landscaping

Applicant: George Wimpey North Thames

Ward: Leggatts

Date received: 25.9.07

13 week date (major): 25.12.07 ______

SUMMARY

The proposal includes the redevelopment of the former Leggatts Campus site, comprising 248 dwellings (172 2-bed flats, 17 3-bed houses and 59 4-bed houses) a neighbourhood centre, public open space, a Locally Equipped Area of Play (LEAP) and associated parking and landscaping. The existing buildings on the site are to be demolished to make way for the new scheme.

The proposal was advertised in the Watford Observer, signs placed around the site and neighbour letters sent out to all adjoining occupiers. The application was also referred to statutory, internal and external consultees, with a majority of the responses containing

G 1 objections or concerns. There remain outstanding concerns in relation to highways, arboriculture, archaeology, urban design, crime prevention, drainage, noise, playing fields, flooding and ecology.

In general, the proposed layout of the site is not considered to address the draft planning brief for the site, and neither does it follow sound planning principles with regards to the relationship between buildings, spaces and movement. The proposed tenure of units in the division between affordable housing and open market is unacceptable and does not comply with either Council or national policies.

The proposal does not pay sufficient regard to the existing context of the site and surrounds and as a result unduly affects the residential properties to the west along Leggatts Way, the vistas along North Western Avenue and across the playing fields, and potentially prejudices the development of the BECC site immediately to the south.

This site is an important opportunity to provide a high quality scheme with the potential to create as little impact upon the existing neighbourhood as possible. It is an opportunity to create an individual identity, whilst still respecting the housing and open spaces that surround it. However, in contrast to these aims, the current proposal fails to achieve compliance with many of the objectives in the draft planning brief, the Watford District Plan 2000 or national planning policy statements and guidance. The applicant was given detailed advice at pre-application stage on a proposal almost identical to the one currently before the Committee. It is disappointing that this advice was not taken on board, and that little justification has been provided for the many instances where the scheme departs from established policies and guidance. The proposal is considered to be an unacceptable development of the site, and the Development Manager therefore recommends the application be refused as set out in the report.

G 2 BACKGROUND

Site and surroundings Leggatts Campus is a former Sixth Form College owned by West Herts College and has been operational as an educational institution since the late 1930s. The application site covers an area of 7.89 hectares and can be most easily identified by two distinct parcels of land. The eastern part of the site contains a grassed open space of approximately 4.72ha comprising 7 playing pitches. This area is a designated wildlife corridor on the proposals map in the Watford District Plan 2000 and abuts Harebreak Woods to the south which is designated as a Wildlife Corridor, a Wildlife Site and a Local Nature Reserve on the Proposals Map.

The western part of the site (approximately 3.17ha) is comprised of the now redundant College buildings and surrounding hardstanding and soft landscaping.

The site is roughly rectangular in shape and is largely level. Apart from a limited number of trees within the core of the site, there is strong boundary demarcation to the north, comprised of a dense Hawthorn and Field Maple hedge and also second larger tree group (a mix of English Oak and Ash) to the west boundary between the site and Leggatts Way properties. There are smaller tree specimens planted at intervals along the access road and to the west of the playing fields. The submitted tree survey includes a plan indicating the precise location of the trees.

The applicant provided the following further assessment of the surroundings:

“The site is located in a primarily residential area, approximately 2.5km north of Watford town centre and Watford Junction railway station. To the west, the site is bounded by the rear gardens of inter-war housing fronting Leggatts Way. The style of these properties is generally two storey, detached, semi-detached or terraced dwellings set within regular sized plots. To the south of the built-up area of the site lies the Bill Everett Community Centre (BECC), a local community centre and leisure facility [owned by

G 3 Hertfordshire County Council and managed by Watford Borough Council]. The older building on the BECC is consistent with the style of the original College buildings and this is currently used as a youth facility and a crèche. Sporting facilities, including a swimming pool are accommodated in the newer buildings. Beyond the eastern boundary of the playing fields lies Cherry Tree Junior Mixed Infants’ School and the Jamia Mosque. The A41 North Western Avenue extends along the length of the site’s northern boundary.”

Proposed development Full planning permission is sought for the redevelopment of the site to provide 248 dwellings (172 2-bed flats, 17 3-bed houses and 59 4-bed houses), a neighbourhood centre, public open space and associated parking and landscaping. The proposal also incorporates a Locally Equipped Area of Play (LEAP).

Vehicular access is to be provided off the A41 (North Western Avenue) and Heather Lane. A further vehicular access may be possible from Leggatts Way in the future. However, this relies on the redevelopment of the BECC centre and therefore presently does not form part of this application.

The internal access road has been identified as a “Home Zone” and forms a U shape within the development. There are a number of paths through the development for pedestrians and cyclists.

The layout of the site concentrates a majority of the flatted units along the A41, although there is also a considerable number throughout the rest of the development. The northern set of flats (Type K) is arranged over 4 storeys in a U shape with a further arm attached to each end of the U. There is a public courtyard located at the centre of the U, and car parking to either end of the arms and between the building and the road. To the east of this block is a rectangular block of flats (Type E), also 4 storeys in height, that abuts both the A41 and the edge of the playing fields.

G 4 To the south of these flats, there are houses (Type F) fronting onto the playing fields which have been designed to address the exterior of the developable area. There are two blocks of flats (Type G) attached to the ends of these houses. The car parking for these houses and flats is located to the rear of the building, in a mixture of parking courts and garages which open directly onto the access road.

To the south of this building is a further block of flats (also Type E). The Locally Equipped Area of Play (LEAP) is sited to the east of the flats and houses, and encroaches into one of the playing pitches.

The Neighbourhood Centre (Type H) is located along the southern boundary of the site adjacent to the BECC site, with retail units at ground floor and residential flats above. This building is completely surrounded by car parking and access roads.

The houses (Types B, C and J) located along the western boundary abut the rear gardens of existing properties in Leggatts Way. The proposed dwellings are 2 and 2.5 storeys high and run both parallel and perpendicular to these properties. There is a small strip of land between Nos. 122 and 124 Leggatts Way that has been closed off for a long time. The applicant proposes to re-open this access to provide a pedestrian link through to Leggatts Way.

Completing the housing around the outside boundaries of the site are three houses (Type A) which abut the A41 and front onto the vehicular access from Heather Lane. The vehicular access through the development follows the units mentioned above in a U shape.

On the opposite side of the access road there is a second ring of properties. There are four blocks of flats (Type E) that mark the corners of this ‘island’ of housing. It is important to note that the access road does not flow directly from the A41 into Heather Lane, and instead there is a pedestrian path and landscaping along the northern edge of the ‘island’. The infill units between the flats are 3 storeys high along the north (Type A), east (Type A)

G 5 and south (Type D) edges, and 2-2.5 storeys high along the western edge (Types B, C and J). These properties all front onto the main vehicular access.

The third ring of housing (Types B, C and J) fronts onto a central parking court. There is one further set of housing (Type A) which fronts onto the parking court for the Type E flats in the north-west corner of the ‘island’.

There is currently a residential dwelling at No. 90 Leggatts Way which forms part of the application site. The applicant proposes to demolish this building and replace it with a block of flats (Type L) and associated car parking. This would remove the existing pedestrian access to this section of Leggatts Way.

A detailed analysis of each housing type is provided later in the report.

With the exception of the intruding LEAP, the playing fields are to remain in their current form. An additional 40 car parking spaces also proposed as part of this scheme, to be located in the grassed area bordered by the A41 and the two accesses off the A41.

Planning history The site has a limited planning history, the majority of which is related to the site’s educational use. The original College buildings were erected in the late 1930s. There have been various additions to the campus since this time and large steel framed metal- clad buildings were constructed in the early 1990s. The existing building footprint occupies 9,872m².

Pre-application advice The applicant had a number of discussions with the Local Planning Authority prior to submission of the application. The following advice was provided to the applicant, based on a proposal very similar to that now before the Development Control Committee:

G 6 • The Council would prefer the application to be submitted after the development brief for the site had been adopted. • Public transport issues will need to be discussed with Hertfordshire County Council Highways Department. • Traffic calming off site would have to be discussed. • The brief will make more explicit the access arrangements regarding the two phases. • It will be necessary to provide a full tree survey and strategy for trees on the site. The design and access statement should include a tree and landscape rationale section. • Affordable housing as shown is not acceptable. It will be necessary to have 30% of the houses as affordable and 30% of the flats as affordable. • There are two ways of dealing with the pedestrian access to Leggatts Way. Either it is opened up a proper route with appropriate measures to minimize opportunity for antisocial behaviour and access to rear gardens; or it is incorporated into private ownership and managed by the owner of a currently adjoining property. It cannot be left as it is now. • The proposed description of the development is acceptable. • Would like to see a “home zone” concept used between the two turning head located at the vehicle entry points to the site. This should remove the need for the speed tables and the standard width roads and pavements. This will assist in creating a less engineered layout and provide greater opportunity for structural tree planting. • The arrangement of the blocks and roads behind the crescent of town houses causes some concern. The relationship of the backs of the houses and the limited frontage on the other side of the road is not acceptable as it stands. This should be reviewed and the units currently fronting onto this road turned around so that we have backs to backs. This will necessitate relocating the road and ensuring the fronts front onto the roads and public space. • General concerns with the blocks of flats – they should have front doors onto the road/public space and not be accessed solely through the parking areas.

G 7 • Not comfortable with the parking arrangements around the neighbourhood centre; this is a security issue as much as an aesthetic one and needs to be reviewed. • Refuse storage and collection; concerns over the location of bin stores regarding distances for collection in places where the access is restricted by the archway device. Also, need to show that recycling provision has been made – including for the flats. • Elevations - there is concern over the fenestration arrangement shown on the drawings - primarily there is a preference for a logical vertical order on the elevations with the larger windows on the ground floors and smaller ones above – but a consistent size and approach across the site is required. The large French doors shown on the crescent town houses needs to be broken up into 2 narrower sets of doors. This is necessary to ensure the vertical lines in the elevations are there and treated consistently. This will add coherence to the scheme design. • A palette of materials should be submitted with the application. • It is suggested that the applicants undertake a self assessment of the scheme against the CABE Building for Life criteria as referred to in the brief. • The layout needs to have a clear servicing plan. • Council is seeking approximately 50:50 split between 1 & 2 bed flats and 2-5 bed houses on the site; current split is unacceptable.

