Development Brief for the Gants Hill Area Action Plan Opportunity Sites C, D & E at Eastern Avenue, Gants Hill

Development Brief for The Gants Hill Area Action Plan Opportunity Sites C, D & E at Eastern Avenue, Gants Hill

Planning & Regeneration Adopted February 2014

0 1. Introduction

1.1. This Development Brief is based on a planning assessment of the Opportunity Sites C to E as identified in Map 3 of the Gants Hill Area Action Plan, adopted by the Council in May 2009. These sites are all located on the west section of the Eastern Avenue at Gants Hill, on the southern side of the road, and include:

C. Commercial House (406-410 Eastern Ave); D. Montrose House (412-416 Eastern Ave); and E. The Vauxhall Car Showroom (418-420 Eastern Ave).

1.2. The purpose of this Development Brief is to inform prospective developers and the community of the Council’s planning requirements for the development of the above sites; the quality of design expected, and the type of development the Council envisages occurring on these sites. The Brief does not take into account any rights of way, access over the site, or other legal issues that may require resolution prior to development.

2. Site Location and Description

2.1. The Gants Hill Area Action Plan Opportunity sites C, D and E are located on the south-western section of the A12 Eastern Avenue, at Gants Hill district centre, which lies in the southern, central area of the borough. Gants Hill is a district centre and key investment area within Redbridge that has a strong urban environment, and good local public transport services (but with some tall buildings generally removed from the central area of the roundabout). Traffic flows around the roundabout are very busy with some 55-60,000 vehicles travelling through the centre on a daily basis. There is a local retail economy but it has struggled for several decades, needs reviving and is not a significant draw for shoppers compared to other centres in the borough. This situation has improved in recent years with the completion of additional residential development and new retail attracted to the area. However the centre does have a strong evening economy, with a healthy number of bars and good quality restaurants on offer, and in recognition of Gants Hill’s performance in the evening and through the night, its number of venues, local transport, crime levels, cleanliness and character, it was awarded Purple Flag status in 20131.

2.2. This brief covers three of the remaining opportunity sites in the Area Action Plan (AAP) for Gants Hill: Commercial House (406-410 Eastern Ave); Montrose House (412-416 Eastern Ave); and the Vauxhall Car Showroom (418-420 Eastern Ave). These sites have all been identified in the Gants Hill Area Action Plan, and were originally recognised as opportunity sites in the Gants Hill Area Action Plan Supporting Studies document (January 2007) as sites suitable for well-designed, higher-density, multi-storey development within the district centre, as well as being suitable for the promotion of mixed-use development and mixed-use areas.

2.3. The maps on the pages below show where Gants Hill is in the context of the borough as a whole and looks closer in detail at how the three sites are actually split up in terms of boundaries and ownership. The current uses on the sites include office use (Commercial House and Montrose House; B1 use class), and a former car sales show room (Sui Generis). Section 4 below on current and preferred uses goes into more detail on the uses on the sites.

1 See Purple Flag website for further information on the Purple Flag programme: https://www.atcm.org/programmes/purple_flag/WelcometoPurpleFlag

Map 1: Location of Gants Hill in relation to the borough. 2

A12/Eastern Avenue (West)

A Wentworth House, 350 Eastern Ave B Big Yellow Storage, 374-404 Eastern Ave C Commercial House, 406-410 Eastern Ave D Montrose House, 412-416 Eastern Ave E The Vauxhall Car Showroom, 418-420 Eastern Ave

Map 2: This Map shows all the sites on the south side of Eastern Avenue (West), but this brief is focused on sites C, D and E only. 3

2.4. In terms of the size of the sites, their collective area is approximately 6,046sqm/65,078.6sq ft/0.6046ha, which is a large site area for a key district centre, and is able to accommodate a major development scheme. Their individual footprint areas are: • Site C - 1,671sqm/17,986.5sq ft/0.1671ha; • Site D - 1,596sqm/17,179.2sq ft/0.1596ha; • Site E - 2,779sqm/29,912.9sq ft/0.2779ha.

2.5. As stated above the heights of the buildings on these sites range from a single storey at the former Vauxhall Car Showroom on site E, to ground and five storeys above for the office blocks on sites C and D. Generally however heights in the immediate area are fairly low at predominantly two storeys (residential). All the opportunity sites front onto the A12 Eastern Avenue, a very busy arterial road that flows westward into central London, and back onto Clarence Avenue (one way with exit only from the roundabout), which is a road serving both residential and non-residential properties. The relationship that the buildings have with these two roads differs first in that none of the buildings use the A12 road as a vehicular access point but they all have vehicular access at their rear from Clarence Avenue, which is still accessible from the Gants Hill roundabout. In terms of the character of the buildings on the opportunity sites, again their relationship with the A12 highway and Clarence Avenue differs, which is discussed further below.

2.6. In terms of the make up of the character of the surrounding area there is a strong divide here too; on the one hand there is the very busy A12 road and roundabout area, with fairly active business and retail areas and high volumes of traffic and some tall buildings, and on the other there are the low rise residential streets to the rear of these businesses. Sites C, D and E represent part of a dividing line or band of buildings along Eastern Avenue west between these two town centre characters, and this occurs elsewhere within the town centre, where there are a line of shops and businesses fronting the main, busy roads and residential streets to their rear.

2.7. Much of the pedestrian movement within the district centre does not occur around the opportunity sites A to E on the west side of Eastern Avenue, which the Council believes would change if these sites were redeveloped for uses that attract pedestrian activity. This does have an effect on the character immediately around the sites on this part of Eastern Avenue, which becomes more isolated the more one journeys west along Eastern Avenue. From a land use perspective there is a strong sense that much of the true potential of this part of the district centre has been limited by the type of development that has to become established there namely office development with limited active frontage).

2.8. Traffic Issues and Public Transport

2.9. As stated above the Eastern Avenue A12 is a major road in London which runs through Gants Hill district centre. Traffic volumes are very high in the centre (approximately 60,000 vehicles each day) creating major traffic issues and problems for the Gants Hill area. The A12 road flows westwards until it reaches Mabley Green Park, Homerton where it turns south and continues past Victoria Park and Hackney Wick Rail and Tube Station and becomes the Blackwall Tunnel Approach. In the east the A12 travels on to Romford as the Eastern Avenue until it reaches Gallows Corner where it becomes the A12 Colchester Road which links with the A1023/M25 Nags Head junction, and continues northwards on to Ipswich. Clearly this is a major road within the southeast region and naturally creates a large volume of traffic, which is evident in the daily traffic volumes at Gants Hill. A further very busy and key route through Gants Hill is the Cranbrook Road North and South, or the A123, between Barking Park in the south, where it links with the A124 Longbridge Road, and the A113 in the north where it connects with the High Road in Chigwell.

Aerial Photography 1: Opportunity Sites C, D and E at Eastern Avenue Gants Hill

2.10. Public transport at Gants Hill is very good with multiple bus routes (12) travelling through the centre to various parts of the East London sub region; and with the Gants Hill Tube station providing a convenient underground service to central London via the Central Line. The Public Transport Accessibility Levels (PTAL) in the area are at 5, which is very good.

2.11. The opportunity sites are well positioned to benefit from the very good public transport services in Gants Hill being located close to the Eastern Avenue (West) subway entrance/exit on the southern side of the road. They are also located close to the Central Line Underground Station

under the roundabout, where a very good variety of bus services pass through, making the sites highly accessible in terms of public transport.

2.12. Recently there have been significant improvements made in the area by Transport for London (TfL) and the London Borough of Redbridge. Resurfacing work has been carried out on the carriageway around the roundabout; traffic flows have been made safer and more efficient with the closure of Clarence Avenue to two way traffic (exit only from the roundabout), improved, easier turning points and alignments on the roads around the roundabout; and the installation of pedestrian and cycle signal controlled crossing facilities which are co-ordinated with the roundabout signals, significantly improving pedestrian connectivity across the roundabout and within the District Centre generally.

2.13. Other Site Location Considerations

2.14. Pedestrian Activity

2.15. As a district centre Gants Hill naturally retains a number of different uses and is an area appropriate for a wide mix of uses, some of which could potentially be incorporated into a single development scheme. The district centre essentially remains a retail centre but still retains some office use, community facilities and has a strong evening economy, including restaurants, bars and night clubs. The aim of Gants Hill AAP retail policies is essentially to broaden the retail experience of Gants Hill and make it more of a shopping magnet by exploiting the very good transport links the centre has and so broaden its catchment. The development of opportunity sites on Eastern Avenue (West) and its transformation into a new, key retail area is part of the overall strategy of the AAP.

2.16. Currently the relationship that the existing uses on Eastern Avenue (West) shares with other uses in Gants Hill is rather disconnected in the sense that the uses on the opportunity sites A to E provide very little pedestrian activity or interest to the District Centre. The AAP seeks to change this by bringing uses to these sites that:

• Are linked to the retail aspect of the district centre as a whole; • Build upon the recently installed pedestrian links (crossings) and traffic calming measures that increase access for pedestrians across the centre; and • End the severance of the different parts of the district centre by offering customers a more complete shopping experience across the centre.

2.17. The aim is also to enable a critical mass of development that will improve every aspect of the district centre economy, and this is to be achieved by creating the right conditions for the encouragement of mixed use development.

