Goodmayes Hospital London Borough of Redbridge Local Plan 2015 - 2030, Pre-Sumbission Draft (July 2016) 3

Ref: Local Plan Publication stage (for official use only) representation form (Regulation 19)

Redbridge Local Plan 2015-2030

Please return to London Borough of Redbridge by 30th September 2016 5pm

This form has two parts: Part A – Personal Details Part B - Your representation (s). Please fill in a separate Part B for each representation you wish to make.

Part A

1. Personal Details1 2. Agent’s Details

Title Mr Mr

First Name Simon Iain

Last Name Jones Hill

Job Title (where Planning Director relevant

Organisation NELFT Ingleton Wood LLP (where relevant)

Address Line 1 8 Whiting Road

Address Line 2 Norwich Business Park

Address Line 3 Norwich

Post Code NR4 6DN

Telephone 01603 915 322 Number Mobile 07793758560

Email address [email protected]

1 If an agent is appointed, please complete only the Personal Details, Title, Name and Organisation boxes, but complete the full contact details for Agent. www.redbridge.gov.uk Part B - If necessary please use a separate sheet for each response

Name or Organisation: North East London NHS Foundation Trust (NELFT)

3. To which part of the Local Plan does this relate?

Policies Paragraph 6.1.7 Policy LP34 Map

4. Do you consider the Local Plan is (tick):

4. (1) Legally compliant Yes X No

4. (2) Sound Yes X No

4. (2a) If No, then which of the Positively Prepared ‘Soundness test’ does it fail? Justified

Effective

Consistent with

National Policy

4. (3) Complies with the Yes X No Duty to co-operate

5. Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty-to-cooperate. Please be as detailed as possible. If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate, please also use this box to set out your comments.

See attached documents.

6. Please set out what modifications(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the test you have identified at question 5 above where this relates to soundness. (NB please note that any non-compliance with the duty to co-operate is incapable of modification at examination). You will need to say why this modification will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as detailed as possible.

See attached documents.

Please note your representation should cover concisely all the information, evidence, and supporting

information necessary to support/justify the representation and the suggested d modification, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage. After this stage, further submission will only be at the request

of the Inspector, based on the matters and issues he/she identifies for the examination. 7. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination?

No , I do not wish to participate at Yes, I wish to participate at the X the oral examination oral examination

8. If you wish to participate at the oral part of the examination, please outline why you

consider this to be necessary

Given the significance of the issues raised and their relationship to both the soundness of the Local Plan and the delivery of one of the most strategic sites within the Borough, we wish to appear at the Hearing Sessions of the Examination in Public.

Please note the inspector will determine the most appropriate procedure to adopt to hear who have indicated that they wish to participate in the oral examination.

9. Please let us know if you wish to be notified when the Yes X No Local Plan is submitted.

10. Signature Iain Hill Date 30/09/16 Ref: Local Plan Publication stage (for official use only) representation form (Regulation 19)

Redbridge Local Plan 2015-2030

Please return to London Borough of Redbridge by 30th September 2016 5pm

This form has two parts: Part A – Personal Details Part B - Your representation (s). Please fill in a separate Part B for each representation you wish to make.

Part A

1. Personal Details1 2. Agent’s Details

Title Mr Mr

First Name Simon Iain

Last Name Jones Hill

Job Title (where Planning Director relevant

Organisation NELFT Ingleton Wood LLP (where relevant)

Address Line 1 8 Whiting Road

Address Line 2 Norwich Business Park

Address Line 3 Norwich

Post Code NR4 6DN

Telephone 01603 915 322 Number Mobile 07793758560

Email address [email protected]

Name or Organisation: North East London NHS Foundation Trust

3. To which part of the Local Plan does this relate?

Policies Paragraph Policy LP1B Map

4. Do you consider the Local Plan is (tick):

4. (1) Legally compliant Yes X No

4. (2) Sound Yes No X

4. (2a) If No, then which of the Positively Prepared X ‘Soundness test’ does it fail? Justified X

Effective X Consistent with X National Policy

4. (3) Complies with the Yes X No Duty to co-operate

See attached documents.