Overall it was considered that there was considerably more work to do before a satisfactory scheme could be reached. The Council would prefer these issues to be resolved prior to the submission of a formal application rather than having to deal with them as negotiation points during the application process, which could result in a prolonged and messy route to determination. The Council prefers to avoid consulting with neighbours more than once during the life of an application which may happen if major points are left to be negotiated on post submission.

Leggatts Campus Planning Brief The Council has published a draft planning brief for West Herts College’s Leggatts Campus and the Bill Everett Community Centre to ensure that any new development on

G 8 that site will be appropriate, and of benefit to the area. The draft version of the brief has been the subject of public consultation and is due to be considered by the Cabinet at its meeting in December. The brief is still in draft form and has not been adopted by the Council.

Relevant Policies Watford District Plan 2000 A summary of the relevant policies is provided below. For the full text of each policy, you should refer to the main document.

Policy SE4 – Energy Efficient Design Supports initiatives to conserve energy and to utilise local energy sources through energy conservation in building design, energy efficient site layouts and landscape schemes.

Policy SE7 – Waste Storage and Recycling in New Development Requires new developments to make provision for waste storage and recycling facilities.

Policy SE22 – Noise The Council will seek to separate noise sensitive uses from noise generating development and, where appropriate, may impose conditions or obligations to mitigate the effect of noise nuisance.

Policy SE23 – Light Pollution Seeks details of external lighting schemes to ensure light pollution is minimized.

Policy SE27 – Flood Prevention The Council will resist any development which has potential to contribute to flood risk.

Policy SE29 – Utilities Infrastructure The Council will only permit development where the water supply, sewerage system and associated utilities infrastructure has sufficient capacity and design to meet anticipated increase in demand.

G 9 Policy SE30 – Surface Water Run-off, Water Conservation and Sustainable Drainage Systems The Council will have regard to sustainable drainage and water conservation practices.

Policy SE32 – Sites of Nature Conservation Importance Proposals for development likely to affect these sites will not be approved unless the need for the proposal clearly outweighs the need to safeguard the substantive nature conservation value of the site.

Policy SE39 - Tree and Hedgerow Provision in New Development On sites containing trees and/or hedgerows the Council will expect a survey of existing vegetation and a plan for protection.

Policy SE42 – Home Zones Home Zones are described as “people friendly” residential areas where cars take second place to pedestrians, and especially children. Within the Home Zone, priority is given to walking, cycling, chatting, sitting, paying and where cars can travel slowly and safely.

Policy T1 – South West Hertfordshire Transportation Strategy Supports proposals set out in the strategy which are material considerations in the determination of development proposals.

Policy T4 – Transport and New Development All development proposals will be considered against the amount, type and timings of transport movement likely to be generated and the effect on the highway network. Where significant transport impacts are likely, a transport assessment should be prepared.

Policy T6 and T7 – Pedestrian Facilities in Developments Requires new development to provide safe pedestrian access and contributions to improving pedestrian routes to site.

Policies T9 and T10 – Cycling Facilities Encourage the provision and improvement of facilities for cycling through off-site works, financial contributions and on-site cycle parking

G 10 facilities.

Policy T21 - Access and Servicing Requires new developments to make adequate provision for access/egress and servicing arrangements to meet the necessary safety and capacity requirements.

Policy T22 - Car Parking Standards Development will be expected to comply with the maximum parking standards set out in Appendix 2 of the Plan.

Policy T23 – Non-Residential Development All major non-residential development should be in locations with the potential for good access by means of travel other than the private car to reduce the demand for more car-based travel.

Policy T24 – Residential Development Full parking needs should be met on-site unless the site is in the Town centre or has good access to passenger transport.

Policy T27 – Car Park Location and Design All new car parking should be designed, located and landscaped so as to have minimal impact on the quality of the local environment.

Policy H5 - Development on Previously Developed Land This policy seeks to encourage a high proportion of new residential development to be constructed on previously developed land to ensure the sustainable and efficient use of land in Watford.

Policy H7 - Primarily Residential Areas In these areas proposals for residential purposes will be acceptable in principle provided they do not result in an overall loss of residential accommodation; an oversupply of housing; loss of open space, a community facility or necessary off-street parking; or harm to nearby living conditions or the character of the area.

G 11 Policy H8 - Residential Standards This Policy seeks a high standard of design and layout in all new residential developments.

Policy H10 – Educational and Community Facilities Requires contributions from new developments towards any increase in demand for school places or other social or community facilities arising from the development.

Policy H11 – Housing Mix All proposals for residential development should provide a variety of housing types and sizes having regard to the local area’s needs.

Policy H12 - Housing Density Standards Encourages higher density development but recognizes density will depend on type of unit, mix and location. On sites over 0.05 hectare density should be at least 30 dwellings per hectare. Higher density (over 50 dwellings per hectare) encouraged in Town Centre and close to passenger transport facilities.

Policy H15 – Non-Residential Proposals in Residential Areas – Proposals for non- residential uses within primarily residential areas will be assess having regard to the need to retain the existing use and any detrimental effect on the character or appearance of the area.

Policy H17 - Provision of Affordable Housing All new housing developments of 25+ dwellings (or on sites over 1H) should provide affordable housing at 30% of units for perpetuity. Also expected on small sites comprising phases of a larger site.

Policy E3 – Small Business, Self-Employment and Homeworking The Council will encourage the provision of small industrial and business units, subject to compliance with Policy E2, and will not permit development which involves a net loss of small units.

Policy S4 – Shop Design, Access and Facilities The needs of shoppers with young children and people with disabilities should be provided for in the design of new shopfronts

G 12 and in the design and layout of external space and parking in new shopping developments.

Policy L5 – Playing Fields The Council will prevent the loss of facilities or access to resources which are important in terms of sports development in accordance with the Town and Country Planning (General Development Procedure) Order 1995; PPG17: Sport and Recreation, and other relevant guidance and policies of this plan.

Policy L8 - Public Open Space All new housing developments regardless of size should provide for public open space, either in the form of on-site provision or, where appropriate, commuted payments.

Policy L9 - Children’s Play Space All new housing developments should make provision for children’s play space, either in the form of on-site provision or, where appropriate, commuted payments, unless there is already a suitable facility within 200m of the site.

Policy L11 – Maintenance of Open Spaces, Play Areas and Pocket Parks Where an open space, play area or pocket park is provided by the developer, and not adopted by the Council, the developer will be required to enter into a planning obligation to ensure its subsequent maintenance. Where such an area is adopted by the Council at the request of the developer but is considered to be principally of benefit to the development itself rather than the wider public, the Council will require the payment of a commuted sum for its maintenance.

Policy U1 - Quality of Design This Policy states that all new development should represent high quality design to enhance the quality of the built environment of the town.

Policy U2 - Design and Layout of Development All new development should achieve a high standard of design and layout. New development should integrate with the local character of the area, provide satisfactory levels of sun and day lighting, privacy and outlook to the proposed development and to adjoining buildings and uses, seek to

G 13 enhance the overall quality and character of the area, ensure that space is provided for utility and access purposes, minimize light pollution and encourage non-car modes of travel.

Policy U3 - Integration of Character All new development should be based on an understanding of the local characteristics of the surrounding area. Sets out detailed criteria used in defining the character of the area and for assessing new development.

Policy U4 – Community Safety All new development should be designed to provide safety and security to the environment, and reduce the opportunities and fear of crime and anti- social behaviour.

Policy U6 - Landscape Design All development proposals are required to submit a landscape scheme as an integral part of the development. Such proposals will be monitored and enforced.

Policy U24 – Shopfronts The Council will require a high standard of appearance of all shopfronts and associated awnings, roller shutter grilles and signs. New shopfronts should be in keeping with the character of the upper part of the building and relate well to adjoining frontages.

Policy IMR2 – Planning Obligations In accordance with the terms of Section 106 of the Town and Country Planning Act 1990, Circular 1/97 (Planning Obligations) and Structure Plan Policy 2, the Council may require developers to enter into a planning obligation to provide environmental works, infrastructure, community facilities and services that directly relate in scale and kind to the proposed development.

Supplementary Planning Guidance Notes SPGs 4, 5 and 10 were prepared in accordance with paragraphs 3.15 to 3.18 of PPG12: Development Plans and give guidance further to Policies H8, L8, L9, U1, U2 and U3 of the Watford District Plan 2000. The consultation process for SPGs 4, 5 and 10 was as

G 14 follows: two 6 week periods of public consultation (19 th – 30th June 2000 and 11 th May - 22nd June 2001); notices in Watford Observer and London Gazette; publicity in Watford Today, Watford Council website and in One Stop Shop at the Town Hall; all statutory consultees, residents groups and local interest groups informed of consultations. SPGs 4, 5 and 10 were adopted by the Planning and Highways Committee on 11 th October 2001.

SPG1 Affordable Housing . This guidance seeks to explain the way in which the Council will seek to provide affordable housing when considering applications for residential development and supports policy H17 of the Watford District Plan 2000. It is intended to provide developers with guidance that will assist their negotiations. The guidance has been prepared by the Council as part of the Housing and Regeneration Initiative (HARI), involving Three Rivers and Watford Councils and local RSLs.

SPG3 – Housing Density Standards This guideline provides details on the Governments density standards in relation to the location of sites and their proximity to the Town Centre, public transport and local amenities.

SPG 4 - Privacy Guidelines This guideline aims to ensure reasonable levels of privacy between new and existing development by requiring 27.5m between first floor windows to habitable rooms and a distance of 13.75m between first floor windows and garden boundaries. In certain circumstances screening can assist.

SPG 5 - Private Gardens This guideline aims to ensure that every house, and where appropriate flat, has its own private amenity space of 37.2sqm for 1 or 2 people plus 18.6sqm for every additional person. It also gives minimum garden length of 13.75m.

SPG6 Internal Room Space Standards This guideline sets out the standards for the minimum space required for different types of rooms depending on the amount of people living within the dwelling.

G 15 SPG10 - Open Space Provision This guidance supports Policies L7-L11 of the Watford District Plan 2000 and provides greater detail with regard to the provision of on-site open space and children’s play space and calculations in respect of commuted payments (only allowed in exceptional circumstances).

SPG14 – Designing for Community Safety This guidance supports Policy U4 of the WDP 2000 and provides greater detail on design measures that increase the physical and perceived safety in new developments.

Planning Policy Guidance Notes and Statements Planning Policy Statement 1 – Delivering Sustainable Development Reinforces the role of planning as a positive and proactive activity which should ensure high quality development through good design, sustainable development, social inclusion and good use of resources. Design assessment should include function as well as appearance, security, density, character of locality, and mobility access.