2.18. Building Heights

2.19. Generally the heights in this part of the centre [around sites C, D and E] are taller and of a bigger scale than most of the buildings within the district centre, particularly if you consider the height and scale of the neighbouring sites A and B. There are of course other parts of the district centre where other tall buildings exist, but in general the scale across Gants Hill is fairly low. However the existing scale having been established is not particularly imposing on or damaging to the amenity of local residents and has shown that buildings of height and scale can work in this part of the district centre. The policy section below discusses issues relating to the height of new development schemes within the district centre in more detail.

2.20. Car Parking/Transport

2.21. Sites C, D and E have a large number of parking spaces to the rear of the buildings, with access to it from Clarence Avenue. These are currently staff parking spaces that could become visitor spaces supporting new development on the sites, There is also the potential for car clubs to be organised for new housing (flats) development in the district centre. The Gants Hill AAP makes it clear that provision of adequate car parking is critical to the economic regeneration of Gants Hill, and recognises that a balance has to be struck between encouraging new investment in district centres by providing adequate levels of parking, and potentially increasing traffic congestion caused by too many cars. The provision of appropriately located, short-term car parking spaces is of importance to the vitality of the retail sector and will be encouraged along the key shopping streets in the district centre.

2.22. Apart from the A12 main, arterial road the roads surrounding opportunity sites C, D and E are not main highways, but there are some key local roads in the area, such as Beehive Lane, which link different parts of the Gants Hill area. Other key, important roads include Woodford Avenue (A1400) to the north of sites C, D and E, and Cranbrook Road A123 (north and south). Woodford Avenue and Eastern Avenue are both part of the Transport for London Road Network (TLRN), and Cranbrook Road is part of the Strategic Road Network (SRN).

2.23. As stated above Transport for London (TfL) have recently carried out road, street and subway improvements in the district centre in partnership with the Council, spending £7.2m on:

• Resurfacing and maintenance work on the roundabout carriageway; • Installation of full signalisation on the roundabout; • Three circulatory lanes on the roundabout; • Removal/rationalisation of guard railings; • Closure of subway entrance at Eastern Ave (West), north side, to enable road realignment; • Closure of Clarence Ave to two way traffic, access to the road from the roundabout, but not from the road to the roundabout; • Pedestrian and cycle signal controlled crossings on all arms of the roundabout; • New median provided at Cranbrook Road North; • Streetscape improvements, including new pavement surfaces and tree planting; • Improvements to the subway network, including general maintenance, new tiling and internal furniture and new coloured tiling and signage for way finding; • New district centre cycling network.

2.24. The road improvements and traffic initiatives in the enhancement scheme were modelled before the scheme was implemented and the AM peak model showed that the cumulative queuing predicted on the approaches to the roundabout was less than that observed during the queue length surveys conducted prior to the scheme, thus a small improvement is made in terms of a reduction in queues of approximately 10% of general congestion. A similar model pattern was observed in the PM peak2. Anecdotal evidence post scheme implementation suggests that the works have improved traffic flow through the roundabout.

2.25. As well as reducing congestion the conversion of the roundabout to signal control has brought significant safety benefits, by offering a traditional engineering solution to the problem of an oversaturated roundabout and an inherently safer form of control. Whilst the congestion benefits are relatively modest the associated benefits with regard to road safety and importantly the opportunities to open up the surrounding environs generally and make them more pedestrian friendly and less traffic dominated, provides significant benefits to motorised

2 Transport for London, Gants Hill Town Centre Enhancement: Option Report, January 2007. Pell Frischmann Consulting Engineers. 7

vehicles, pedestrians and cyclists alike3. As noted above feedback from residents and a local engagement group has informed Council officers that the improvements at Gants Hill have actually enhanced traffic flows and efficiency for drivers and made it easier and safer for pedestrian access across the centre. However for sites C, D and E transport access will be a key issue.

2.26. Retail Demand

2.27. A new retail study has recently been undertaken for the Council (‘Retail, Leisure and Office Demand Study for London Borough of Redbridge Planning Policy and Environment Unit’ August 2012) that offers a current and future perspective for the major centres in the borough, including Gants Hill, with regard to retail, leisure and office demand.

2.28. The study finds that currently Gants Hill has 30 retail convenience units and 42 retail comparison units. There are a total number of 173 units in the centre, with an overall floor space area of 24,888 m². Many of these units are in the leisure/evening economy. The centre also had 16 vacancies with a vacancy rate of 8.5% - this is higher than the borough average of 4.1%, but lower than the Great Britain average of 14.8%. There is an available spend for the Gants Hill of £33,590,000 in convenience goods, but a net leakage of £8,901,000 (26.5%), - total sales are £24,688,000. This last statistic tells us that there is potential for that leakage of spend to be captured with the right, new retail development. However it should be considered that much of the spend leakage in the borough is to larger centres such as Stratford City, Lakeside and the West End – convenience goods stores in Redbridge are forecast to achieve slightly less sales in 2013 than the value of spend in the borough. This hints at centres in the borough needing to perhaps find particular retail niches.

2.29. Population in Gants Hill is set to rise from 26,200 to 30,378 between 2013 and 2028, and in the same period there is a forecast of growth in the demand for convenience goods of £24,220,000 in Gants Hill, and a sustainable increase in the number of food stores of 3.96 for the small format stores (at 1,300m²), and 0.39 for the large format (at 7,100 m²). In the borough as a whole there is a forecast additional demand of 55 small or 5-6 large format food stores by 2028. However currently there is no new comparison and very little convenience goods space in the planning pipeline within the borough to satisfy the rapidly escalating demand. This prognosis of increased demand demonstrates growth capacity and goes some way to supporting the objective of increased retail and positive regeneration set out in the AAP. It is conceivable that one of the additional 5-6 large format stores predicted for development within the borough could be developed at Gants Hill.

2.30. In a previous retail study for the Council (London Borough of Redbridge, Retail and Leisure Study. Roger Tym and Partners, Final Report February 2006) an over representation in the number of units for the service sector in Gants Hill District Centre (currently 43 units) was highlighted and this remains the case. The centre also remains over represented in the restaurant/cafes/take aways and hairdressers/beauty salons/health and fitness sub sectors, and continues to under perform as a retail centre. There is a need to secure a major retail component within the centre in order to better balance and anchor its overall economic composition, and help bring about the regeneration and general economic upturn in Gants Hill sought by the Council and the Area Action Plan strategy.

2.31. Many of the environmental issues suffered in the area that have affected the performance of the centre have been addressed through the traffic improvements and streetscape enhancements in Gants Hill carried out by Transport for London (TfL), and were also highlighted in the strategy of the Council’s LDF Area Action Plan document

3 Transport for London, Gants Hill Town Centre Enhancement: Option Report, January 2007. Pell Frischmann Consulting Engineers. 8 for Gants Hill. High levels of traffic still go through the centre but in a much more efficient way and with a greater level of pedestrian safety due to the addition of at grade crossings on all arms of the intersection, and signalisation on the roundabout. As well as addressing pedestrian safety the new at grade crossings have immeasurably increased pedestrian access making the centre much easier to negotiate. Considering that 517 out of the minimum target of 800 new residential units have been completed in the centre, adding an additional retail customer base, overall the town centre is more amenable to major retail investment now than it perhaps was when the retail study was first carried out.

Photograph 1: Site C Montrose House

Photographs 2 and 3: Sites D and E, Commercial House and Vauxhall Car Showroom (now vacant)

3. Local Development Framework (LDF) Policy Overview

3.1. National Planning Policy Framework (NPPF – March 2012).

3.2. The National Planning Policy Framework (NPPF) is the new Government planning guidance adopted in March 2012 that sets out the planning framework for England and Wales. In section 2 of the guidance it states that in order to ensure the vitality of town centres:

Planning policies should be positive, promote competitive town centre environments and set out policies for the management and growth of centres over the plan period. In drawing up Local Plans, local planning authorities should:

• recognise town centres as the heart of their communities and pursue policies to support their viability and vitality; • define a network and hierarchy of centres that is resilient to anticipated future economic changes; • define the extent of town centres and primary shopping areas, based on a clear definition of primary and secondary frontages in designated centres, and set policies that make clear which uses will be permitted in such locations; • promote competitive town centres that provide customer choice and a diverse retail offer and which reflect the individuality of town centres; • retain and enhance existing markets and, where appropriate, re-introduce or create new ones, ensuring that markets remain attractive and competitive; • allocate a range of suitable sites to meet the scale and type of retail, leisure, commercial, office, tourism, cultural, community and residential development needed in town centres. It is important that needs for retail, leisure, office and other main town centre uses are met in full and are not compromised by limited site availability. Local planning authorities should therefore undertake an assessment of the need to expand town centres to ensure a sufficient supply of suitable sites; • allocate appropriate edge of centre sites for main town centre uses that are well connected to the town centre where suitable and viable town centre sites are not available. If sufficient edge of centre sites cannot be identified, set policies for meeting the identified needs in other accessible locations that are well connected to the town centre; • set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres; • recognise that residential development can play an important role in ensuring the vitality of centres and set out policies to encourage residential development on appropriate sites; and • where town centres are in decline, local planning authorities should plan positively for their future to encourage economic activity.

3.3. It is considered by the Council that the Gants Hill Area Action Plan and the LDF Core Strategy documents from which its policy is formulated conforms to all the above measures outlined in the NPPF with regard to planning for the future vitality of Gants Hill District Centre.