Please note your representation should cover concisely all the information, evidence, and supporting

No , I do not wish to participate at Yes, I wish to participate at the X the oral examination oral examination

8. If you wish to participate at the oral part of the examination, please outline why you

consider this to be necessary

Please note the inspector will determine the most appropriate procedure to adopt to hear who have indicated that they wish to participate in the oral examination.

9. Please let us know if you wish to be notified when the Yes X No Local Plan is submitted.

10. Signature Iain Hill Date 30/09/16 LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015 - 2030 PRE-SUBMISSION DRAFT (JULY 2016)

REPRESENTATIONS ON BEHALF OF NORTH EAST LONDON NHS FOUNDATION TRUST (NELFT)

SEPTEMBER 2016 2

LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015-2030, PRE-SUBMISSION DRAFT (JULY 2016)

31123.1 Representations on behalf of North East London NHS Foundation Trust (NELFT)

SUBMITTED TO: PLANNING POLICY TEAM LONDON BOROUGH OF REDBRIDGE FREEPOST RSLR-JACE_HSUG ILLFORD IG1 1DD

Author: IH Checked: IH Date: September 2016

GOODMAYES HOSPITAL LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015 - 2030, PRE-SUMBISSION DRAFT (JULY 2016) 3

CONTENTS

Executive Summary

Background

Question 4

Question 5

Question 8

Contact Details

Appendices

Plan A - Contraints Plan Plan B - Illustrative Masterplan Plan C - Site A: Indicative Layout

INGLETON WOOD SEPTEMBER 2016 4

EXECUTIVE SUMMARY

• Ingleton Wood are instructed by our client, North East London NHS Foundation Trust (“The Trust”), to submit representations to the London Borough of Redbridge’s (“the Council’s”) Local Plan 2015-2030 Pre-Submission Draft (July 2016) (the draft Local Plan).

• NELFT are freehold owners of approximately 18 hectares (44.4 acres) of land around Goodmayes Hospital, Barley Lane, Essex. NELFT has in recent years given consideration to the future disposal of the site; with the intention being to reinvest any funds secured from the disposal into the provision of enhanced healthcare facilities within the locality.

• NELFT fully supports the release of land identified as King George Hospital and Goodmayes Hospital (parcels GB16b) at paragraph 6.1.7 and Figure 22: Proposed Green Belt Release of the draft Local Plan, from the Green Belt. The proposal is considered to be ‘sound’, given that it has been positively prepared, is justified and is consistent with national planning policy.

• NELFT fully support the identification of land in and around King George and Goodmayes Hospitals (Site 46) as a Development Opportunity Site, within the Crossrail Corridor Investment and Growth Area, under Policy LP1B of the draft Local Plan to provide at least 500 units.

• Whilst the principle of significant residential development on the site is supported, it is understood that, at this stage, the capacity of the site to accommodate the identified number of units, having regard to key constraints, viability and relevant planning policy, has not been fully assessed.

• Capacity studies prepared by NELFT’s and BHRUT’s advisors, who own the King George Hospital, demonstrates that land within their ownership has capacity to accommodate, as a minimum, the scale of residential development proposed by the draft Local Plan. It is strongly requested that this information is used by the Council to prepare a robust evidence base to justify the proposed allocation and demonstrate that objectively assessed development needs can be met during the plan period. This approach will ensure that the Local Plan is ‘sound’.

• The capacity studies demonstrate that that the Opportunity Site has potential to provide significantly more than the 500 dwellings identified in the draft Local Plan. To ensure that the opportunities afforded by the site and its contribution toward meeting objectively assessed housing needs are maximised, the draft policy should refer to ‘at least’ 500 dwellings on the site. This approach will ensure that the Local Plan has been planned positively.