PPS3 - Housing Sets out how the planning system supports the growth in housing completions needed in England. This replaces Planning Policy Guidance 3: Housing (published March 2000). The statement encourages higher density developments in accessible locations and existing urban areas. Encourages good design to create attractive, high quality environments: • create places with their own identity but respect and enhance the local character • promote design that embraces issues of public health, crime prevention and safety • give priority to pedestrians over vehicles • promote energy efficient housing Also encourages provision of affordable housing.

PPS9 – Biodiversity and Geological Conservation Planning, construction, development and regeneration should have minimal impacts on biodiversity and be enhanced wherever possible. In moving towards this vision, the Government’s objectives for planning are: • To promote sustainable development;

G 16 • To conserve, enhance and restore the diversity of England’s wildlife and geology; • To contribute to rural renewal and urban renaissance

PPS10 – Planning for Sustainable Waste Management The overall objective of Government policy on waste, as set out in the strategy for sustainable development, is to protect human health and the environment by producing less waste and by using it as a resource wherever possible.

PPG13 – Transport This gives guidance on how the Government’s objectives for integrated transport can be achieved through land use planning, through promoting more sustainable transport choices, promoting accessibility to jobs, shopping, leisure facilities and services, and to reduce the need to travel by private car.

PPG16 – Archaeology and Planning This guidance is for planning authorities in England, property owners, developers, archaeologists, amenity societies and the general public. It sets out the Secretary of State's policy on archaeological remains on land, and how they should be preserved or recorded both in an urban setting and in the countryside. It gives advice on the handling of archaeological remains and discoveries under the development plan and control systems, including the weight to be given to them in planning decisions and the use of planning conditions.

PPG17 – Planning for Open Space, Sport and Recreation Open spaces, sport and recreation all underpin people's quality of life. Well designed and implemented planning policies for open space, sport and recreation are therefore fundamental to delivering broader Government objectives. These include: • Supporting an urban renaissance • Supporting a rural renewal • Promotion of social inclusion and community cohesion • Health and well being • Promoting more sustainable development

G 17 PPG24 – Planning and Noise Planning Policy Guidance 24 (PPG24) guides local authorities in England on the use of their planning powers to minimise the adverse impact of noise. It outlines the considerations to be taken into account in determining planning applications both for noise-sensitive developments and for those activities which generate noise.

PPS25 – Development and Flood Risk Flooding from rivers and coastal waters is a natural process that plays an important role in shaping the natural environment. However, flooding threatens life and causes substantial damage to property. The effects of weather events can be increased in severity both as a consequence of previous decisions about the location, design and nature of settlement and land use, and as a potential consequence of future climate change. Although flooding cannot be wholly prevented, its impacts can be avoided and reduced through good planning and management.

CONSULTATIONS

Neighbour consultations The following properties were notified: 56 Maytree Crescent 36 Maytree Crescent 449 North Western Avenue 60 Maytree Crescent 39 Maytree Crescent 90 Maytree Crescent 65 Maytree Crescent 40 Maytree Crescent 42 Maytree Crescent 68 Maytree Crescent 41 Maytree Crescent 46A Maytree Crescent 83 Maytree Crescent 44 Maytree Crescent 46 Maytree Crescent 86 Maytree Crescent 48 Maytree Crescent 22 Maytree Crescent 91 Maytree Crescent 50 Maytree Crescent 24 Maytree Crescent 97 Maytree Crescent 51 Maytree Crescent 75 Maytree Crescent Room 2 429 North Western 53 Maytree Crescent 87 Maytree Crescent Avenue Ground Floor Flat 71A 55 Maytree Crescent 69 Maytree Crescent Maytree Crescent 4 Maytree Crescent 57 Maytree Crescent 58 Maytree Crescent 6 Maytree Crescent 59 Maytree Crescent 63 Maytree Crescent 8 Maytree Crescent 61 Maytree Crescent 66 Maytree Crescent 10 Maytree Crescent 62 Maytree Crescent 2 Maytree Crescent 12 Maytree Crescent 67 Maytree Crescent 71 Maytree Crescent 16 Maytree Crescent 68A Maytree Crescent 33 Maytree Crescent 18 Maytree Crescent 141 Leggatts Way 34 Maytree Crescent

G 18 20 Maytree Crescent 154 Leggatts Way 36A Maytree Crescent 26 Maytree Crescent 156 Leggatts Way 6 Leggatts Close 27 Maytree Crescent 158 Leggatts Way 15 Leggatts Close 28 Maytree Crescent 160 Leggatts Way 21 Leggatts Close 29 Maytree Crescent 417 North Western Avenue 90 Leggatts Way 30 Maytree Crescent 385 North Western Avenue 96 Leggatts Way 31 Maytree Crescent 447 North Western Avenue 98 Leggatts Way First Floor Flat 71 Maytree 455 North Western Avenue 421 North Western Avenue Crescent Ground Floor Flat 71 74 Maytree Crescent 423 North Western Avenue Maytree Crescent 5 Silver Dell 77 Maytree Crescent 425 North Western Avenue 461 North Western Avenue 78 Maytree Crescent 427 North Western Avenue 467 North Western Avenue 79 Maytree Crescent 429 North Western Avenue 473 North Western Avenue 80 Maytree Crescent 431 North Western Avenue 479 North Western Avenue 81 Maytree Crescent 64 Maytree Crescent 487 North Western Avenue 82 Maytree Crescent 1 Silver Dell Harebreaks Adventure 84 Maytree Crescent 3 Silver Dell Playground, Leggatts Way Room 1 429 North Western 85 Maytree Crescent 70A Maytree Crescent Avenue 457 North Western Avenue 88 Maytree Crescent 70 Maytree Crescent 481 North Western Avenue 89 Maytree Crescent 72 Maytree Crescent 409 North Western Avenue 92 Maytree Crescent 73A Maytree Crescent 403 North Western Avenue 95 Maytree Crescent 73 Maytree Crescent 7 Silver Dell 99 Maytree Crescent 419 North Western Avenue 71A Maytree Crescent 397 North Western Avenue 433 North Western Avenue 93 Maytree Crescent 399 North Western Avenue 435 North Western Avenue 37 Maytree Crescent 401 North Western Avenue 437 North Western Avenue 14 Maytree Crescent 405 North Western Avenue 439 North Western Avenue 45 Maytree Crescent 407 North Western Avenue 441 North Western Avenue 76 Maytree Crescent 411 North Western Avenue 443 North Western Avenue 54 Maytree Crescent 413 North Western Avenue 445 North Western Avenue 47 Maytree Crescent 415 North Western Avenue 451 North Western Avenue 453 North Western Avenue 256 Leggatts Rise 250 Leggatts Rise 459 North Western Avenue 260 Leggatts Rise 252 Leggatts Rise 463 North Western Avenue 268 Leggatts Rise 258 Leggatts Rise 465 North Western Avenue 276 Leggatts Rise 4 Evans Avenue 469 North Western Avenue 284 Leggatts Rise 6 Evans Avenue 471 North Western Avenue 290 Leggatts Rise 2 Rushton Avenue 475 North Western Avenue 266 Leggatts Rise The Lodge, North Western Avenue 477 North Western Avenue 278 Leggatts Rise Cemetery Lodge, North Western Avenue

G 19 483 North Western Avenue 262 Leggatts Rise 206 North Western Avenue 485 North Western Avenue 264 Leggatts Rise 204 North Western Avenue 489 North Western Avenue 272 Leggatts Rise North Watford Cemetery, North Western Avenue 491 North Western Avenue 274 Leggatts Rise 196 North Western Avenue 387 North Western Avenue 280 Leggatts Rise 198 North Western Avenue 389 North Western Avenue 282 Leggatts Rise 200 North Western Avenue 391 North Western Avenue 286 Leggatts Rise 202 North Western Avenue 393 North Western Avenue 288 Leggatts Rise 208 North Western Avenue 395 North Western Avenue 292 Leggatts Rise 210 North Western Avenue 2 Evans Avenue 294 Leggatts Rise 5 Maytree Crescent 1 Rushton Avenue 220 Leggatts Rise 132 Leggatts Way 232 Leggatts Rise 222 Leggatts Rise 28 Leggatts Close 242 Leggatts Rise 226 Leggatts Rise 126 Leggatts Way 270 Leggatts Rise 228 Leggatts Rise 121 Leggatts Way 254 Leggatts Rise 234 Leggatts Rise 123 Leggatts Way 224 Leggatts Rise 236 Leggatts Rise 135 Leggatts Way 230 Leggatts Rise 240 Leggatts Rise 132A Leggatts Way 238 Leggatts Rise 244 Leggatts Rise 13 Leggatts Close 248 Leggatts Rise 246 Leggatts Rise 108 Leggatts Way 81 Foxhill 24 Leggatts Close 2 Leggatts Close 83 Foxhill 16 Leggatts Close 3 Leggatts Close 87 Foxhill 106 Leggatts Way 5 Leggatts Close 89 Foxhill 100 Leggatts Way 7 Leggatts Close 93 Foxhill 112 Leggatts Way 8 Leggatts Close 95 Foxhill 140 Leggatts Way 10 Leggatts Close 97 Foxhill 144 Leggatts Way 11 Leggatts Close 85 Foxhill 146A Leggatts Way 14 Leggatts Close 91 Foxhill 146 Leggatts Way 17 Leggatts Close Cherry Tree J M I School, 152 Leggatts Way 19 Leggatts Close Berry Avenue Bill Everett Centre, Leggatts 118 Leggatts Way 20 Leggatts Close Way 7 Maytree Crescent 120 Leggatts Way 23 Leggatts Close 9 Maytree Crescent 125 Leggatts Way 25 Leggatts Close 11 Maytree Crescent 129 Leggatts Way 26 Leggatts Close 13 Maytree Crescent 131 Leggatts Way 1 Leggatts Close 15 Maytree Crescent 132B Leggatts Way 4 Leggatts Close 17 Maytree Crescent Leggatts School, Leggatts 9 Leggatts Close Way 21 Maytree Crescent The Flat Langleybury 12 Leggatts Close Annexe, Leggatts Way 23 Maytree Crescent 96A Leggatts Way 18 Leggatts Close 25 Maytree Crescent 101 Leggatts Way 22 Leggatts Close 109 Leggatts Way 104 Leggatts Way 27 Leggatts Close