3.4. The local planning policy context for Gants Hill district centre is guided by Redbridge Council Local Development Framework planning policies in the form of:

• Local Development Framework Core Strategy Development Plan Document (March 2008); • London Borough of Redbridge Borough Wide Primary Policies Development Plan Document (May 2008); and • London Borough of Redbridge Gants Hill District Centre Area Action Plan Development Plan Document (May 2009)

3.5. Key LDF Policies

3.6. The key strategic Core Strategy policy context pertaining to Gants Hill essentially covers the main aspects of the Gants Hill Area Action Plan (AAP) strategy which includes town centre growth (regeneration); retail; housing; and the future use of employment land (office conversion). The Core Strategy policies that are fundamental to the regeneration strategy for the district centre include:

• Strategic Policy 1: Overall Growth; • Strategic Policy 4: Retail; • Strategic Policy 7: Housing

3.7. The Borough Wide Primary Policies Development Plan Document (DPD) also contains key planning policies that relate to or guide regeneration strategies for Gants Hill district centre. Gants Hill AAP policies are an expression of and merge with borough wide policy objectives. The key borough wide policies that relate to the Gants Hill AAP include:

• Policy R1 – Sustainable Centres; • Policy R2 – New Shopping Development; • Policy H1 – Housing Provision; • Policy BD1 – All Development; • Policy BD2 – Tall Buildings

3.8. The policies from these development plan documents are outlined in more detail in Appendix 1 below.

3.9. AAP Policy Context

3.10. In terms of the policy context within the Gants Hill Area Action Plan (AAP), whilst they are aimed at addressing issues within the local Gants Hill area the policies are also linked to and an expression of Core Strategy and Borough Wide policy aims and objectives. The main objective of the AAP for Gants Hill is to improve the local district centre economy, chiefly by encouraging new investment in the area and enabling new housing and mixed use development; this is essentially a town centre regeneration programme. The key preferred policy approach for the AAP consists of AAP policies:

• GH4: Building Heights; • GH5: Land Use; • GH6: Expanded Retailing; • GH7: Housing; • GH8: Use of Employment Land.

3.11. There are also other important policy options that include issues relating to sustainable transport and amenity space, but the policies outlined above are those that directly tackle the chief concern of the failing town centre economy.

3.12. Retail

3.13. With regard to retail in Gants Hill the AAP makes a number of important key statements about the nature of the retail economy in Gants Hill district centre, the capacity for further retail, Government guidance on retail in town centres, and how the Council intend to respond with local AAP policies. The AAP states that Gants Hill has a small customer base within its catchment

area due to a lack of passing trade stopping off within the centre, and as stated above a new retail study recently undertaken for the Council states that there is a net leakage of spend indicating that there is potential for that leakage of spend to be captured with the right, new retail development. Government policy says that where district centres are in decline, local authorities should consolidate and strengthen these centres “by seeking to focus a wider range of services there, promote the diversification of uses and improve the environment.’

3.14. In order to address these issues Policy GH6: Expanded Retailing states that:

‘The Council will grant planning permission for development which broadens the retail offer within Gants Hill. In particular, planning permission will be granted for:

1. A supermarket appropriate in scale to a district centre and providing for more than the local catchment. Opportunity Sites A-E along Eastern Avenue (on Map 3: Opportunity Sites) (either individually or combined) would be suitable locations. 2. Other convenience retail within the District Centre. 3. Retail uses within the subway system. 4. Ground-floor retail uses within mixed-use developments.

3.15. The policy also identifies Sites A-E as suitable sites for a supermarket as these are currently subject to low intensity use and likely to come forward in the short to medium term. The Council wishes to see retailing on the ground floor of mixed-use developments, to ensure an active street frontage is developed and maintained. The policy also makes it clear in its justification text that If a supermarket has not been completed within the District Centre by 2012 or if prior to this date only one opportunity site remains potentially available and feasible (from Sites A-E), the Council will consider the use of Compulsory Purchase Order (CPO) powers on the most suitable site at that point in time. Developers are advised however that a CPO process involves significant time and cost implications, as well as other associated risks. A planning permission would need to be in place, and effective measures to assemble the land without a CPO must initially be fully pursued by the developer before a CPO could be considered by the Council. Although the policy highlights all the opportunity sites identified on Eastern Avenue west as having the potential for retail/supermarket development, it is considered that sites C, D and E have the greater potential to come forward for this particular land use.

3.16. Housing

3.17. At the time when the AAP for Gants Hill district centre was drafted the centre had a very small residential population, housed mainly in units above shops, but with the level of recent housing completions in the town centre this is changing. The Gants Hill AAP relates its housing policy to policies in the Borough Wide Primary Policies DPD by stating that the primary policy on density levels for new residential development (BD3) sets a housing density range for Gants Hill District Centre of 165-275 dwellings per hectare, which acknowledges the regeneration objectives for Gants Hill and the capacity within the district centre for additional housing. Other highlighted and relevant borough wide policies that would need to be considered for planning applications within the centre include:

• BD1 All Development; • BD2 Tall Buildings; and • GH4 Building Heights

3.18. The Gants Hill AAP housing policy (GH7) states that:

‘To promote the regeneration of Gants Hill and to contribute to the borough-wide target of 9,0504 new homes by 2017, the Council will seek to deliver a minimum of 800 new homes in Gants Hill District Centre. In pursuit of this, planning permission will be granted for residential schemes:

1. On the Opportunity Sites identified on Map 3; 2. Through the conversion of existing office premises in accordance with Policy: GH8 Use of Employment Land; 3. Elsewhere as part of mixed-use schemes with active ground floor retail or community use frontages.

3.19. In strategic terms the approach taken by the AAP is to increase the town centre population through additional housing and create a broadened customer base that can support new, major retail and other appropriate town centre services, thereby enabling a critical mass of investment and development capable of reinvigorating the district centre economy.

3.20. Land Use

3.21. In terms of land use the approach of the Gants Hill AAP is to be site specific about requiring the type of desired district centre uses that will achieve the objectives of the strategy, namely and chiefly, residential, retail, and commercial/business uses. Maps 6 and 7 in the AAP (below) show the potential uses for ground and upper floor areas within the district centre’s opportunity sites. The AAP is also very specific with regard to the optimum areas within the district centre where a new supermarket may be located, namely to the western section of the A12 Eastern Avenue on the south side of the road. In doing this the AAP is, to an extent, pre-empting any planning applications on these particular opportunity sites (A-E) by indicating before a proposal is made and an application is submitted that in principle supermarket is considered appropriate by the Council on any of the sites shown.

3.22. The AAP Policy GH5: Land Use states that:

‘The Council will grant planning permission for development which complies with the land use strategy for the Opportunity Sites shown on Map 6: Opportunity Sites – Ground Floor Land Uses and Map 7: Opportunity Sites – Upper Floor Land Uses. Elsewhere in the district centre, planning permission will be granted for mixed use development proposals which include active ground floor retail/commercial uses that address the street frontage.’

3.23. The aim of the policy is to help create a “passing parade” and add to the sense of human activity and vibrancy in the district centre and on the A12 Eastern Avenue to the west of the roundabout, essentially the aim is to create a new primary shopping frontage at sites A to E.

3.24. Building Heights

3.25. With regard to building heights in Gants Hill, the Gants Hill district centre area is shown on the LDF Proposals Map as an area where planning permission for tall buildings, usually considered over 30 metres, will be granted in accordance with criteria set out in LDF Policy BD2: Tall Buildings. The policy states that the height and siting of tall buildings will be established on the basis of their design qualities, transport accessibility and the character of development in the centre and the surrounding area. The policy also states that where suitable AAPs should identify key sites and provide guidance on building heights in the local area. In general tall buildings are expected to be of outstanding architectural quality, make a positive contribution to the skyline and the local setting and character of the area, and not have an adverse impact on local character.

3.26. The Gants Hill AAP Policy GH4: Building Heights relates directly to borough wide LDF Policy BD2 by stating that ‘…In the case of tall buildings (i.e. over 30 metres in height), excellent design quality

4 The current annual housing target for Redbridge is 760 units per annum. 14

is especially important and planning permission will only be granted for proposals which comply with the design criteria set out in Borough Wide Primary Policy BD2: Tall Buildings…’ However the policy goes further than just relating to LDF policy by setting local building height criteria of its own. Map 5 in the AAP (below) specifies areas within the district centre that are appropriate for tall buildings and other areas where heights are restricted to 3-5 storeys. Generally areas directly overlooking the roundabout and at the key shopping area of Cranbrook Road north and south are those areas where heights are restricted to 3-5 storeys. AAP Policy GH4 states that:

‘…in order to preserve an open and inviting environment in the most heavily pedestrianised areas within the district centre, the building height strategy is refined within this Area Action Plan to maintain relatively modest heights (3 storeys on street frontages rising to 5 storeys for set-back development) around the heart of the district centre and along Cranbrook Road North and South, where pedestrian use is at its greatest (see Policy GH3: Place Identity), while allowing greater heights towards the edge of the centre. This is consistent with the current distribution of taller buildings...’

3.27 GH8: Use of Employment Land

3.28. Office space in Gants Hill has proven difficult to rent over the previous two decades, and as stated in the preamble text of Chapter 8 Employment and Business of the Gants Hill AAP ‘…much of the office space is outdated and there are high vacancy rates…’ The text also states that ‘…the Mayor of London advised that “the London Office Policy Review indicates that there is no demand for large-scale office development in Gants Hill District Centre. If there is static and declining demand for offices, then a managed release for other uses, such as housing, should be considered”. 5.