• Whilst NELFT fully support, in principle, a coordinated and collaborative delivery of the King George and Goodmayes Hospital Development Opportunity Site, the draft Policy should recognise both that the site is within multiple ownership and that the redevelopment of the site is likely to be, and can be, delivered in phases i.e. proposals for Goodmayes Hospital will be delivered separately from King George Hospital. The capacity studies prepared by NELFT and BHRUT demonstrate how, due to, amongst other things, separate accesses arrangements, the two sites can come forward independently.

• To ensure a coordinated approach to the development of the site it is suggested that a high-level Planning Brief / Conceptual Masterplan is prepared by the Council and relevant landowners. A detailed masterplan relating to

GOODMAYES HOSPITAL LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015 - 2030, PRE-SUMBISSION DRAFT (JULY 2016) 5

the entire Opportunity Site is considered unnecessary and will delay the delivery of the site within ‘Phasing Period 2015 -2020’, which in turn will compromise the effectiveness of the Local Plan.

• Clarity is requested in relation to the requirement for a school(s) within the Opportunity Site. At this stage, no information is provided on the: size; preferred location; or delivery mechanisms for potential infrastructure requirements. This is required in order to enable the extent of land potentially needed for a School to be identified; which in turn will establish how much of the Opportunity Site could be developed for residential purposes. It will also enable an accurate assessment of the deliverability of the Opportunity Site to be made.

• To make Policy LP1B ‘sound’, it is requested that further work is undertaken by the London Borough of Redbridge prior to the submission of the draft Local Plan to assess the capacity of The King George and Goodmayes Hospitals Development Opportunity Site’, in order to confirm its ability to deliver objectively assessed development and infrastructure requirements. It is requested that the Council should work closely with land owners, who have undertaken capacity work in relation to site, when undertaking this additional work.

INGLETON WOOD SEPTEMBER 2016 6

BACKGROUND

We are instructed by our client, North East London NHS Foundation Trust (“The Trust”), to submit representations to the London Borough of Redbridge’s (“the Council’s”) Local Plan 2015 - 2030 Pre-Submission Draft (July 2016) (the draft Local Plan).

We note that the Local Plan is at Regulation 19 consultation stage and therefore any representations received by the Council will be submitted with the final submission version of the Local Plan, along with supporting documents, to the Planning Inspectorate. Representations should, therefore, be made on the basis of the “soundness” of the document. That is, in accordance with the requirements of paragraph 182 of the National Planning Policy Framework (“NPPF”).

North East London Foundation Trust (NELFT)

The North East London Foundation Trust (NELFT) provides mental health and community services for people living in the London Boroughs of Waltham Forest, Redbridge, Barking & Dagenham and Havering. It provides community health services for people living in the South West Essex Districts of Basildon, Brentwood and Thurrock as well as Emotional Wellbeing Mental Health Services across Essex. With an annual budget of more than £300 million, it provides care and treatment for a population of almost 1.5million and employs around 6,000 staff.

NELFT’s Land Ownership at Goodmayes

NELFT are freehold owners of approximately 18 hectares (44.4 acres) of land around Goodmayes Hospital, Barley Lane, Essex. NELFT’s ownership, which is outlined on the attached plan titled ‘Plan A – Constraints Plan’, can be broken down into the following areas:

Site A – Goodmayes Hospital

The site covers an area of 8.38 ha (20.7 acres). A number of buildings are located on the site, predominantly associated with the site’s use as a hospital. Some buildings are currently vacant, although the site continues to function as a hospital providing both administrative and out-patient services. The buildings on the site range from one to three storeys in height. The principal buildings, which were constructed at the turn of the last century as a former asylum hospital, are designed in an echelon formation and extend to two storeys. The echelon shape has now been broken with the construction of a modern building which will be retained for healthcare.

Two temporary car parks, which previously accommodated outlining ward buildings used for health related purposes, are located along the western boundary of the site, with open space beyond. To the east and adjacent to the site’s boundary with Barley Lane, two administrative buildings are located. The buildings provided on the site of the Goodmayes Hospital cover a footprint of 16,490m2 (177,498 sq ft).

The site has a single point of access from Barley Lane.