G 20 110 Leggatts Way Langleybury Annexe, 99 Leggatts Way Leggatts Way 111 Leggatts Way Flat, Watford College 102 Leggatts Way 115 Leggatts Way 19 Maytree Crescent 103 Leggatts Way 116 Leggatts Way 113 Leggatts Way 150 Leggatts Way 119 Leggatts Way 32 Maytree Crescent 137 Leggatts Way 122 Leggatts Way 35 Maytree Crescent 138 Leggatts Way 124 Leggatts Way 38 Maytree Crescent 139 Leggatts Way 127 Leggatts Way 43 Maytree Crescent 142 Leggatts Way 128 Leggatts Way 49 Maytree Crescent 148 Leggatts Way 130 Leggatts Way 52 Maytree Crescent 114 Leggatts Way 133 Leggatts Way 1 Maytree Crescent 117 Leggatts Way 136 Leggatts Way 3 Maytree Crescent 134 Leggatts Way

10 responses were received citing the following objections: • Potential for anti-social behaviour along the currently disused entrance to the site of Leggatts Way; • Heather Lane is too narrow to support two-way traffic; • Safety of Heather Lane due to a blind-corner; • Increase in traffic along Leggatts Way and the A41; • Noise during construction; • No provision of facilities for young people; • Overdevelopment; • Excessive density; • Insufficient infrastructure in the area to support the large increase in population; • Drainage and increased run-off from hard surfaces; • Impact on local wildlife; • Location of Council Housing; • Privacy of houses; • Excessive height; • Overshadowing; • Design not in keeping with the rest of the area, especially the property on the corner by the entrance to the BECC; • Proximity of new development to houses along Leggatts Way;

G 21 • Insufficient and non-compliant provision of private amenity space for each new house; • Impact of the 4 storey flats on the A41; • Question over the legitimacy of the Home Zone and whether it being used in its specific technical sense; • No provision of a community room in the Neighbourhood Centre; • Insufficient transport statement; • Insufficient storage provision for bicycles; • The main school building should be retained and converted to residential;

Advertisements in local paper/ site notices A press notice was published in the Watford Observer and a site notice was placed near the site on the 5 October 2007. Letters were sent to adjoining owners on 4 October 2007.

Statutory consultations

Hertfordshire Highways The site is allocated for Housing redevelopment and Hertfordshire County Council, as Highways Authority, has no fundamental objection to the proposed residential development including neighbourhood centre, public open space and associated parking and landscaping. However, the Transport Assessment submitted in support of the development is inadequate in terms of a number of assumptions made and fails to demonstrate adequate measures to mitigate the impact of the development.

The Highways Authority does not agree with the trip generation, the sustainable accessibility of the development and the predicted impact of the development as presented within the Transport Assessment. The Transport Assessment also fails to demonstrate to the satisfaction of the Highways Authority the suitability of the access arrangements in terms of visibility, safety and capacity.

G 22 It should be noted that no pre-application discussions were entered into by the Developer with the Highways Authority other than some late, brief telephone conversations. The Highways Authority remains willing to continue dialogue with the applicant. If, however, the Local Planning Authority are minded to determine this application in the near future, the Highways Authority on the basis of information submitted to support the application would recommend refusal on the grounds that inadequate information is presented to demonstrate adequate measures to mitigate the impact of the development.

Arboricultural Officer The proposals do attempt to retain the boundary trees, however all the trees within the built element of the site are shown for removal. Of the individual trees shown for removal only the oak T20 is of sufficient size and condition to consider for retention, however to do this would require considerable re-design of the site layout to accommodate it. In addition the relative heights of the proposed buildings are likely to restrict views of the tree even if retained.

My only other area of concern regards the partial removal of part of Group G2, the hedge that runs along the A41 boundary. The plans indicate that a 27 metre length will need to be removed or will be severely affected by the construction of the adjacent parking bays and whilst this may not punch a hole right through the screen (due to it being planted on both sides of the boundary) there is a possibility that gaps will occur. I would therefore wish to see this area of parking amended to maintain the integrity of this hedge/screen.

With the exception of the above mentioned area of Group G2, the proposed areas of tree protection, ground protection and areas of ‘no-dig’ construction to the indicated retained trees as shown on drawing no.WIM16247-03 Rev A are considered acceptable.

Urban Design Officer • Point made on the pre-application note sent to them regarding the fronts to backs relationship on the eastern edge of the site is still not resolved and as it stands is not of sufficient quality to support.

G 23 • There are still issues with the blocks of flats - the design of the flank/side elevations is not good in terms of active frontages; I feel that this is partly a function of the size of the blocks and the lazy approach to designing corner blocks. The corner units need to be smaller and better integrated into the housing blocks. • The proportion of flats to houses is 70:30 % which is not in line with the brief which sets out that houses should be the dominant unit form. Flats are acceptable along the boundary with the A41 and on top of the neighbourhood centre but only in very limited number elsewhere. • The elevations of the neighbourhood centre do not reflect the purpose of the building and have not incorporated sufficient servicing and bin stores - also not really a dual frontage. • Need details of street elevations as a street not a series of unit types. • Too much 3 storey - need to reduce all elements not on corners to 2 or 2.5 - only exception may be the block opposite the neighbourhood centre. • Need to have cross section of the streets showing the building heights and shared surface etc. • Flats at either end of the crescent are bulky and poor in terms of pedestrian environment. • Not convinced about the pedestrian access to the south via the isolated block - this needs clarity. • Still need to resolve the access to Leggatts way between the houses.

Crime Prevention Officer The following comments were made: 1. The fencing to be moved level with the building line in following locations, so as to prevent any areas where people can hide [Drawing 06/053/021A taken as reference]: ie plan references 178B, 168C, 117A, 122A, 123A and 125A.

2. Next to 50B there is “dead” ground between their garden fence and the parking spaces could this be removed by making the garden a little larger.

G 24

3. I have concerns about the permeability within the site particularly around the Type E flats nos 35-46, 64-75, 82-93 & 105-116. Can these be fenced off as anyone can walk into these areas alongside 47A, 76D, 120A and 81D.

4. I have similar concerns over the general permeability at the centre of the site, firstly next to 60J into the car parking for flats 64-75 and secondly, the area between 53B & 53C. I don’t want these areas to become “rat runs” or “desire lines” particularly if someone is running away from the police. They would also become easy exits etc for any thieves in the area.

5. The pathway into the site from Leggatts Way alongside 122/124 is still a big issue as far as anti-social behaviour is concerned.

6. I have concerns that the land behind 98 Leggatts Way between the parking for shops/flats and 150-153 parking on BECC exit area may become an area for congregation of youths; perhaps some definite defensible planting may solve this problem. The Landscape Masterplan is not clear other than to propose bat boxes.

7. There will need to be a lighting plan for the shops/flats car park, plus delineation between this and the BECC parking.

8. The Type E flats 1-12 & 233-248 are rather isolated and vulnerable, on Flats 1-12 could a 2 metre fence plus trellis be used as a boundary both for the grounds of the flats and the garages. On Flats 233-248 they are exposed on their western, northern & southern boundaries, again could a 2 metre fence plus trellis be erected to delineate their boundary on both these flanks so as to make residents feel safer and prevent someone wandering into their communal space.

9. I would prefer to see the play area moved northwards level with the top edge of Type G flats 13-18.

G 25

10. I do have concerns that currently youths do congregate in areas to the rear of the BECC building which will be close to Flats 1-12 and the play area, putting a boundary fence and moving the play area [plus perhaps some lighting] may mitigate this problem. I’m also aware that the BECC may be sold on 2008 and this may allay my fears, however there is a groundswell of opinion so I am looking at this site in isolation!

11. The boundary hedge on the North Western Avenue is according to the Landscape Masterplan to remain, can this be reinforced with other fencing and/or defensible planting to prevent penetration into the site, particularly as the car parking for the flats is in this area.

12. In the same vein can the fencing to 179A, which also boarders the North Western Avenue also be 2.2 metres with trellis.

Thames Water Following initial investigation, Thames Water has identified an inability of the existing waste water infrastructure to accommodate the needs of this application. Should the Local Planning Authority look to approve the application, Thames Water would like the following 'Grampian Style' condition imposed.

"Development shall not commence until a drainage strategy detailing any on and/or off site drainage works, has been submitted to and approved by, the local planning authority in consultation with the sewerage undertaker. No discharge of foul or surface water from the site shall be accepted into the public system until the drainage works referred to in the strategy have been completed". Reason - The development may lead to sewage flooding; to ensure that sufficient capacity is made available to cope with the new development; and in order to avoid adverse environmental impact upon the community.

G 26 Three Valleys Water The site is not located within any groundwater catchment area so no comments have been provided.

Hertfordshire County Council – Property Officer Contributions would be sought by way of a planning obligation for education, library and fire and rescue services are as follows.

Primary Education £414,608 Libraries @ £204 p/dwelling £50,592 Youth and Childcare @ £410 p/dwelling £101,680 (applied to dwellings with more than one bedroom)

All calculations are based on PUBSEC index 166 and will be subject to indexation.

Fire hydrant provision is also sought and should be secured by the standard form of words in a planning obligation.

Hertfordshire County Council – County Archaeologist The applicant has provided some information in the form of an “Archaeological Desk Based Assessment” (DBA) and a Historic Buildings Assessment (HBA). The DBA document appears to examine the entire Campus, rather than the current development area. It asserts (para 6.1) that the site has “low potential for all archaeological periods, except for the Medieval…” The report recommends (para 6.2) that a geophysical survey be undertaken of the playing fields and that the results of these investigations should be tested as a condition of any planning permission. However, this recommendation does not apply to the land area that is the subject of the current application.

Our pre-planning advice to Wimpey Homes recommended that the results of a desk- based assessment and trial trench evaluation would be required before the application was determined. This office also advised that the former college buildings be

G 27 archaeologically recorded prior to any demolition/development. This could be secured post-determination of any application by condition.

Unfortunately this office was not consulted prior to the production of the reports, the contents of which do not fully meet the requirements of any design briefs for DBAs issued by this office.

Archaeological Desk Based Assessment No use is made of pre-1878 sources should they exist, no secondary sources are consulted, and no data concerning the impact of past development at the site such as geo-technical data is considered. This is surprising since the bibliography of the report states that the sources used included a “Report on Site Investigations at West Herts College, Leggatts Campus, North Watford” by Geotechnical Developments (UK) Ltd 2006. In addition, only Historic Environment Record data within an arbitrary distance of 500m from the site are considered.

There are currently no known archaeological remains within the site (as the DBA states), other than the 1930s/40s standing structures. The Historic Environment Record shows a number of known sites in the vicinity. An Iron Age and Roman settlement, HER10048 is recorded at Leavesden Airfield, approximately 800m from the site. There is also a concentration of sites to the north comprising a Bronze Age arrow head, medieval pottery, Roman coins at two separate sites and a medieval manorial site.