3.29. In view of this the Gants Hill AAP contains a policy that relates to the conversion of vacant employment land to alternative uses – Policy GH8: Use of Employment Land states that:

‘The Council will grant planning permission for the conversion of existing offices to other uses, including housing, as part of mixed-use schemes with active ground floor retail or community use frontages.’

3.30. In the time since this the policy was initially drafted by the Council the former office block Citygate House on the east section of Eastern Avenue has come forward for conversion to residential use, but the prospects for office use in Gants have not improved. Other remaining office blocks at Wentworth House, Commercial House, and Montrose House, and the Vauxhall Showroom site have been designated as opportunity sites and earmarked for conversion or redevelopment to alternative uses, and make up a key part of the regeneration strategy at Gants Hill.

5 As an update to AAP evidence base the Mayor of London, London Office Policy Review for November 2009 states: ‘Redbridge exhibits many of the same characteristics as other east London boroughs – low demand and low supply. Although there is evidence of vacancy in Ilford, the quality of the stock is uninspiring. None of the other centres in the borough show any indication of having what it takes to become an office centre, nor to benefit from office-led regeneration.’ 15

Map 3: taken from Gants Hill Area Action Plan (AAP) (May 2009).

Map 4: taken from Gants Hill Area Action Plan (AAP) (May 2009).

4. Current and Preferred Land Uses

4.1. As stated above in section 2 the current uses on the opportunity sites C, D and E include office use (Commercial House and Montrose House; B1 use class), and a car sales show room (Sui Generis use class) (recently vacant). The office uses are located on sites C and D; site C also has a ground floor shop front for the Hein Gericke motorcycle company, with five floors of office space above; site D consists of a ground floor foyer area and a further five floors of office space above. The latest information on these sites received directly from the letting agents for these office buildings reveals that the office space in these buildings is currently almost fully let. However this does not preclude site assembly, or the re-provision of the existing office space within a new development scheme. Site E is the recently vacant car showroom site with a single storey building and most of the floor space previously taken up by new and used cars on display.

4.2. The preferred land uses for these sites include a mixture of retail, leisure and residential uses and although the AAP only specifies general appropriate uses for the sites C, D and E it does state in the justification text following Policy GH8 that ‘…any new scheme should include a mix of uses with active ground floor uses that address the street, in order to encourage a vibrant public realm…’ Such uses are likely include retail at the ground floor level, residential above, and other uses that might be typically found within active town centre primary shop fronts such as community uses, bowling alleys, gyms, eateries, business space etc. With regard to community uses the Council is committed to the retention of those that remain active and are of benefit to the local community. Referring to maps 6 and 7 in the AAP, preferred uses shown for the opportunity sites include retail, commercial/business uses, and residential uses on the floors above ground floor level.

4.3. However a key aim of the Gants Hill AAP in terms of future land use is to bring a new supermarket to the district centre on sites A to E, as part of a mixed use development scheme chiefly alongside residential use, in order to retain local spending being lost to other centres in the borough, and to capture new spending from many potential customers that simply pass through Gants Hill in their cars. Of sites A to E it is sites C, D and E that are most suited to this form of mixed use development scheme because of their proximity to Gants Hill Underground Station (Central Line) and the many bus routes that pass through the five arms of the roundabout; and because of their close proximity to each other, which makes assembling these sites easier. The Council is fully committed to the objective of obtaining a supermarket for Gants Hill that it has stated within the AAP that it is prepared to consider compulsory purchase key opportunity sites in order to secure this objective. A new supermarket in Gants Hill is one of the AAP’s key monitoring tasks, with the aim of:

• ‘Securing a developer for a supermarket within the District Centre and complete construction by early 2012; and • If a supermarket has not been completed within the District Centre by early 2012 or if prior to this date only one opportunity site remains potentially available and feasible (from Sites A-E), the Council will consider use of compulsory purchase order powers on the most suitable site at that point in time, by mid 2012. ‘

4.4. As stated housing is also a key aim of the Gants Hill AAP which has a minimum target of 800 new homes, in the district centre. This is partly to promote the regeneration of Gants Hill but also to contribute to the borough wide target for housing of 9,050 new homes by 2017, as set out in LDF Policy H1 Housing Provision6. Part of the strategy to achieve these targets in Gants

6 The Council’s difficulty in identify sufficient housing sites to meet the London Plan (Feb 2008) housing target (905 dwellings per annum) for a full 10 years prompted the Council’s Core Strategy review process. The London Plan (July 2011) sets a new housing target to deliver a 18

Hill is to encourage conversions of office blocks like Wentworth House, but an additional approach is to gain housing as part of mixed-use schemes with active ground floor retail frontages. Generally the overall aim in Gants Hill district centre is to seek to focus a wider range of services and promote diversification of uses, support the evening economy, and improve the local environment.

5. Development Parameters

5.1. Building Heights

5.2. The AAP identifies that tall buildings (of around 30m in height), are acceptable across much of the district centre at Gants Hill, however there are areas that front onto the roundabout where heights have been restricted to 3 to 5 storeys in order to preserve an open and inviting environment in the most heavily pedestrianised areas of the district centre and retain modest heights on street frontages around the heart of the district centre and along Cranbrook Road North and South, which is the primary shopping frontage and where pedestrian use is at its greatest. As stated the AAP outlines a height restriction of 3 to 5 storeys for buildings fronting the roundabout, (including the eastern end of the subject sites) and up to 10 storeys at the edge of centre areas, as illustrated by map 5 below.

5.3. This is effectively a more detailed expression of borough wide Policy BD2, which states that where appropriate Area Action Plans will identify key sites and provide detailed guidance on building heights. In the Gants Hill AAP specific areas within the town centre have been identified for modest heights and areas to the edge of the town centre have been established for tall buildings. The policy also states that planning permission will only be granted for proposals that comply with design criteria set out in LDF Policy BD2, namely that tall buildings should:

• Make a positive contribution to the skyline; • Not adversely affect views of importance; • Be of outstanding architectural quality; • Not impact adversely upon the setting and character of Conservation Areas, Listed Buildings (Statutory and Local), Residential Precincts, and historic parks and gardens; • Be sensitive to their impact on micro-climates in terms of wind, sun, reflection and overshadowing; • Take account of functional constraints including air navigation corridors, communication links (including television) and underground services and facilities; • Where appropriate, contain a mix of uses with public access, such as lower floor retail and leisure facilities with an active street frontage.

5.4. In relation to sites C, D and E; the scope for ten storeys is limited to the Eastern Avenue frontage away from the roundabout and this should include set back elements at upper levels and variations in height (i.e. with some lower elements). Development at Clarence Avenue should have a more subdued ‘domestic’ scale of between two to four storeys.

5.5. Density

5.6. There are no policies within the Gants Hill AAP that offer further area specific guidance on the issue of density as specific, clear density ranges for Gants Hill have already been set in the Borough Wide Primary Policies DPD in Policy BD3 Density in New Residential Development. Within the district centre a density level in the range of 165-275 units per hectare (450-700 habitable minimum of 760 new dwellings per annum in Redbridge over the period 2011 to 2021. The target is based on the London-wide Strategic Housing Land Availability Assessment (SHLAA) undertaken in 2009.

19 rooms per hectare) has been set, which is appropriate for the local PTAL of 5, and in accordance with London Plan Policy 3.4 ‘Optimising Housing Potential’. These are higher density ranges than other district centres within the borough as Gants Hill is recognised as an investment area with substantial capacity for additional housing, and an area that is very closely located to a key public transport hub. The intention at Gants Hill is to encourage development that will enable economic growth, and in order to achieve this new development needs to be built to an intensified level. Policy BD3 states that where new development complies with Policy BD1 ‘All Development’ planning permission will be granted for new residential development where it achieves densities applicable to its location within the borough. Development should be design- led rather than density driven.

Map 5: taken from Gants Hill Area Action Plan (AAP) (May 2009).

5.7. Amenity Space

5.8. The Gants Hill AAP does not provide direct policy guidance for the provision of amenity space for new development as the LDF already provides adequate policy direction in the form of Policy BD4 Amenity Space in New Residential Development which requires that new development provide 20sqm of amenity space per habitable room, except where flatted development is provided with a balcony in excess of 4sqm, in which case the amenity space requirement is reduced to 15sqm per habitable room. However BD4 also states that in town centres new or converted dwellings may be permitted without amenity space if they are non family units. Evidence shows that about 25% of two bedroom units are lived in by families with children and should be defined as family units. Equally, 75% are not. Within town centres, 25% of two bedroom units will be regarded as family units, and amenity space should therefore be provided pro rata for those units, and provided communally to reflect the fact that families may occur at random within the housing available. The Council’s supplementary planning guidance Amenity Space and Residential Development (2005) provides further guidance of amenity space requirements

5.9. Balconies and other amenity space shall be arranged to benefit from sunlight and good micro climate. It should not be unduly overshadowed or overlooked. Space should be allowed for sitting out and a variety of other activities. Appropriate high quality amenity space could take the form of winter gardens, loggia and amenity decks.