The site has a mature parkland setting and there is a significant number of mature trees located across the site. A blanket Tree Preservation Order (TPO) covers the majority of the trees on the site. A further TPO covers trees on the site’s eastern boundary.

GOODMAYES HOSPITAL LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015 - 2030, PRE-SUMBISSION DRAFT (JULY 2016) 7

The site is not within a Conservation Area and there are no Listed Buildings on the site. However, a number of the buildings on the site are locally listed. These include the main echelon buildings, as well as the main hall and water tower, the laundry and workshop blocks, and the superintendent’s lodge.

The site will be surplus to requirements in the near future and therefore is considered available for development.

Site B – Sunflowers Court

Sunflowers Court comprises a modern mental health in-patient facility located to the south of the site, which was opened in 2011 and which provides a 91 bed campus offering 6,500 m2 (69,966 sq ft) of floor space. The site shares a vehicular access to Barley Lane, with the main hospital site (Site A).

Tantallon House, which is currently NELFT’s Headquarters, is also located on the site along with associated visitor car parking and ancillary accommodation.

NELFT will continue to provide in-patient and mental health in-patient services from the site, therefore, Site B is not, at this moment in time, considered available for development.

Site C – Playing Fields

The site, which extends to 1.9 ha, comprises sports playing fields, together with associated changing rooms and floodlights. The site is used occasionally by a local Gaelic football club for training purposes on a Tuesday and Thursday. Much of the subterranean area of the site is taken up by a Ground Source Heat Pump, which links with the Energy Centre at Sunflowers Court (Site B) to supply sustainable energy.

The site, therefore, cannot be built on and is considered to have limited development potential.

Site D – Playing Fields

The area extends to approximately 4.0 ha. The eastern part of the site provides a playing field that is used infrequently by a Gaelic football club to play games on a Saturday and Sunday. The western part of the site comprises overgrown scrubland and is partially within Flood Zone 3.

Access to the site is currently restricted via Site B, although NELFT retains the right to make a highway connection to Barley Lane via Medici Close.

The site is considered available for development.

Site E –Allotments

The site comprises allotments that are let to tenants. Given the protection afforded to allotments, the site is not, at this moment in time, considered available for development.

INGLETON WOOD SEPTEMBER 2016 8

Site F – Brookside

A Child Development Centre, operated by NELFT, is located on the site. The site, which extends to 1.7 ha, is not, at this moment in time, considered available for development.

Surrounding Area

The site is located at the eastern edge of the Borough, just south of the A12 (Eastern Avenue) and to the north of the A118 (High Road). The site is approximately 1.4km north of Goodmayes Station served by TfL Rail services and will have Elizabeth Line (Crossrail) services operating from 2017. There are bus stops serving 4 routes within 400m walk of the site along Barley Lane and to the north of the site outside of King George Hospital. The site has a public transport accessibility level (PTAL) of between 1b and 2.

King George Hospital (owned by a separate NHS Trust) is located to the north of the site with playing fields to the west. The western boundary of the site is separated from the adjacent playing fields by a tree-lined river, designated as a Site of Importance for Nature Conservation. The areas to the east and south of the site are predominantly residential in use. The northern parts of NELFT’s ownership (Sites A, B and C, as identified on the Drawing ‘Plan A – Constraints Plan’), are screened from the surrounding area by mature trees and vegetation.

Redevelopment Proposals for Goodmayes Hospital

The Goodmayes Hospital Site (Site A on ‘‘ Plan A – Constraints Plan’), is due to become vacant in the near future. Accordingly, NELFT has in recent years given consideration to the future disposal of the site; with the intention being to reinvest any funds secured from the disposal into the provision of enhanced healthcare facilities within the locality. In order to maximise the value of the site, it is NELFT’s intention to secure planning permission for a residential development prior to the disposal of the site.

In recent years, NELFT has engaged Design Teams and Development Advisors to prepare proposals for the redevelopment of the Goodmayes Hospital site. Pre-application discussions have been held with the London Borough of Redbridge, Greater London Authority, Transport for London, and the Design Council, in relation to the part-conversion, part- redevelopment of Site A to provide 250-300 residential units. NELFT’s intention is to submit a planning application in relation to this part of the site at the earliest available opportunity.