Historic Buildings Assessment The 1930s/40s school buildings and the associated school house are of a Scandinavian Neo-Georgian style and appear to be largely intact with many original fittings in evidence. They are therefore worthy of preservation by record, as stated in our pre-planning advice to the applicant, although this recommendation has not been considered by the HBA.

G 28 Recommendations Therefore, with the above in mind and in accordance with the advice contained within PPG 16 (paragraphs 21 and 22) and the Local Plan policy on archaeology, I would be likely to recommend that an applicant provide further archaeological information regarding the impact of the proposal on the historic environment before any application is determined.

Below Ground Archaeology Given the fact that the application does not propose to develop the majority of the playing fields area:

This additional information should comprise the results of an archaeological desk-based assessment of the site followed by a field evaluation of those areas of the site likely to be disturbed by any new ground. This field evaluation is likely to take the form of a number of trial trenches to sample the archaeological potential of the proposed development site.

Once the results of such work is available, this office will be able to advise as to the likelihood of the site containing remains worthy of preservation in situ, which may be a constraint on the development, and/or of the necessity for further archaeological investigations.

If the applicant wishes to submit a planning proposal, I would be able to provide a design brief detailing the requirements for the investigation and provide information on archaeological contractors who may be able to carry out the necessary work.

College Buildings Not withstanding the above advice, I can also state that in terms of the former college buildings, I would advise the planning authority faced with a development application on the site that they should be archaeologically recorded prior to any demolition, alteration or development. This could be secured post-determination of any application by condition.

G 29 Environmental Health Officer Raised concerns in relation to the noise assessment submitted by Alan Saunders Associates, in particular with regard to the hours of data collation and therefore the validity of the assessment. Further concerns are also raised relating to the translation of the mitigation measures into design outcomes.

Sport England I can confirm that the consultation is statutory as it affects a playing field. Unfortunately, I am not currently in a position to make a substantive response to the consultation because insufficient information has been provided to allow me to make an informed assessment of whether the proposal would accord with Sport England's playing fields policy, A Sporting Future for the Playing Fields of England’ (1997);

To allow me to undertake an informed assessment, I would request the following information:

1. A site plan (to a defined scale) showing the existing and (if appropriate) proposed summer and winter grass playing pitch layout in order to allow me to undertake an informed assessment of the impact of the development on playing pitch provision. At present, it is not possible to assess whether the proposed play area (LEAP) would have any impact on existing playing pitch provision. The provision of the requested playing pitch layouts would allow this assessment to be undertaken;

I would be grateful if you could ask the applicant to provide the above information at your earliest convenience. Until then Sport England would place a holding objection on the planning application and the provisions of the Town and Country (Playing Fields) (England) Direction 1998 would apply i.e. the application would need to be referred to the Secretary of State (via GO-East) if the Council is minded to approve the planning application contrary to this advice.

G 30 Environment Agency The Environment agency object to the proposed development due to the following reasons: 1. Greenfield discharge rates have not been achieved for the subject site. 2. 1 in 100 year and climate change on-site attenuation has not been provided. 3. The use of SUDS systems has not been adequately addressed.

The Environment Agency requires the following drainage criteria be met: 1. Provide data evidence to demonstrate the achievement of applicable Greenfield discharge rates. 2. Provide data evidence to demonstrate the achievement of 1 in 100 year climate change on-site attenuation. 3. Demonstrate that opportunities to implement sustainable drainage techniques at the subject site have been maximised using the hierarchical approach to SUDS selection.

Advice to Applicant - This objection is consistent with Watford's SFRA which places emphasise on achieving the above drainage requirements. Please refer to the EA Thames region's drainage guidance when addressing this objection.

Ecology and Conservation The Council’s Conservation and Development Officer commented as follows: 1. In light of a probable bat roost being found in Building B10 it should be ascertained (by a licensed bat worker) whether or not the site is also a hibernation roost (a possibility).

The building should not be demolished, but incorporated as part of a development redesign. Alternatively, like-for-like replacement for the roost is to be provided, on, or near, the site of B10. A license will be required from Natural England (NE). This roost is of local conservation importance and bats in the area should not be left without a maternity roost. An EIA should be carried out. The EIA to include further bat surveys to determine the presence, or otherwise of bat roosts at Buildings: B1, B4 and B7. It is

G 31 possible that at the time of the original survey that the bats had already dispersed.

Surveys to include trees: T1, T2, T3 & T4. In addition, bat feeding/flight paths, where ascertained, incorporated within the development and not impeded by new buildings.

Appropriate consultation to take place with Natural England for works planned which impact on all the identified protected species. Full mitigation proposals for any loss to be included in Ecological/Biodiversity Plan (see condition 5 below).

2. Boundaries. The mixed native hedgerows to the north (PH1 & PH2) are of significant biodiversity value and should not , therefore, be either removed, or formally landscaped, but retained in their present form as natural native hedges, in accordance with Policies SE37 & SE39. The opportunity to be taken to gap up with native species.

3. Lighting. It is important that light pollution is minimised throughout the development, especially in the buffer zones and existing natural areas, in particular Harebreaks Wood LNR. Artificial lighting adversely affects the natural rhythms of a wide variety of wildlife. The development will ensure that there is no light spill from external artificial lights with the proper location of suitable, directional (downward), lighting. Lux level not to exceed 0-2 lm.

4. The Playing Fields and Harebreaks Wood LNR form part of a green corridor. WBC is committed to protecting green corridors and networks, in accordance with PPS9. Also, Harebreaks Wood LNR, as an ancient woodland, is one of Watford’s most important wildlife sites. It is actively managed by the Council, in partnership with local residents, to protect and enhance its conservation and amenity value.

Therefore, a buffer zone of 20m in width is to be established, incorporating the northern hedgerow, the boundary of Cherry Tree School, and the northern and western edges to Harebreaks Wood. There is to be no formal landscaping within this buffer zone; any appropriate planting to consist of native trees (of UK genetic stock) This 20m buffer

G 32 zone will ensure the future integrity of the green corridor and the connectivity of neighbouring sites. It will provide an undisturbed refuge and enable wildlife to migrate between contiguous sites.

The edges of the woodland will be vulnerable to erosion pressure from an increased population arising from the development. Therefore, in addition to the above measures, a triple row, mixed, native hedge should be planted around the edges of Harebreaks Wood, which will add to the biodiversity and ensure entry and egress is only by the designated entranceways.

5. Biodiversity Plan. The ecological enhancement of this site is important for the mitigation of the proposed loss of potential bat roost buildings and mature trees. There should be a net gain in biodiversity. Therefore, a detailed design plan for the biodiversity enhancement of this site should be submitted for approval before works commence. This plan should include long term management objectives and maintenance schedules/responsibilities. The Ecological Management Plan will incorporate the suggested mitigation conditions and recommendations below and also the recommendations to the application made in the ‘Phase 1 Habitat Survey Report’. Such a management plan will ensure that the site’s biodiversity is conserved and enhanced.

6. Trees of Biodiversity Importance. Trees T5 in proximity to woodland to be incorporated in the proposed Buffer Zone.

T1, T2, T3 & T4, being mature, native pedunculate oaks, are of significant biodiversity value. Each tree on its own is important for invertebrates and nesting birds. Where trees have significant decay, such as T3 & T4, it is possible that they are being utilised by bats. They should be retained, and incorporated with in the development.

7. General biodiversity enhancements to be incorporated throughout the development site to help offset loss of habitat elsewhere. Modern building developments usually exclude wildlife, but this needn’t be the case. The Ecological plan should include the following

G 33 measures, which will help ensure that the biodiversity of the Health Campus site is maximised:

7.1 Swift Nesting Boxes

Swifts are an important Watford bird, found throughout the town nesting on older buildings. Unfortunately, modern buildings are not accessible to them and nationally this species is declining. Swifts should be provided for easily, and inexpensively, throughout the Leggatts site by the installation of ‘nesting bricks‘ in new buildings. Several per building. Further information can be obtained from WBC’s Conservation and Development Officer.

7.2 Bird Boxes

To compensate for the loss of nesting sites in this development, 20 different size bird boxes should be provided for throughout the development, not just the identified ‘green’ areas, but included on buildings. Further information from WBC’s Conservation and Development Officer.

7.3 Bats

Bats also benefit from being provided with artificial roosting sites and bat bricks & boxes can be inexpensively provided throughout the site on buildings and trees. Further information from WBC’s Conservation and Development Officer. Thirty bat boxes to be provided and grouped e.g. tree mounted boxes to be three per tree.

7.4 Green Roofs

‘Green’ roofs throughout the development will help provide a green chain linking the wildlife corridors and other green spaces, providing valuable habitat for wildlife, which will help offset habitat loss elsewhere. An additional benefit is that green roofs enhance

G 34 the performance of buildings, helping to regulate temperature, increase the life of the building and provide an improved visual amenity. They are a common feature of buildings on the continent and increasing incorporated in new buildings in London. Further information from WBC’s Conservation and Development Officer.

7.5 Other Habitat Creation

Within the development create a pond & wildflower meadow. Establish tall grass headland throughout the buffer zone and contiguous with new planted trees and hedgerows.

All the above biodiversity enhancements will need to be managed and maintained once installed and this should be detailed in the sites ecological or biodiversity plan.

8. Sustainability. The applicant should detail in the submitted plans how the development will minimise water use, through measures such as rainwater harvesting and reuse of grey water.

9. There should be no storage of materials or plant during the active development phase, within the entire length of the 20 metre buffer zone, nor within any of the natural areas identified above. There should be no movement of plant, or other machinery, within this area during development. The entire area should be demarcated and protected with suitable fencing throughout the development phase. In addition, there will be no entry within this area during development, except to undertake agreed planting.

No clearance of scrub or felling of trees to take place during March-July inclusive. Any building demolition/tree felling to take place September/October. In addition, agreed demolition to be by hand. If bats found work to cease and NE informed and licence applied for.

Hedgerow planting to take place in the Autumn/Early Winter. Inspection of mature trees

G 35 for bats to take place before any felling operation.

APPRAISAL

The Development Plan for the site, for the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, comprises the “saved” policies of the Hertfordshire Structure Plan Review 1991-2011 and the Watford District Plan 2000. The Structure Plan was adopted in April 1998 and provides strategic level policies for the area. In so far as its “saved” policies are still consistent with emerging regional guidance and PPGs and PPSs, they continue to have weight as material considerations in accordance with the above Act. The District Plan was adopted in December 2003 and provides local level policies. This Plan provides the most up to date “development plan” policies and should therefore be afforded considerable weight in decision making on planning applications.