5.10. Car Parking and Access

5.11. Policy T5 Parking Standards sets parking standards across the borough and states that car parking will be sought in accordance with the maximum standards set out in Schedule 3 of the Borough Wide Primary Policies DPD, and for Gants Hill district centre where new development is likely to take the form of major mixed use schemes the principles and standards within the policy are likely to be applied in several forms in order to cover several different types of uses. In the case of sites C, D and E those uses are likely to predominantly be residential and retail, but there may also be other use classes incorporated into mixed use schemes, such as community uses, financial and professional uses, or residential institutions. Green travel plans and traffic impact assessments will be required with proposals for mixed use schemes that entail traffic implications for the local network. The following [relevant] parking standards are set out in Schedule 3 of the Borough Wide Primary Policies DPD. They provide a starting point for determining maximum parking standards, taking account of local circumstances:

Use Description Car Spaces (Maximum) Cycles Spaces A1 Shops Smaller food store (up to 1 space per 35m² gross 2 stands plus 1 per 350m² 500m² gross floor area) floor area gross floor area Food supermarket 1 space per 20 sq. metres 2 stands plus 1 per 350sq. (up to 2500 sq. metres gross floor area metres gross floor area retail floor area/4000 sq. metres gross floor area Food superstore 1 space per 18 sq. metres 2 stands plus 1 per 350sq. (over 2500sq. metres gross floor area metres gross floor area retail floor area / 4000sq. metres gross floor area) Non food retail 1 space per 22 sq. metres 2 stands plus 1 per 500 warehouse gross floor area sq. metres gross floor area Town centre / shopping 1 space per 20 sq. metres 2 stands plus 1 per 350 mall gross floor area sq. metres gross floor area A3 – A5 Restaurants & Cafes Treat each application on 1 stand per 20 staff plus 1 Food & Drink its merits stand per 10 seats for 22

visitors Drinking Establishments Treat each application on 2 stands plus 1 per 100 its merits sq. metres gross floor area Use Description Car Spaces Cycles Spaces A3 – A5 Hot Food Takeaways Treat each application on 2 stands plus 1 per 50 sq. Food & Drink its merits metres gross floor area

Drive-through or Treat each application on 1 stand per 20 staff plus 1 takeaways without its merits stand per 10 seats for seating visitors

Food & Drink on mixed- Treat each application on stand per 20 staff plus 1 use sites its merits stand per 10 seats for visitors C3 Predominant housing 1 stand per unit Dwelling houses type (In all C3 dwelling cases, 4+ bed units 2-1.5 spaces per unit 1 stand per unit when a garage is to be 3 bed units 1.5-1 space per unit 1 stand per unit built, space in front large 1-2 bed units 1 to less than 1 per unit 1 stand per unit enough to station a vehicle clear of the public highway shall be provided where possible. Such space counts as a parking space).

Table 1: Local Development Framework (LDF) Car Parking Standards. Regard should also be given to the applicable car parking standards outlined in the ‘Parking Addendum to Chapter 6 of the London Plan (2011).

5.12. Basement car parking is the optimum solution in high density development, it may be precluded here by the shallow depth of the underground tube network. Multi-storey, decked or undercroft car parking could be practical alternatives in this instance, but must not undermine the requirement for active frontage to adjoining streets. Surface car parking is usually intrusive and an inefficient use of land that is unlikely to be supported in this instance, unless placed beneath an elevated building and hidden from public view by active frontages.

5.13. Sustainable Design and Construction

5.14. Under the Council’s development plan (which includes the London Plan), new development is required to comply with the Mayor of London’s Energy Hierarchy, namely:

a. be lean: using less energy, in particular by adopting sustainable design and construction measures; b. be clean: supplying energy efficiently, in particular by prioritising decentralized energy generation, and c. be green: using renewable energy.

5.15. Redevelopment on sites C, D and E will therefore need to meet the following standards as a minimum:

Sustainability requirements for new developments

a. for residential development: Code for Sustainable Homes ‘Level 4’ (as per the Council’s Sustainable Design and Construction Supplementary Planning Guidance Jan 2012); b. for non-residential development: Building Research Establishment Environmental Assessment Method (BREEAM) ‘Excellent’ rating (as per the Council’s Sustainable Design and Construction Supplementary Planning Guidance Jan 2012), and

Energy and reducing carbon emissions

(1) Residential (a) From 2012, 25 per cent improvement on 2010 Building Regulations, Part L (equivalent to Code Level 4 for energy). This is just for regulated emissions. (b) 2013 - 20167, 40 per cent improvement on 2010 Building Regulations, Part L. This is just for regulated emissions. (c) 2016 - 20318, zero carbon development.

(2) Non-residential (a) From 2012, 25 per cent improvement on 2010 Building Regulations, Part L. This is just for regulated emissions. (b) 2013 - 20169, 40 per cent improvement on 2010 Building Regulations, Part L. This is just for regulated emissions. (c) From 2016 - 201910, as per Building Regulation requirements. (d) From 2019 - 203111, zero carbon development.

5.16. The size of the site, its location, and potential uses presents a number of opportunities for sustainable design and construction approaches which the Council would expect to be incorporated, including:

a. Orientation of new buildings on the site to reduce solar gain in summer and increase it during winter. b. Passive ventilation to reduce the need for air conditioning. c. Construction materials with high insulation values and construction methods to maximise air tightness within the building. d. Innovative approaches to insulation, such as green roofs. e. Water cycle measures, such as water efficiency devices and on-site sustainable urban drainage measures (i.e. water butts, permeable surfaces, soak-aways). f. De-centralised energy, including a communal heat and power (CHP) system. g. A range of renewable energy sources, including solar hot water, photovoltaic (i.e. electricity from the sun), and air source heat pumps. h. Promotion of sustainable transport options, including cycle parking bays and car-club spaces.

5.17. The Council will require that sustainability measures are proven, reliable, appropriate to the site and the proposed use, and make a meaningful contribution to the reduction of carbon dioxide emissions and sustainability outcomes.

7 The start date for this will be when the proposed 2013 amendments to Part L of the Building Regulations come into effect. 8 The start date for this will be consistent with the Government’s zero carbon agenda. 9 The start date for this will be this will be when the proposed 2013 amendments to Part L of the Building Regulations come into effect. 10 The start date for this will be when the proposed 2016 amendments to Part L of the Building Regulations come into effect. 11 The start date for this will be consistent with the Government’s zero carbon agenda. 24

5.16. Internal Space Requirements

5.17. To ensure that dwellings have adequate internal space to make them functional and sustainable the Council will have regard to Policy 3.5 Quality and Design of Housing Developments in the Mayor of London’s London Plan (July 2011), and the Housing Supplementary Planning Guidance (SPG) published November 2012, which has introduced minimum dwelling space standards for the region at Annex 1 Summary of the quality and design standards. Local Plans should generally conform to this new SPG and boroughs should seek to ensure that new development reflects the design standards set out in the annex. These are minimum standards which developers are encouraged to exceed. The table below outlines the internal space standards in the new guidance.

Dwelling type Essential GIA (sq.m) (bedroom/ persons) Flats 1p 37 1b2p 50 2b3p 61 2b4p 70 3b4p 74 3b5p 86 3b6p 95 4b5p 90 4b6p 99 Two Storey Houses 2b4p 83 3b5p 96 4b5p 100 4b6p 107 Three Storey Houses 3b5p 102 4b5p 106 4b6p 113 For dwellings designed for more than 6 people, at least 10sq.m gross internal area should be added for each additional person.

Table 2: Internal Space Standards from the Mayor of London’s Housing Supplementary Planning Guidance, Nov. 2012. The guidance also states that ‘…developments should avoid single aspect dwellings that are north facing, exposed to noise levels above which significant adverse effects on health and quality of life occur, or contain three or more bedrooms…’

5.18. Active Frontage and Articulation

5.19 Development shall animate adjoining streets with frequent building entrances, shop displays and large window openings, large building elements shall be broken down into smaller modules and human scale elements, and articulated with elements set forward and back to create lively and visually rich elevations.

5.20. Flooding

5.21. Gants Hill has not been designated as an area at risk of flooding and has been given no flood zone designation, but sites C, D and E are in fact close to the following flood zones:

2: Medium Probability – Rivers: between 1% (1 in 100 years) and 0.1% (1 in 1000 years) 3a: High Probability – Rivers: greater than 1% 1 in 100 years) 3b: Functional Flood Plain – Greater than 5% (1 in 20 years)

Flood risk levels 2 and 3a apply to sites C and D, with the highest risk of 3b in the surrounding area to the south of but not on the sites. The sites are considered potentially vulnerable to surface water flooding and flood risk can be managed through effective flood attenuation measures, allowing necessary development to occur. Sustainable drainage systems, including both attenuation and infiltration options, will need to be promoted where there is new development.

5.22. Planning Obligations and Community Infrastructure Levy (CIL)

5.23. The Council’s Local Development Framework (specifically Strategic Policy 12: Planning Obligations) requires developers to make appropriate contributions to offset the cost of providing new physical and social infrastructure required as a result of their proposals either by way of financial contributions, or direct provision of such infrastructure within larger developments.

5.24. The Council has adopted a new Community Infrastructure Levy (CIL). The Community Infrastructure Levy (CIL) (as set out in the Planning Act 2008) is a new system of developer contributions and is intended to supplement other public sector funding streams to ensure that new community infrastructure (such as schools and health care facilities) can be provided to keep pace with population growth. CIL is set locally and is a standard charge of £70 per square metre (excluding the Mayor’s CIL charge of £35 per m², which is added to the Council’s charge for an overall charge of £105 per m²) applied to all developments, with the exception of social housing, buildings used by charities and buildings into which people do not normally go, or go only for routine maintenance of plant or equipment, which remains subject to S106 contributions. The charge is imposed at the time planning permission is granted and paid at the commencement of development. The charge is indexed annually.