GOODMAYES HOSPITAL LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015 - 2030, PRE-SUMBISSION DRAFT (JULY 2016) 9

QUESTION 4

Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as detailed as possible. If you wish to support the legal compliance or soundness of the Local Plan, or its compliance with the duty to co-operate, please also use this box to set out your comments.

NELFT fully supports the release of land identified as King George Hospital and Goodmayes Hospital (parcels GB16b) at paragraph 6.1.7 and Figure 22: Proposed Green Belt Release of the draft Local Plan, from the Green Belt.

The National Planning Policy Framework advises that “Once established Green Belt boundaries should be altered only in exceptional circumstances, through the preparation or review of the Local Plan”. On reviewing the draft Green Belt Review (January 2016), prepared by Wardell Armstrong on behalf of the Council, it is clear that site does not satisfy the purposes of Green Belt land as identified at paragraph 80 of the National Planning Policy Framework. The site is urban in character, surrounded by development on all sides and physically and visually disconnected from other areas of land within the Green Belt, due to the location of the A12.

It is also evident that the Council’s Objectively Assessed Housing Need cannot, based on The Strategic Housing Land Availability Assessment (2013), be met on previously developed land.

Accordingly, the proposed release of the site from the Green Belt, following a review of the Local Plan in order to meet objectively assessed housing and infrastructure requirements for the Borough, is fully supported. The proposal is considered to be ‘sound’, given that it has been positively prepared, is justified and is consistent with national planning policy.

NELFT fully support the identification of land in and around King George and Goodmayes Hospitals (Site 46 of Appendix 1: Development Opportunity Sites of the draft Local Plan) as a Development Opportunity Site, within the Crossrail Corridor Investment and Growth Area, under Policy LP1B of the draft Local Plan.

As detailed above, the principal part of the Goodmayes Hospital site (Site A on ‘Plan A – Constraints Plan’) is due to become vacant in the next two years. The redevelopment of the site will ensure the effective re-use of previously developed land. The site is also, by virtue of its size, capable of making a significant contribution towards satisfying the Council’s future growth requirements. It occupies a sustainable location, which will be enhanced by the imminent opening of Crossrail, being within easy reach, by means of transport other than the car, of a range of amenities. The suitability of the site is recognised in the Redbridge Crossrail Area Action Plan, which forms part of the adopted Development Plan, as an Opportunity Site (CCOS26) that has potential to be redeveloped for residential and educational purposes.

Policy LP1B: Crossrail Corridor Investment and Growth Area states that the King George and Goodmayes Hospital sites will be developed to provide around 500 high quality new homes (including affordable). Whilst the principle of significant residential development on the site is fully supported, it is understood that, at this stage, the capacity of the site to accommodate the identified number of units, having regard to key constraints, viability and relevant planning policy, has not been fully assessed. The NPPF advises at para 157 that Local Plans ‘should allocate sites to promote development and flexible land uses …. and provide detail on form, scale, access and quantum of development where appropriate.’

Whilst it is noted that the draft policy requires the preparation of a site wide masterplan, failure to provide this evidence at this stage questions the ‘deliverability’ of the proposed allocation, and will result in the draft Local Plan not being

INGLETON WOOD SEPTEMBER 2016 10

considered ‘sound’, given that it is not based on a robust evidence base or consistent with national planning policy.

As detailed above, a substantial amount of work has been undertaken in relation to the Goodmayes Hospital site (Site A) and it is NELFT’s intention to submit a planning application for the redevelopment of the main hospital (Site A) as soon as possible. It is, therefore, requested that prior to the Submission of the draft Local Plan to the Secretary of State, the Council work with NELFT and other landowners to ensure that the proposed allocation and associated policy, particularly its ability to accommodate at least 500 residential units, is justified by robust evidence. The work undertaken by NELFT, in relation to the capacity of the site, is summarised below.