The Supplementary Planning Guidelines have been prepared and adopted following consultation exercises detailed above. They are, therefore, a material consideration in the determination of planning applications and are intended to ensure consistency in decision making.

Affordable housing The provision of affordable housing on this site, as proposed in an e-mail from the applicant’s agents received on 25 October 2007, is as follows:

Plots 120-125 Type A Houses 6 Plots 126-141 Type H Apartments over commercial 16 units Plots 179-181 Type A Houses 3 Plots 182-232 Type K Apartments 51 TOTAL 76 dwellings

G 36

This siting and type of provision is contrary to SPG1, which states the following:

“Developers are expected to incorporate good designs, where affordable homes are located in small clusters or groups throughout the development. The Council will expect designers to ensure that the affordable housing is integrated into the overall development, in terms of their built form and external appearance, such that affordable homes are indistinguishable from those intended for sale. Less desirable positions within a site should not be used for locating any particular tenure. Involving RSLs (or other organisations involved in the long term management of the scheme) in the design process will enable this to be achieved more quickly and with better outcomes than if the design is developed in isolation.”

The affordable housing units are sited in the least desirable positions on the site, being adjacent to the A41 and above the neighbourhood centre which is surrounded by car parking and roads on all four sides. The apartments adjacent to the A41 are not similar to the rest of the housing on the site in terms of design, are not integrated into the site and are easily distinguishable.

There has been no mention in the submission of a partner RSL. An RSL should have been approached at the preliminary design stages of the project to ensure that the provision of affordable housing and its location and distribution over the site would be acceptable.

Further, there should be provision of 30% of each housing type on the site, which has not been proposed as part of this application. The Council’s Housing officers object to the proposals and gave commented as follows:

“In respect of the affordable housing, we note that there is an under provision of houses within the scheme; as there are only 9 houses to be provided out of a total of 76 homes. Furthermore, we note the affordable is segregated from the private

G 37 housing. In our opinion, both the layout and the mix of affordable housing proposed, does not support the building of a balanced sustainable community. We would recommend that the scheme is amended, to take account of the need to better integrate the affordable housing within the scheme and the need to increase the proportion of houses.”

The issues referred to above were all raised with the applicant at pre-application stage and it is disappointing that this advice has not been taken on board in the design of the scheme. The application is therefore considered to be contrary to Policy H17 and SPG1 of the Watford District Plan as well as PPS3.

Mix of accommodation The proportion of flats to houses is 70%:30% which is not in line with the draft brief for the site which sets out that houses should be the dominant unit form. Flats are acceptable along the boundary with the A41 and on top of the neighbourhood centre but only in very limited numbers elsewhere.

Pedestrian access onto and around the site The treatment of the existing pedestrian access to Leggatts Way in the south-west corner of the site is not considered acceptable as the proposal effectively blocks off the access through the introduction of flats and car parking. This section of the site should remain as a public footpath onto Leggatts Way, at least until the BECC site has been redeveloped to ensure that the development of the adjoining site is not prejudiced in any way.

There should be a pedestrian footpath to the east of the flats in the north-east corner of the developable area of the site, with an access into the building. This would also ensure that there was some definition between the public open space and the private apartments.

The current proposal is contrary to Policies T6 and T7 of the Watford District Plan 2000.

G 38 Height of the buildings The 3 storey buildings should be sited strategically on corners and on some of the edges where they would provide a buffer. It is considered that there is an excessive number of 3 storey buildings, suggesting that the proposal is an overdevelopment of the site. A number of the 3 storey buildings should be reduced to 2.5 storeys or 2 storeys as discussed in more detail later in this report. The applicant has suggested that the corner flatted developments have been designed to mark and follow the angle of the corner, and that the justification for their dominance is to provide ’book-ends’ to the rest of the streetscape. However, this function is lost if the infill between the ‘book-ends’ is not more recessive, at a lower height and on a smaller scale than the end flats.

The proposal is contrary to Policies H7, H8, U1, U2 and U3 of the Watford District Plan 2000 and PPS3.

Streetscene elevations Streetscene elevations should be provided of each street frontage. The perspectives are not sufficient to show the proposed new streetscapes, especially in relation to the areas which are dominated by car parking and garages.

Neighbourhood centre The siting of the proposed neighbourhood centre does not allow for any development close to the building on the BECC site. This is considered to jeopardise the development of this adjacent site. Further, the location of flats on top of the neighbourhood centre, whilst generally encouraged, would not work with this proposed layout as they would be surrounded on 3 or 4 sides by car parking and roads. This is not acceptable and would not create a level of amenity acceptable for residential occupation. The elevations of the neighbourhood centre do not reflect the purpose of the building and have not incorporated sufficient servicing and bin stores. Moreover, the design of this building does not adequately reflect the dual frontage that it has. The siting of the flatted block in the south- east corner of the site is also located too close to the property boundary.

G 39 The proposal is contrary to Policies S4, T27, SE7, H8, H15, H17 and SPG1 of the Watford District Plan 2000.

Servicing Servicing to the ground floor commercial units within the neighbourhood centre and some of the flats is not considered acceptable. There is also insufficient provision of bin storage areas for the neighbourhood centre.

This is contrary to Policy SE7 of the Watford District Plan 2000.

Design The proposal incorporates dwelling types of a similar design to those proposed for the Meriden Primary School scheme (55 units). However, development of the Leggatts site should try to create its own identity and sense of place, and should not, therefore, repeat something in another part of Watford. Further analysis of each housing type has been included in a separate section below.

There are particular issues with the blocks of flats - the design of the flank/side elevations is not good in terms of active frontages; this is partly a function of the size of the blocks and the approach adopted to designing the corner blocks. The roofs of the flatted blocks are excessively large and poorly laid out. The corner units need to be smaller and better integrated into the housing blocks.

The general massing, scale, proportions, site coverage and layout of the proposal is not considered to be appropriate. Whilst it is acknowledged that this site has the opportunity of creating its own sense of place, this is not achieved by siting units in every section of the site. The rear gardens, levels of privacy, and overall streetscapes and opportunities for landscaping are all harmed by this approach to the design.

The design of the houses and the flats should be more considered and respond individually to their immediate surroundings and the context in which they will sit when the

G 40 development is complete. At this stage, the proposed units are not considered to respond appropriately to these issues; rather, it appears they have been positioned somewhat randomly around the site with the main goal of maximising the land coverage and density.

The proposal is therefore considered to be contrary to Policies SE4, H7, H8, H12, U1, U2, U3, U4, U6, U24, SPG3, SPG4, SPG5, SPG6, SPG14 and SPG16 of the Watford District Plan 2000 and PPS1 and PPS3.

Noise The noise assessment carried out by Alan Saunders Associates dated 12 September 2007 reports that at the junction with the A41, the site is located within Noise Exposure Category C during the daytime and night time periods and Noise Category A or B along the southern boundary where it would be screened from North Western Avenue. The proposed building design incorporates some of the suggestions from this report, including minimal glazing along the elevation fronting the A41 and the siting of living rooms and bedrooms away from the edge of the site. It is not considered, however, that the design achieves full compliance with the report’s recommendations, and no details have been provided of the estimated noise levels inside the flats based on the proposal currently before the Council. The resultant design of the building is not considered to be appropriate for this location, with a generally flush façade, minimal fenestration or other design features, and minimal articulation for a length of 95 metres. The proximity of the central core of flats to North Western Avenue – 7.5 metres – relies on an inappropriate setback which does not allow for the provision of sufficient vegetation in this area. Additional vegetation is required in this area to maximise the buffer between the road and the residential accommodation on the site and to minimise the noise levels generated by traffic using this route.

The point made in the pre-application advice sent to the applicant regarding the garages and parking on the eastern edge of the site fronting the internal access road is still not resolved and as it stands this aspect of the development is not of sufficient quality to enable the proposal to be supported. No justification has been provided to justify the

G 41 contention that this area creates a sense of enclosure or a safe streetscape.

The proposal is therefore contrary to Policy SE22 and SPG19 of the Watford District Plan 2000 and PPG24.

Individual unit type analysis Many of the problems identified below arise from the fact that the housing types are essentially generic “boxes” with external detail applied. It is difficult to comprehend the points of reference for the neo-Georgian rusticated design approach employed for these buildings.

Type A: Fenestration to the front and rear elevations needs to be improved as the layout and sizing of windows is disjointed and inappropriate. Flank elevations to some of the Type A buildings should contain some articulation, i.e. windows. There is not enough vertical emphasis separating individual dwellings. Furthermore, the building heights are inappropriate and should be two and a half storeys in the main with two storeys only to 117A - 119A (Plan Ref: 06/053/021 A). Internally, the positioning of the door into the kitchen of the unit does not work well in terms of circulation and active use of the kitchen.

Type B: Fenestration to the front and rear elevations needs to be improved as the layout and sizing of windows is disjointed and inappropriate. Flank elevations to some of the Type B buildings should contain some articulation, i.e. windows. Again, there is not enough vertical emphasis separating the dwelling units. The roofs are totally out of proportion with the remainder of the building – the height of the roof itself actually exceeding the height of the two storey brick wall element. These buildings are simply not two and half storeys in height. Internally, the positioning of the door into the kitchen of the unit does not work well in terms of circulation and active use of the kitchen.

Type C: Fenestration to the front and rear elevations needs to be improved as the layout and sizing of windows is disjointed and inappropriate. The brick arches over the ground floor windows are marooned alone as a random ‘design’ feature. Flank elevations are

G 42 bland and ugly and need some articulation. Internally, the positioning of the door into the kitchen of the unit does not work well in terms of circulation and active use of the kitchen.

Type D: Fenestration to the front and rear elevations needs to be improved as the layout and sizing of windows is disjointed and inappropriate. There is no passive surveillance and there is a poor appearance at ground floor level to the front due to the positioning of garage within the building. Potential overlooking of neighbouring rear gardens due to the location of the living room and Juliet balcony at the rear of the unit at first floor level. Again brick arch on proposed garages is a marooned and unsightly ‘design’ feature. Rear gardens are not of a comparative size and length with the surrounding existing dwellings outside the site, which gives rise to particular problems with the Type D dwellings as they are large three-storey units (4 bedroom) with short gardens positioned perpendicular to adjoining Type C and J dwelling units. The building resembles a block of flats and requires more articulation.