5.25. CIL replaces Section 106 contributions for general types of community infrastructure, however Section 106 will still be used for site specific mitigation measures that are required to make a development acceptable (such as a new access road) as well as for affordable housing provision. CIL is paid according to a Charging Schedule prepared by the Council (the Charging Authority).

5.26 Transport Impact and Access

5.27. With regard to the potential impact that new development could have on the road network surrounding sites C, D and E and any future access arrangements and constraints that new development could face, Council Officers informally consulted with Development Planners in the Surface Transport unit at Transport for London (TfL). TfL is the highway authority for the Transport for London Road Network (TLRN) which includes the A12 Eastern Avenue, is also responsible for the subways beneath the roundabout as part of its highway responsibilities, for all signals across London, and for London Buses, including the bus stop outside sites C, D and E, which are TfL’s responsibility.

5.28. The comments made by TfL Officers during this informal consultation primarily focused on highways aspects, and represent TfL Officer’s views, which should not be taken to represent an indication of any subsequent Mayoral decision in relation to a planning application based on a 26

proposed scheme. These comments also do not necessarily represent the views of the Greater London Authority (GLA).

5.29. The following comments are offered as general advice, may not be exhaustive and may need to be revised in light of further information provided by an applicant. They are intended to identify issues of relevance to the development of sites C, D and E:

Car and cycle parking levels should be in line with London Plan standards (including electric charging points, car club spaces, disabled users) – as the area has a good accessibility to public transport – reducing overall car parking provision is encouraged – taking account of current car parking provision within the AAP area. Cycle parking standards are minimum level and TfL support measures that encourage and promote cycling.

All vehicle activity associated with the site should be accommodated on site and away from the TLRN. TfL have concerns about overspill impact on the A12 and the bus stop if vehicular activity is not actively managed.

TfL are also concerned about the relative impact at the Gants Hill Roundabout –and consider they may need to review signal timings/line markings in relation to any new development, although they are unlikely to wish to amend its operation significantly – and they also wish to understand changes in individual movements from the development rather than the overall traffic impact.

TfL would also need to see a profile of trip generation over a typical day and at the weekend before agreeing assessment periods, and would seek to look at the relationship between highway peaks and development peaks.

It maybe also necessary to update and extend the Gants Hill Roundabout traffic models to include the A12/Beehive Lane junction (plus other junctions the Borough may suggest).

The creation of a new access point onto the A12 is not ruled out, though there are limits:

a. TfL’s prime concern is traffic capacity and road safety; as well as the desire to encourage walking, cycling and bus use. The developer will need to demonstrate an overall benefit to all highway users. b. A direct access from Site E to the A12 is unlikely to be supported due to proximity to the roundabout and existing bus stop. c. A single access point from site C or D that serves site C, D and E is preferred. If the existing Site B/Burger King access could be incorporated into single access arrangement that would be a favoured alternative. d. The location of the existing westbound bus stop should be regarded as fixed. Therefore, any proposed access points would need to be west of this stop. e. Left in/left out only - access proposal that involves breaking the central reserve are unlikely to be supported by TfL. Though an Origin-Destination assessment (for large vehicles and general traffic) will be needed as would a routing strategy. f. Any proposal that adds additional signals would not be supported at this location. g. A deceleration lane is likely to be needed taking account of guidance in the Design Manual for Roads and Bridges and will require a Road Safety Audit before TfL approves the design in principle. h. TfL also recommend Manual for Streets 1 (residential areas) and 2 (town centres) inform the design process. i. Treatment of the urban realm fronting the site should form part of the development proposals and be in line with the following guidance: TfL Streetscape Guidance

27 Bus Stop Accessibility Guidance London Cycling Design Standards

j. Any physical works on the TLRN would require an agreement with TfL under Section 278 of the Highways Act 1980 and would be at the developer’s expense.

. Residential development may need a separate vehicular access point from Clarence Avenue.

Vehicular servicing requirements should be catered for on site without stopping on the A12. Any heavy goods vehicles (including refuse vehicles) should leave and enter the A12 in forward gear.

The overall aim should be to manage vehicle activity on site to minimise impact on the A12 during peak times (including employees, service vehicles, and residents).

Public Realm improvements could include a continuation of footway design and materials used at Gants Hill, as intended by London Borough of Redbridge. This would benefit the active shop frontages proposed on the A12. Improvements on the southern A12 footway should be extend as far as Beehive Lane as each site comes forward.

TfL may request s106 contributions to wider urban realm measures such as Legible London signage to encourage walking and cycling to site.

Safeguarding existing and planting additional trees on the TLRN should be a consideration for part of the public realm measures where appropriate in consultation with TfL’s Arboriculture & Landscape Route Manager.

Construction activity needs to be managed to minimise impact on the TLRN. There will be a need to agree a Construction Logistics Plan and temporary arrangements during construction.

5.30. Loss of Community Facilities

5.31 With regard to existing community facilities on sites C, D and E, Council LDF Policy C1 Existing Community Facilities’ commits the Council to the protection of such facilities. Planning permission for a change of use that involves the loss of community facilities will only be granted where the applicant can demonstrate that there is no longer a need for that facility and where there are similar such facilities nearby. The last sentence here could be translated to a nearby relocation of facilities or the inclusion of exisiting facilities within the new proposed development scheme, both options would maintain the status quo with regard to local community facility provision

6. Preferred Development

6.1. Mixed Use Redevelopment

6.2. The preferred development for sites C, D and E is that of a major mixed use development scheme that includes a supermarket appropriate in scale to a district centre (2,500sqm of trading floor space with car parking), and incorporating land uses that are appropriate and prevalent in town/district centre primary shopping areas that will create an active retail frontage on the main road at Eastern Avenue (west). Such land uses may include:

• Ground floor; o Retail; o Evening economy uses; 28 o Community Use; o Leisure; o Other uses that contribute to an active street frontage; • Upper floors o Residential use o Leisure uses (including a bowling alley)

6.3. It is anticipated that an assembled site could accommodate around 133 residential units in addition to ground floor complementary uses. This estimate of capacity is set within the adopted Gants Hill AAP. (C= 37 Units, D=35 Units, E= 61 Units). Overall residential capacity may be lower if sites are not combined as suggested.

6.4. As well as these land uses the Council is also seeking to encourage developers to create green links towards Valentines Park within the centre, development which improves access to Valentines Park will be supported and measures to enhance landscaping on approach streets to Valentines Park will be welcome. The Council will also require through planning obligations any supermarket located outside the key high street corridor at Cranbrook Road north and south to provide an improved public realm and pedestrian/cycle connections to the high street corridor. The scheme can be developed to a medium scale, with heights of 3 to 5 storeys overlooking Gants Hill roundabout, stepping up to around 8 storeys as the scheme progresses along Eastern Avenue towards the western edge of the centre. The design of the scheme is expected to be of a high architectural standard in order to create landmark buildings in key locations of the centre that improve its overall character.

6.5. Retail and residential uses are essential to the establish a strong, viable economy in Gants Hill as a virtuous economic circle can be created through additional capacity within the centre for these land uses. Providing for community uses and social infrastructure is also critical to building a strong, sustainable community in Gants Hill District Centre.

7. Proposed Development

7.1. With regard to the approach to the development of sites C, D and E specific considerations need to be borne in mind in order for the sites to come forward for redevelopment in the manner desired by the Council. These considerations include:

• Site assembly; • The mix of uses; • The height and scale of the new development; • Design standards – landmark and outstanding; • Improved pedestrian friendly streetscape; • Parking issues - access and egress for new development on the sites; • Sustainable development; • Density & amenity space.

7.2. Sites C, D and E are separate sites as described above and they each have different owners. In order for the objective of a major, mixed use scheme incorporating a supermarket and residential use to come forward it is very likely that sites C, D and E will need to be assembled by the developer as it is unlikely the outcomes sought by the AAP for this part of Gants Hill could be achieved on one site only. The diagram below shows landownership for major opportunity sites within the centre, and for sites C, D and E there are currently three freehold landowners:

• Forest Gate Property Management – part of site C; • General Motors Acceptance Corporation (UK) Plc – part of site C (car park area) and site E12; • Tareem Limited – site D

7.3. Creating a single, large site within the town centre is essential to bringing about the desired outcomes outlined in the Gants Hill AAP and achieving the overall regeneration of the area. Working with landowners to acquire the sites is an essential part of the process for any developer seeking to bring the scheme to fruition. Site assembly also calls for pro-active assistance from the Council in assembling a suitable site. The AAP helps by being as specific as possible with regard to where the desired uses are most appropriate in the district centre.

7.4. in terms of the mix of uses as stated above in section 6 of the brief the aim is to achieve a scheme that incorporates a mix of uses that are appropriate and prevalent in town/district centre primary shopping areas that will create an active retail frontage on the main road at Eastern Avenue (west). One of the key aims of the Gants Hill Area Action Plan (AAP) is to establish a supermarket on the sites with a trading floor space of 2,500sqm, and with car parking. As part of the overall scheme and mix of uses residential use is another key objective for the sites, built above ground floor level as flats as part of an approach towards an intensified use of the land.

7.5. The Council considers the aim of establishing a supermarket, as part of an intensified, mixed use development scheme in order to help anchor the local Gants Hill economy, as crucial to the overall strategy of the AAP. The Gants Hill AAP is based on a strong and sound evidence base, backed up by two retail studies, neither of which has demonstrated that the aim of pursuing the establishment of additional retail in Gants Hill, in the form of a major new supermarket, should not be continued.