Having regard to identified constraints and relevant planning policy, Goodmayes Hospital (Site A) is considered to have capacity to accommodate at least 250-300 units. In identifying the potential capacity of the site, consideration has been given to key factors and constraints including highways, flooding, trees, ecology, visual impact, heritage, and retained hospital infrastructure.

Plan A – Constraints Plan highlights the existing built form, landscape setting, and protected trees across the site. This, together with the need to provide new vehicular access to Barley Lane, influences the achievable density across Site A. The NELFT design work to date (illustrated on Plan B – Illustrative Masterplan and Plan C - (Site A Indicative Layout Plan) supports a development of at least 250-300 units across Site A, which would equate to an average number of dwellings per hectare of circa 30-36dph. This relatively low average figure - the PTAL rating of 2 pointing towards a target range of 45-170 units per hectare – is a direct product of considering existing site constraints, in particular, the retention and conversion of a number of locally listed buildings; trees protected by a preservation order; adjacent operational hospital infrastructure; and delivering development of a scale that, in accordance with the draft policy relating to the site enhances the setting of the site and surrounding area.

The attached plans demonstrate that through a mix of new build development and conversion of existing buildings, the site can provide at least 250-300 units in buildings ranging from 2-5 storeys in height. The scale of development proposed is considered appropriate having regard to the context of the site and surrounding area, notably the location of King George Hospital to the north, mature landscaping around the site, as well as the aspiration of the draft policy to enhance the setting of the former mental health asylum.

Work undertaken on behalf of NELFT by Peter Brett Associates, which is submitted as part of this representation, demonstrates that the operational vehicular trip generation of the proposed redevelopment of the site to provide up to approximately 300 residential units, could be significantly less than the vehicles generated by the existing use of the site.

In terms of vehicular access, the relationship of the site to the A12 means that east west trips that need to be made by car, can be done without impacting upon the more sensitive parts of the local network to the south. Planned TfL improvements to the A12/ Barley Lane junction in combination with potentially reduced traffic generation from the site, when considered in comparison to the historic uses, further benefits this east west access.

The work undertaken by Peter Brett also demonstrates that safe vehicular access can be provided from Barley Lane, to serve residential development on the existing Goodmayes Hospital. These access arrangements can be provided both technically and safely.

GOODMAYES HOSPITAL LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015 - 2030, PRE-SUMBISSION DRAFT (JULY 2016) 11

Whilst a Site of Nature Conservation Importance is located to the west of Site A, ‘Plan B – Illustrative Masterplan’ demonstrates that no development would be required in this area in order to deliver the proposed residential development.

An Ecological Survey was undertaken by Indigo Surveys on behalf of NELFT in 2015. A survey found that with the exception of bats, there is no evidence of European Protected Species or Notable Protected Habitats within the site. In relation to bats, a Nocturnal Bat Survey found that the main bat roosting points were contained within the existing hospital buildings. Whilst some of these maybe removed as part of any proposal, mitigation measures can be put in place to ensure bats are adequately protected.

As detailed above, a number of buildings on the site are locally listed. The proposals prepared by NELFT have been informed by a Heritage Assessment, prepared by CgMS, and which has concluded that any proposal that retains and converts the echelon buildings would protect the site’s heritage by securing the built fabric of the original hospital buildings, ensuring no further degradation occurs. Therefore, any impact caused by the part demolition of the hospital buildings would be offset.

In relation to the other land within NELFT’s ownership, only Site D is, at this moment in time, considered to be available for development. Whilst the site, in the main, comprises a playing field (marked out as a football pitch) it is not subject to a Protected Open Space and Play Space designation on the Policies Map that accompanies the draft Local Plan. The London Borough of Redbridge Playing Pitch Strategy (2016), which forms part of the evidence base for the draft Local Plan, does not identify Goodmayes as an area where there is a lack of provision of such facilities. In addition, Site C, located to the north of Site D, is, as detailed above, not available for development of residential uses. However, Site C could be used to provide enhanced open space / sports facilities as part of any wider redevelopment of the Goodmayes Hospital Site.