Type E: There are still issues with the blocks of Type E flats - the design of the flank/side elevations is not good in terms of active frontages. This is partly a function of the size of the blocks and the approach adopted to designing corner blocks. The roofs of the flatted blocks are excessively large and poorly laid out and are very high. The corner units need to be smaller and better integrated into the housing blocks. There are inconsistent treatments in terms of sills and lintels. The entrances to the buildings do not sit comfortably with the rest of the buildings in terms of their scale and type. The entrances look like back doors and do not attract visitors or allow them to understand how the building works. The main access route into the flatted block is somewhat tortuous and requires rethinking. The buildings are not set back from the street scene and will give rise to a lack of privacy for the ground floor units, in particular the bedrooms fronting onto the street scene.

Type F: Fenestration to the front and rear elevations needs to be improved as the layout and sizing of windows is disjointed and inappropriate. The balconies and privacy screens/supporting pillars add nothing to the design and appearance of the building. They

G 43 create more shadow for the ground floor front rooms. There is no need for a full wall/pillar at ground floor level between each unit. It is not possible from the plans (Refs: 06/053/037 and 06/053/039) to see how the attached Type F and Type G buildings would work together. One or both of the plans appears to have been provided at an inappropriate scale or not to scale. (They cannot both be 1: 100 given that the Type G units are shown as smaller on plan than the Type F when they are intended to be of the same number of storeys with a slightly higher floor to ceiling height and roof height).

Type G: Fenestration to all elevations needs to be improved as the layout and sizing of windows is disjointed and inappropriate. There is inappropriate set back from the main road into the site – the relationship of bedroom windows and secondary windows to living areas to the road is not acceptable. This is a particular problem at ground floor level, but is also not highly successful at first and second floor level. The roof is at a different angle to that of the Type F units and as a result the juxtaposition appears uncomfortable. The mono-pitched roof to the main entrance is unpleasant and not in keeping with the rest of the building. The flatted blocks at either end of the crescent are bulky and poor in terms of pedestrian environment.

Type H: The proposed building is “neither fish nor fowl” – it fails to work either as a retail centre or as residential accommodation. The elevations of the neighbourhood centre do not reflect the purpose of the building and have not incorporated sufficient servicing and bin stores. The building is not designed to have a dual frontage. The Juliet balconies are not sufficiently well separated from the retail ground floor. The building is hard up against the edge of the site, which is likely to prejudice the proper development of the BECC site (this is also true of the buffer to the Type E which borders the BECC site). The residential accommodation above the retail element will, in all probability, be bordered on 3 or 4 sides by car parking and roads, and it is not considered that this would provide a sufficient level of amenity for the future occupiers of the first and second floor flats.

Type J: The fenestration and general elevational treatment is poorly thought out. The buildings look forward out onto a significant expanse of hard surfacing and are positioned

G 44 over parking. There does not appear to be any amenity space provided for the two- bedroom unit. There is a considerable amount of blank façade to the rear and flank elevations. The poor standard of amenity is exemplified by the need to use roof lights to the rear as the only source of natural light to the bathroom and access. Overall, this type of unit is particularly poor and should be removed entirely from the development.

Type K: The building resembles nothing more than a Victorian workhouse or prison, albeit with a number of Juliet balconies. The roof layout is convoluted, particularly when viewed from the flank elevations. The entrances are poorly detailed and of an inappropriately small size relative to the rest of building. The building is overly large and requires greater articulation to lighten its overwhelming and dour appearance.

Type L: This does not fit in with the streetscape. The existing buildings on the site should be retained at least until the BECC site is redeveloped. The building effectively blocks off pedestrian access to Leggatts Way, which is not acceptable. This pedestrian access must be retained to allow for ease of movement onto and off the site and to ensure legibility around the site.

Based on the above analysis, it is considered that the proposed design and layout of all of the flats and units is currently inappropriate for this development and that they do not work cohesively to create a legible and functional development.

Transportation, access and parking Access and traffic There are two proposed vehicular access points onto the site, from North Western Avenue and from Heather Lane. The Highway Authority has no fundamental objection to the proposed residential development. However, the transport assessment submitted in support of the development is inadequate in terms of number of assumptions made, and fails to demonstrate adequate measures to mitigate the impact of the development. It is therefore considered that the proposed vehicular access and internal road system is not compliant with Policies T4 and T21 of the Watford District Plan 2000.

G 45 Parking The application site is located within Car Parking Zone 4 in the Watford District Plan 2000. Accordingly, the following are the maximum parking standards:

1 Bedroom Dwellings – 1.25 spaces per dwelling 2 Bedroom Dwellings – 1.5 spaces per dwelling 3 Bedroom Dwellings – 2.25 spaces per dwelling 4 or more Bedroom Dwelling – 3 spaces per dwelling

The proposal incorporates a total of 248 units, including 172 2-bed flats, 17 3-bed houses and 59 4-bed houses. There is also a Neighbourhood Centre and a LEAP.

The following maximum parking spaces should be provided:

172 (2bed) x 1.5 = 258 car parking spaces 17 (3bed) x 2.25 = 38.25 car parking spaces 59 (4bed) x 3 = 177 car parking spaces Total: 473.25 car parking spaces.

According to the Transport Statement completed by WSP Development and Transportation dated September 2007, there is provision of 348 car parking spaces on the site (although only 345 are shown on the plans). This is 73% of the required provision (or 1.4 spaces per unit) with no additional provision for the Neighbourhood Centre. It is not considered that there is a sufficient number of car parking spaces on the site for the proposed number of units. The site is located in Zone 4, with very minimal public transport in the area such that there will be a heavy reliance on the private car. Even if the ratio of 1 space per flat and 2 spaces per house plus an additional 25% for visitors were used to determine the required provision, there would still be a shortfall of 41 car parking spaces and still no provision for the neighbourhood centre. Whilst it is acknowledged that the parking standards are maxima, it is considered that in this location (identified as the ‘external areas of Watford’ by the applicant’s traffic consultant) the

G 46 maximum standards should generally be met.

Based on the above assessment, it is not considered that the proposal is compliant with Policies T22, T24 and Appendix 2 of the Watford District Plan 2000.

Archaeology The County Archaeologist recommends that the applicant provide further archaeological information regarding the impact of the proposal on the historic environment before any application is determined. Further, the former college buildings should be archaeologically recorded prior to any demolition, alteration or development. This could be secured as a condition of planning permission if the application was approved.

Trees and landscaping The Council’s Arboricultural Officer has raised concerns in relation to the proposed removal of Oak Tree T20 and part of Group G2. Although the proposal could be amended in order to comply with Policies SE37 and SE39, the proposal is currently contrary to these policies.

Community safety The Hertfordshire Constabulary Crime Prevention Officer raised concerns in relation to fencing, dead spaces, movement permeability, pedestrian accesses, lighting, layout, the LEAP and landscaping. It is evident from a number of his comments that the proposal is not considered to be appropriate in terms of safety and that changes would have to be incorporated into any future scheme. The current proposal is therefore contrary to Policy U4 and SPG14 of the Watford District Plan 2000 and PPS3.

Playing Fields Sport England has registered a holding objection based on the provision of insufficient information to determine whether the proposal accords with Sport England's playing fields policy “A Sporting Future for the Playing Fields of England” (1997). The two main areas of concern include the intrusion of the LEAP into one of the playing fields, and the potential

G 47 impact of the development on the changing facilities currently provided for the playing fields.

The proposed Locally Equipped Area of Play (LEAP) must be assessed against The Six Acre Standard, published by the Fields In Trust (FIT), which sets out the Minimum Standards for Outdoor Playing Space. It is the standard intended for use by developers and local authorities who have a statutory duty to implement a local plan which makes appropriate recreational provision for the community. There is a question over the level of compliance if the LEAP with this standard. Further, it has been confirmed that the proposed LEAP is sited within one of the existing playing fields and as such is contrary to Policy L5 of the Watford District Plan and PPG17.

Drainage Thames Water has identified an inability of the existing waste water infrastructure to accommodate the needs of this application. If the application is approved, Thames Water seeks a 'Grampian' condition in relation to a drainage strategy.

The Environment Agency also objects to the proposed development for the following reasons: • Greenfield discharge rates have not been achieved for the application site. • 1 in 100 year and climate change on-site attenuation has not been provided. • The use of SUDS systems has not been adequately addressed.

In the light of these comments, the proposed development is not considered to be compliant with Policies SE27, SE29 and SE30 of the Watford District Plan 2000.

Ecology The Council’s Conservation and Development Officer has raised concerns about bat roosts, native hedgerows, lighting, buffer zones, biodiversity plan, swift nesting boxes, bird boxes, green roofs, habitat creation, sustainability, plant and equipment, scrub clearance and tree felling.

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Whilst many of these issues could be covered by conditions, it is considered that due to the volume of work to be undertaken, it would be inappropriate for the application to be recommended for approval prior to receipt and analysis of the relevant information.

Consideration of objections received Most of the issues raised by the objectors have been addressed in the report above. Further comment on the remaining concerns is set out below:

Potential for anti-social behaviour along the currently disused entrance to the site of Leggatts Way The application site includes the strip of land between Nos. 122 and 124 Leggatts Way. Therefore, if this area is to be re-opened, it must be designed to avoid any anti-social behaviour by making the path pedestrian friendly and well lit.

Noise during construction If the application were to be approved, a standard condition covering this mater would be included.

No provision of facilities for young people As the application site does not include the BECC site, this is not considered a necessary requirement as part of the current development.

Privacy of houses The existing houses along Leggatts Way would be unduly affected by the siting of the housing that they would back onto. The minimum privacy distances have not always been achieved and as such it is not considered that the proposed layout is acceptable.

Question over the legitimacy of the Home Zone and whether it being used in its specific technical sense The proposed Home Zone is not considered to be satisfactory, especially in light of the

G 49 tracking diagram shown in the Transport Assessment which is based on an earlier plan with straight internal access roads.

The main school building should be retained and converted to residential As the main school building is not listed or located within a conservation area, the Council has no control over the retention or demolition of this building.

Section 106 contributions The proposal requires a planning obligation to secure financial contributions towards the provision of public open space, children’s play space, sustainable transport, health care, libraries, youth and childcare, primary education and fire hydrant provision in accordance with Policies L8, L9, T1, T4, T7, T9 and H10 of the Watford District Plan 2000. Further, the provision of 30% affordable housing also needs to be secured. The applicant has indicated a willingness to enter into a Section 106 Agreement to make the relevant contributions should the Council be minded to grant planning permission, although there is no agreement as to the appropriate affordable housing.