7.6. Whilst there is some flexibility within AAP Policy with regards to alternative approaches to establishing additional retail within the centre (for example, the form and location of such provision), the Council will only depart from the key principles and aims of the AAP strategy where there is sufficient, conclusive evidence that any key objective(s) of the AAP, such as establishing a supermarket within the centre, are not achievable or can be achieved elsewhere within the centre. It will be incumbent upon the developer to provide the Council with such evidence, in the absence of which the Council is unlikely to substantially shift from its key aims with regards to regeneration in Gants Hill District Centre and the provision of a major new supermarket.

7.7. Should a proposal come forward for any or all of the sites covered by this brief that does not include a supermarket, the Council would expect such a proposal to be supported by evidence that:

1. the majority of the top supermarket operators are not interested in the site (either on its own or as part of a larger site); 2. no other potential supermarket operators are likely to be interested in the site generally (either on its own or as part of a larger site); 3. it is not possible to assemble a sufficient large site for a supermarket; 4. the site by itself is not practically suitable for a supermarket (access, car parking, constructability); 5. other sites along Eastern Avenue are potentially suitable for a supermarket 6. the proposed development will provide an active frontage to the full frontage of the site to Eastern Avenue and make a positive contribution to the overall viability of the Centre

12 Site E has very recently been acquired by Fairview Homes 30

7. the proposed development will not prejudice the provision of a supermarket on other sites along Eastern Avenue, nor impact upon the ability for the adjoining sites to be brought forward for development in a comprehensive manner 8. the proposal is able to comply with the relevant development standards (housing mix, amenity space, affordable housing etc)

7.6. The height and scale of the new development scheme has been alluded to previously in the brief and has been given good guidance in the AAP for Gants Hill. Essentially areas of the town centre that directly overlook the roundabout are subject to restrictions in height that keep new structures to a relatively modest scale of 3 storeys on street frontages rising to 5 storeys as the building steps back, and rising further to around 8-10 storeys as buildings step towards the edge of the centre. The reasoning behind this is so that an open and inviting environment in the most heavily pedestrianised areas is maintained. Blocks along Eastern Avenue should be modulated and articulated to create a series of related and visually stimulating buildings. Building scale should be limited (two to four storeys) along Clarence Avenue and adjacent to existing residential property. Excellent design quality is especially important and planning permission will only be granted for proposals which comply with the design criteria set out in Borough Wide Primary Policy BD2: Tall Buildings.

7.7. With regard to design standards the Council’s objective is to achieve landmark buildings of outstanding quality for the district centre, which is particularly important for tall buildings as they have a greater visual impact on the surroundings. As part of the redevelopment of the district centre the development of sites C, D and E would need to be accompanied by a package of public realm improvements to create greater and better access and a pedestrian friendly streetscape for the higher volume of shoppers/pedestrian that are likely to be attracted.

7.8. Adequate parking standards are essential for a mixed use scheme on sites C, D and E if a viable supermarket with a wide catchment is to be achieved. In seeking to achieve a supermarket on the sites the Council is aware that such uses need good parking and vehicular access arrangements in order to remain commercially viable. As stated previously in the brief parking standards within LDF Policy T5 will be applied, which for a supermarket with up to 2,500m² retail floor area/4,000m² gross floor area a standard of 1 space per 20m² gross floor area will be applied. However as Gants Hill is a town centre destination with a high PTAL there is also scope for reduced parking provision. The impact of parking provision for the new development on the local network and efficient, workable access arrangements to and from the developed sites is also an issue of high priority demanding a workable resolution to the satisfaction of Transport for London (TfL), the developer, the local community and the Council. Whilst these issues are not insurmountable they do represent particular constraints that must be overcome in a practical and sustainable manner, and have previously been clearly highlighted at paragraph 5.25 above.

7.9. Design Guidance Plans 1 and 2 below illustrate the principles behind the notional design concept outlined above.

Design Guidance Plan 1: Showing notional design concept 32

Design Guidance Plan 2: Showing principles behind notional design concept 33

Landowners 1. Kenview Limited 2. Big Yellow Storage Company 2 Limited 3. Gumley Properties Limited 4. Forest Gate Property Management 5. General Motors Acceptance Corporation (UK) Plc 6. Tareem Limited 7. Tareem Limited 8. General Motors Acceptance Corporation (UK)

Map 6: Showing land ownership for opportunity sites in Gants34 Hill

APPENDIX 1

Key Core Strategy Policies

Strategic Policy 1 - Overall Growth:

Growth will be harnessed to help achieve the Council’s vision, by focussing new development upon the hierarchy of town centres…in the District Centres of Barkingside, Gants Hill, South Woodford and Wanstead some new development will be permitted including housing, retail, office and other commercial, culture, health, leisure and community facilities. New development will be expected to improve and enhance the public realm.

Strategic Policy 4 - Retail:

Retail provision in the hierarchy of centres identified in Strategic Policy 1 will be achieved by:

• Granting planning permission for an additional 23,000sqm core retail floor space in Ilford Town Centre; • Permitting some new floorspace and protecting the viability and vitality of District and Local Centres; and by • Allowing for a range of service and retailing facilities sufficient to serve the local needs of residential areas.’

Strategic Policy 5 - Employment:

Employment provision will be achieved by Consolidating most commercial activities within the hierarchy of town centres and around public transport nodes as provided for in Strategic Policy 1.

Strategic Policy 7 - Housing:

A minimum of 9,050 quality dwellings shall be delivered to meet the varying requirements of all residents of the Borough between 2007/08 and 2016/17 by locating these new dwellings in accordance with the hierarchy set out in Strategic Policy 1 as follows: 35% to 50% within Ilford Metropolitan Centre, 15% to 25% in the District and Local Centres; and a further 25% to 35% throughout the rest of the borough.

Strategic Policy 8 - Affordable Housing:

• The Council has a strategic borough-wide target that between 2007 and 2017 50% of new housing from all sources should be affordable. • As part of this target, an element of affordable housing will be sought to meet local needs on all suitable housing developments capable of accommodating 10 or more dwellings or residential sites of 0.5ha or more irrespective of the number of dwellings. • On these sites the Council will negotiate to achieve an affordable housing provision of 50% across the range of housing

Strategic Policy 8 encompasses social housing and intermediate housing. Social housing is subsidised housing provided as secure or assured tenancies, with access on the basis of need. Intermediate housing comprises low cost market housing, shared equity schemes, discounted home ownership, or secure or assured tenancies.

Key Borough Wide Primary Policies

Policy R1 – Sustainable Centre:

Within the shopping centres listed in Schedule 4, providing the proposal is appropriate to the scale, character and function of the centre, planning permission will be granted for proposals which contribute towards an appropriate mix of uses. In particular:

• In the Local Centres, Key Retail Parades and Retail Parks and in the primary shopping area of the Metropolitan and District Centres (as identified on the Proposals Map), the Council seeks to protect the predominantly retail function at ground floor level and additional retail use will be granted. Change of use away from A1 retail within these areas will be required to comply with Policy R3. • In the secondary areas of the Metropolitan and District centres (as identified on the Proposals Map), a range of new development including, housing, retail, office and commercial, culture, leisure and community facilities will be granted provided it complies with criteria 2 –10 of Policy R3.’

Policy R2 – New Shopping Development:

Planning permission will be granted for new retail development within the Metropolitan, District and Local Centres as identified at Schedule 4.

Policy BD1 – All Development:

Proposals for all forms of development must incorporate high quality sustainable construction techniques reflecting the Council’s Supplementary Planning Guidance on Urban Design (September 2004) and Sustainable Design and Construction (May 2005).

Policy - BD2 Tall Buildings:

Planning permission for tall buildings, usually considered as over 30 metres, will be granted in Ilford Town Centre to reinforce its role as a Metropolitan Centre and an Opportunity Area. The Ilford Town Centre Area Action Plan identifies key sites and provides detailed guidance on building heights

Policy T1 – Sustainable Transport:

New development will only be granted planning permission where it incorporates measures that demonstrate a reduced reliance on private vehicles. Planning permission will not be granted for development, which would increase trip generation excessively so as to result in an adverse impact on traffic congestion within the local and strategic road network (including motorways) or public transport system. For all major developments a Green Travel Plan will be required to accompany the planning application.

Policy T5 – Parking Standards:

Car parking will be sought in accordance with the maximum standards set out in Schedule 3. [of the BWPPP DPD]. Proposals should also make provision for motorcycle parking.

Policy H1 – Housing Provision:

The Council will provide a minimum target of 9,050 new dwellings in Redbridge in the period 2007 to 2017, through key LDF Development Plan Documents (DPD) such as the ‘Housing Capacity’ DPD, and other DPDs such as Area Action Plans (AAP), as well as town centre opportunity sites, major developed sites, infill development, and through encouraging efficient use of the existing stock by seeking a reduction in the number of vacant, unfit and unsatisfactory dwellings.

Policy BD1 – All Development:

• Be compatible with and contribute to the distinctive character and amenity of the area in which it is located. • Be of a building style, massing, scale, density and design appropriate to the locality. • Realise the potential of the land. • Contribute to local architecture and design quality. • Protect or enhance the effects on valuable habitats and species. • Ensure that landscaping is an integral element in layout design, taking account of existing physical features (e.g. trees, hedgerows, walls, etc). Where appropriate, trees and shrubs should augment the amenity and appearance of the site. • Not prejudice the amenity of neighbouring occupiers by unreasonably restricting sunlight, daylight or privacy to their properties. • Create safe and secure environments and reduce the scope for fear and crime by taking into account the Police Service’s “Secure by Design” Standards. • Be designed to meet the needs of all and include provision for disabled access to, and within public areas. • Include appropriate provision for the storage and collection of waste and recyclable material. • Demonstrate that there is no significant adverse impact on surrounding uses in terms air, water, noise pollution, and of fume and smell nuisance. • Where appropriate provide evidence that there is capacity in utility infrastructure.