The following financial contributions would be required: • £176,750 towards sustainable transport; • £101,680 towards childcare and youth facilities; • £50, 592 towards library facilities; • £414,608 towards primary education facilities; • £613,056 towards the provision or improvement of open space; • £244,280 towards the provision or improvement of children’s play space; • £108,660 towards the provision of health care facilities.

Conclusion

The proposed development is not considered to be of an appropriate layout, scale, height, massing or mix for this “out of centre” location. The proposal has not been well thought out, as exemplified by the objections from a majority of the consultees. Many of the

G 50 submitted reports are inadequate in the information they provide, and are lacking in justification for their departure from policies in the Watford District Plan 2000, the draft planning brief and national guidance in the form of Planning Policy Statements and Guidance.

Any development on this site must provide a high quality design and finish. Whilst a design on this site must respect the existing neighbourhood character, there is a wide scope of possibilities for innovative layouts and buildings on this large site and also an opportunity to create a new sense of place. The planning brief is purposefully not too prescriptive in order to allow for individual interpretation; however, there are a number of defined parameters that must be met. This proposal fails to meet the core objectives for the site and, as a result, the design is wholly inappropriate and out of character with the local neighbourhood.

The amenity of the existing occupiers surrounding the site must also be protected, and a number of the proposed properties abutting the Leggatts Way houses pay little regard to the levels of privacy currently enjoyed, nor the level of amenity that can reasonably be expected to be enjoyed, by these occupiers.

The proposed scheme is considered to be an overdevelopment of the site, and is contrary to advice given at pre-application stage. It fails to comply with many of the policies in the Watford District Plan and national Planning Policy Statements and Guidance. For the above reasons, the Development Manager recommends that planning permission be refused.

HUMAN RIGHTS IMPLICATIONS The Local Planning Authority is justified in interfering with the applicant’s Human Rights in order to alleviate any adverse effect on adjoining properties and their occupiers and on general public amenity. With regard to any infringement of third party Human Rights, these are not considered to be of such a nature and degree as to override the Human Rights of

G 51 the applicant and therefore warrant refusal of planning permission.

RECOMMENDATION

That planning permission be refused for the following reasons:

1. The proposed development, by reason of its scale, siting, design and layout would result in an overly dominant and poorly laid out scheme that would be detrimental to the character and appearance of the area, would not result in a cohesive relationship with the adjoining properties and would be detrimental to the amenity of the future occupiers. This would be contrary to Policies U1, U2, U3, H5, H7 and H8 of the Watford District Plan 2000, SPGs 4, 5 and 6 and PPS1 and PPS3.

2. The design of Building H is inappropriate and unworkable for both neighbourhood centre and residential uses, and it also relates poorly to the surrounding layout and the adjoining site. The proposed design does not create a legible and functional building and it is therefore not fit for purpose.

3. Insufficient information has been submitted to demonstrate that adequate measures could be put in place in order to mitigate the impact of the development on the local road network in accordance with Policy T21 and T24 of the Watford District Plan 2000 and PPG13.

4. There is insufficient evidence to demonstrate that the proposed Locally Equipped Area of Play (LEAP) will meet the required standard of provision (The Six Acre Standard). In addition, the proposed LEAP is sited within one of the existing playing fields. The proposal is therefore contrary to Policy L5 of the Watford District Plan and PPG17.

G 52 5. The proposal fails to incorporate an adequate landscaping plan that retains the significant vegetation around the site and protects the habitats of local and protected animal species in accordance with Policies SE32, SE37, SE39 of the Watford District Plan 2000 and PPS9.

6. The proposal fails to include sufficient archaeological details on the impact of the proposal on the historic environment in accordance with PPG16.

7. The proposal fails to incorporate appropriate measures to contain and attenuate surface water run off flows from the site in accordance with PPS25 and Policies SE27 and SE30 of the Watford District Plan 2000.

8. The proposal fails to address the inability of the waste water infrastructure to accommodate the needs of this application in accordance with SE29 of the Watford District Plan 2000 and PPS10.

9. The proposal fails to incorporate secure by design objectives in accordance with Policy U4 of the Watford District Plan 2000 and SPG14.

10. The design of proposed buildings on the northern side of the development does not address satisfactorily the issues relating to traffic noise from the A41. The Local Planning Authority is not therefore satisfied that the proposed development would result in a satisfactory noise environment in accordance with PPG24 and Policy SE22 of the Watford District Plan 2000.

11. There is insufficient provision of refuse and recycling storage for the residential units contrary to Policy SE7 of the Watford District Plan 2000.

12. The proposed development fails to make provision for public open space, children’s play space, sustainable transport measures, childcare and youth facilities and

G 53 health care facilities contrary to Policy L8, L9, T1, T4, T7, T9 and H10 of the Watford District Plan 2000.

13. The proposal fails to make provision for affordable housing contrary to Policy H17 and SPG1 of the Watford District Plan 2000.

Informatives

1. In reaching it's decision the Local Planning Authority had regard to the following policies:

Watford District Plan 2000: SE4 – Energy Efficient Design SE7 – Waste Storage and Recycling in New Development SE22 – Noise SE23 – Light Pollution SE27 – Flood Prevention SE29 – Utilities Infrastructure SE30 – Surface Water Run-off, Water Conservation and Sustainable Drainage Systems SE32 – Sites of Nature Conservation Importance SE39 – Tree and Hedgerow Provision in New Development SE42 – Home Zones T1 – South West Hertfordshire Transportation Strategy T4 – Transport and New Development T6 and T7 – Pedestrian Facilities in Developments T9 and T10 – Cycling Facilities T21 – Access and Servicing T22 – Car Parking Standards T23 – Non-Residential Development T24 – Residential Development T27 – Car Park Location and Design

G 54 H5 – Development on Previously Developed Land H7 – Primarily Residential Areas H8 – Residential Standards H10 – Educational and Community Facilities H11 – Housing Mix H12 – Housing Density Standards H15 – Non-Residential Proposals in Residential Areas H17 – Provision of Affordable Housing E3 – Small Business, Self-Employment and Homeworking S4 – Shop Design, Access and Facilities L5 – Playing Fields L8 – Public Open Space L9 – Children’s Play Space L11 – Maintenance of Open Spaces, Play Areas and Pocket Parks U1 – Quality of Design U2 – Design and Layout of Development U3 – Integration of Character U4 – Community Safety U6 – Landscape Design U24 – Shopfronts IMR2 – Planning Obligations

Supplementary Planning Guidance SPG1 – Affordable Housing. SPG3 – Housing Density Standards SPG 4 - Privacy Guidelines SPG 5 - Private Gardens SPG6 – Internal Room Space Standards SPG10 – Open Space Provision SPG14 – Designing for Community Safety

G 55 Drawing numbers • 06/053/019 Location Plan • 06/053/020 Location Plan Development / Open Space Areas • 06/053/021A Planning Layout06/053/022A Planning Site Layout and Sports Field • 06/053/023 Proposed Plans Type A • 06/053/024 Proposed Elevations Type A • 06/053/025 Proposed Plans Type B • 06/053/026 Proposed Elevations Type B • 06/053/027 Proposed Plans Type C • 06/053/028 Proposed Elevations Type C • 06/053/029 Proposed Plans Type D • 06/053/030 Proposed Elevations Type D • 06/053/031 Proposed Plans Type E • 06/053/032 Proposed Plans Type E First/ Second/ Third Floor • 06/053/033 Proposed Elevations Type E • 06/053/034A Proposed Side Elevations Type E • 06/053/035 Proposed Rear Elevation Type E • 06/053/036 Proposed Plans Type F • 06/053/037 Proposed Elevations Type F • 06/053/038 Proposed Plans Type G • 06/053/039 Proposed Elevations Type G • 06/053/040A Proposed Plans Type H • 06/053/041A Proposed Elevations Type H • 06/053/042B Proposed Plan and Elevations Type J • 06/053/043A Proposed Plans Type K • 06/053/044A Proposed Elevations Type K • 06/053/045 Proposed Elevations Type L • 06/053/046A Proposed Elevations Type L • 06/053/047 Double Garage Details • 06/053/048 Single Garage Details

G 56 • 06/053/049 Car Port Details • 06/053/050 Bin and Cycle Store Details • 06/053/051 Storey Height Plan • 06/053/052 Proposed Elevations Type E Four Storey Block • WIM16247-03A Tree Protection Plan • WIM16247-11 Landscape Proposals Sheet 1 0f 6 • WIM16247-11 Landscape Proposals Sheet 2 0f 6 • WIM16247-11 Landscape Proposals Sheet 3 0f 6 • WIM16247-11 Landscape Proposals Sheet 4 0f 6 • WIM16247-11 Landscape Proposals Sheet 5 0f 6 • WIM16247-11 Landscape Proposals Sheet 6 0f 6 • Visual 1 • Visual 2 • Visual 3 • Visual 4 • Visual 5 • Visual 6 ______ACCESS TO INFORMATION

Background Papers • Archaeological Desk Based Assessment prepared by CgMs dated December 2006; • Historic Building Assessment prepared by CgMs dated October 2007; • Flood Risk Assessment prepared by Fenland Hydrotech Consulting Engineers dated October 2007 Revision 0; • Environmental Noise Assessment prepared by Alan Saunders Associates dated 12 September 2007; • Extended Phase 1 Habitat Survey Report prepared by ACD Arboriculture dated August 2007; • Landscape Management and Maintenance Report prepared by ACD Arboriculture

G 57 dated September 2007; • Arboricultural Implications Assessment prepared by ACD Arboriculture dated 21 September 2007; • Tree Report prepared by ACD Arboriculture dated 21 September 2007; • Arboricultural Method Statement prepared by ACD Arboriculture dated 21 September 2007; • Landscape Design Strategy and Palette of Materials prepared by ACD Arboriculture dated 23 September 2007; • Planning Statement prepared by Consensus Planning dated September 2007; • Design and Access Statement prepared by Architectus dated 20 September 2007; • Transport Assessment prepared by WSP Development and Transportation dated September 2007.

Published Documents PPS1 – Delivering Sustainable Development PPS3 - Housing PPS9 – Biodiversity and Geological Conservation PPS10 – Planning for Sustainable Waste Management PPG13 – Transport PPG16 – Archaeology and Planning PPG17 – Planning for Open Space, Sport and Recreation PPG24 – Planning and Noise PPS25 – Development and Flood Risk Watford District Plan 2000 SPGs 1, 3, 4, 5, 6, 10 and 14

Case Officers: Ms Hannah McBride-Stephens and Ms Joanna Gilbert-Wooldridge Telephone Ext: -01923 278286

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