Policy BD3 – Density in New Residential Development:

In complying with Policy BD1, planning permission will be granted for new residential development where it achieves the following densities: • In Ilford Metropolitan Centre: 240- 435 units per ha (650-1100 habitable rooms per ha). • In the Gants Hill District Centre: 165-275 units per ha (450-700 habitable rooms per ha). • In the Barkingside, South Woodford and Wanstead District Centres: 80-120 units per ha (250- 350 habitable rooms per ha). • In areas close to the Metropolitan and District Centres (listed in Schedule 4) and along main roads, residential and mixed-use densities should range from 30-65 units per ha (150-200 habitable rooms per ha) for detached and linked houses, to 50-80 units per ha (200-250 habitable rooms per ha) for terraced houses and flats and where it is mostly flats, from 80-120 units per hectare (250-350 habitable rooms per ha). • In the established residential areas not covered above, a residential density in the range of 30-50 units per ha (150-200 habitable rooms per ha).

Policy BD4 – Amenity Space in New Residential Development:

The Council will grant planning permission where new development provides amenity space in accordance with the following minimum standards: • New converted or extended residential development – 20 sq. metres amenity space per habitable room. • Sheltered housing – 12 sq. metres amenity space per habitable room. • Residential institutions – 6 sq. metres amenity space per resident. • Residential development of flats – When a habitable flat is provided with balcony in excess of 4 sq. metres, then the amenity space requirement for that room shall be reduced to 15 sq. metres. In all cases, amenity space in new residential development should: • Be compatible with the prevailing pattern in the surrounding area. • Be of a usable and practical configuration. • Be of an appropriate scale to ensure usability. • Be ‘fit for purpose’ in terms of the particular building it serves. • Incorporate high quality landscaping. • Achieve freedom from overlooking, and privacy, between the rooms of one house and those of another. • Where open space is provided for flatted development and sheltered housing, the needs of the likely occupants of the dwellings and the character of the surroundings should be taken into account • Result in an acceptable relationship between buildings.

The Council will calculate amenity space by excluding areas used for parking (such as driveways) and buffer strips less than 1.5 metres wide. The Supplementary Planning Guidance on Amenity Space and Residential Development (October 2005) sets out further guidance on amenity space in new residential development.

Policy C2 – Access to Community Facilities:

The Council will promote access to community facilities by granting planning permission where Major development proposals include community facilities as an integral part of the development. Planning permission will only be granted for development which imposes additional demand on community facilities, where that demand can be met by current provision or where it can be offset by contributions towards the provision of new or enhanced facilities. Guidance is set out in the Planning Obligation Strategy Supplementary Planning Document (June 2006).

APPENDIX 2

Key Gants Hill Area Action Plan Policies

The Gants Hill Area Action Plan (AAP) responds to strategic Core Strategy and Borough Wide Policies with its own set of policies that dovetail with the Council’s overall strategic planning objectives. These policies are outlined below.

Policy GH4: Building Heights Planning permission will be granted for development which complies with the building heights shown on Map 5: Building Heights. In the case of tall buildings (i.e. over 30 metres in height), excellent design quality is especially important and planning permission will only be granted for proposals which comply with the design criteria set out in Borough Wide Primary Policy BD2: Tall Buildings.

The majority of the district centre is included as an area for tall buildings under Policy BD2: Tall Buildings in the Borough Wide Primary Policies Development Plan Document, in recognition of the centre’s good public transport accessibility and the presence of a number of existing tall buildings within the centre.

However, in order to preserve an open and inviting environment in the most heavily pedestrianised areas within the district centre, the building height strategy is refined within the Area Action Plan to maintain relatively modest heights (3 storeys on street frontages rising to 5 storeys for set-back development) around the heart of the district centre and along Cranbrook Road North and South, where pedestrian use is at its greatest while allowing greater heights towards the edge of the centre. This is consistent with the current distribution of taller buildings.

Policy GH5: Land Use The Council will grant planning permission for development which complies with the land use strategy for the Opportunity Sites shown on Map 6: Opportunity Sites – Ground Floor Land Uses and Map 7: Opportunity Sites – Upper Floor Land Uses. Elsewhere in the district centre, planning permission will be granted for mixed use development proposals which include active ground floor retail/commercial uses that address the street frontage.

The Opportunity Sites shown on Map 6: Opportunity Sites – Ground Floor Land Uses and Map 7: Opportunity Sites – Upper Floor Land Uses were identified through the Gants Hill Area Action Plan Supporting Studies document. The sites are considered to have significant redevelopment potential for housing or mixed-use development during the lifetime of this plan. The area on the southern side of Eastern Avenue, to the west of the roundabout is also considered appropriate for the provision of a supermarket (refer to Policy GH6: Expanded Retailing).

Policy GH6 - Expanded Retailing: The Council will grant planning permission for development which broadens the retail offer within Gants Hill. In particular, planning permission will be granted for: 1. A supermarket appropriate in scale to a district centre and providing for more than the local catchment. Opportunity Sites A-E along Eastern Avenue (on Map 3: Opportunity Sites) (either individually or combined) would be suitable locations. 2. Other convenience retail within the District Centre. 3. Retail uses within the subway system. 4. Ground-floor retail uses within mixed-use developments. 39

The retail offer in Gants Hill is relatively modest and is distributed among the five main streets leading into the central roundabout. In general, Gants Hill has a small customer base within its catchment area due to a lack of passing trade stopping off within the centre. The nearest competing centres – Ilford and Barkingside – have a more extensive retail offer and are only a short distance away.

Of all the district centres in Redbridge, Gants Hill has the lowest proportion of A1 uses (shops) providing comparison and convenience goods. Unlike the other centres there are no major food stores or multiple comparison retailers to anchor a customer base. The retail Policy GH6 within the AAP has been formulated to encourage an expansion of retail within the district centre.

Policy GH7: Housing To promote the regeneration of Gants Hill and to contribute to the borough-wide target of 9,050 new homes by 2017, the Council will seek to deliver a minimum of 800 new homes in Gants Hill District Centre. In pursuit of this, planning permission will be granted for residential schemes: 1. On the Opportunity Sites identified on Map 3. 2.Through the conversion of existing office premises in accordance with Policy: GH8 Use of Employment Land. 3. Elsewhere as part of mixed-use schemes with active ground floor retail or community use . frontages

The borough target for housing provision is set at 7,600 new homes in the period to 2011 - 2021 and the metropolitan and district centres are ear-marked to provide between 15% and 25% of this figure. Gants Hill District Centre currently has a very small residential population, housed mainly in units above shops.

The important consideration in selecting sites for new housing should be the extent to which development is easily accessible and connected to public transport and community facilities. The relatively low density of the district centre, combined with its good public transport access and links to central London, make it an ideal location for new housing.

Policy GH8 - Use of Employment Land: The Council will grant planning permission for the conversion of existing offices to other uses, including housing, as part of mixed-use schemes with active ground floor retail or community use frontages. There is little demand for office space in Gants Hill and this situation is unlikely to change during the lifetime of this plan. Any new scheme should include a mix of uses with active ground floor uses that address the street, in order to encourage a vibrant public realm.

2 There is approximately 12,000 m of office floorspace within or immediately adjacent to Gants Hill District Centre. Most of this is provided within purpose-built office blocks constructed from the 1960s to the 1980s. Much of the office space is outdated and there are high vacancy rates.

There is no demand for large-scale office development in Gants Hill District Centre and a managed release for other uses, such as housing, should be considered. Safeguarding the existing office floorspace is likely to lead to rising vacancy rates.

Policy GH9 - Amenity Provision, Community Uses and Social Infrastructure: The Council will encourage the provision of amenities on mixed use sites with a high density of residential use, and grant planning permission for community uses and social infrastructure: 1. As part of mixed-use development on the Opportunity Sites identified on Map 7: Opportunity Sites – Upper Floor Land Uses. 2. In other accessible locations, where an active40 ground floor street frontage is provided.

Planning policies should ensure that the impact of development on the social fabric of communities is considered and taken into account. The new housing development proposed in the Gants Hill AAP will need to be supported by appropriate community and social infrastructure. Not all the required infrastructure will necessarily have to be provided in the district centre. Given the relatively small number of sites in Gants Hill, the Gants Hill AAP Preferred Options Report established that it would not be appropriate to specifically designate locations for new community or social infrastructure, The Council will identify potential community or social infrastructure uses to development proponents as individual sites come forward for development.

The Council will require through planning obligations any supermarket located outside the Key High Street corridor to provide an improved public realm and pedestrian/cycle connections to the key High Street corridor. Development which improves access to Valentines Park will be supported and measures to enhance landscaping on approach streets to Valentines Park will be welcome.

Providing for community uses and social infrastructure, is critical to building a strong, sustainable community in Gants Hill District Centre, where residents enjoy a good quality of life, businesses wish to invest and visitors want to return. Delivering quality, modern services is also identified by the Redbridge Sustainable Community Strategy as a means of achieving its third ambition “to improve peoples’ health, care and well-being”.