Initial work undertaken by Ingleton Wood, and which is detailed on Plan B – Illustrative Masterplan demonstrates that Site D has capacity to provide at least 200 residential units. This would comprise new build development, which having regard to the context of the surrounding area, is likely to be circa 2-3 storeys in height.

With regard to highways, work undertaken by Peter Brett Associates has demonstrated that safe vehicular access to Site D could be provided via a safeguarded access on to Barley Lane via Medici Close. NELFT has retained access rights following a past disposal of land to Bellway Homes. The work undertaken by Peter Brett Associates also concludes that the local highway network can accommodate in excess of 500 units and that the site presents opportunities to provide more sustainable journey patterns to and from the local area.

It is strongly requested that this information is used by the Council to prepare a robust evidence base to justify the proposed allocation and demonstrate that objectively assessed development needs can be met during the plan period. This approach will ensure that the Local Plan is ‘sound’.

As detailed on Plan A – Constraints Plan and Plan B – Illustrative Masterplan, land within the ownership of NELFT has capacity to accommodate, as a minimum, the scale of residential development proposed by the draft Local Plan. In addition, the work prepared on behalf of BHRUT, owners of the King George Hospital, demonstrates that approximately 187 residential units can be accommodated on the northern part of the Opportunity. The two sites within the Opportunity Site therefore have the potential to exceed the 500 dwellings envisaged by the draft policy. Accordingly, to ensure that the opportunities

INGLETON WOOD SEPTEMBER 2016 12

afforded by the site and its contribution toward meeting objectively assessed housing needs are maximised, the draft policy should refer to ‘at least’ 500 dwellings on the site. This approach will ensure that the Local Plan is flexible to changing circumstances and has been planned positively.

Draft Policy LP1B advises that development on the King George and Goodmayes Hospital Sites should be considered in the context of a Masterplan for the site as a whole. In order to prevent ambiguity and ensure that the policy is effective in accordance with the tests of ‘soundness’, clarity is required as to whether any requirement relates to just the King George and Goodmayes Hospital site, or the wider area covered by the Crossrail Investment and Growth Area. It is strongly requested that each of the Development Opportunity Sites within the Growth Area are planned independently.

Whilst NELFT fully support, in principle, a coordinated and collaborative delivery of the King George and Goodmayes Hospital Development Opportunity Site, the draft Policy should recognise both that the site is within multiple ownership and that the redevelopment of the site is likely to be, and can be, delivered in phases.

The King George and Goodmayes Hospital sites are within two separate ownerships. Whilst they are both currently NHS owned, the freehold titles are with two separate Trusts. King George is owned by Barking, Havering and Redbridge University Hospitals NHS Trust – an acute hospital provider; and Goodmayes Hospital is owned by North East London NHS Foundation Trust – a mental health and community services provider. In addition, land to the south of the proposed allocation is understood to be in the ownership of the Local Education Authority.

It is likely that the availability of land for development will vary between landowners depending on, amongst other things, the operational requirements of existing uses. As a result, the Policy should recognise that applications for the redevelopment of the site are likely to come forward independently and in a phased manner. For example, the work undertaken by NELFT, as detailed above, has demonstrated that the existing Goodmayes Hospital site (Site A) is capable of delivering approximately 250-300 units and can come forward in isolation from the remainder of the Opportunity Site (Refer to Plan C - Site A: Illustrative Masterplan).

Accordingly, the policy should make it clear that a phased approach to the redevelopment of the site will be supported, provided proposals can demonstrate that they would not prejudice the wider aspirations of the Opportunity Site, in so far as they relate to Site 46 only. This would ensure that the policy is both justified and effective. It is considered that failure to do this would undermine the potential for residential development to be delivered on the site within ‘Phasing Period 2015 -2020’, as identified in Appendix 1 (page 149 of the Draft Local Plan).

To ensure a coordinated approach to the development of the site it is suggested that high -level Planning Brief / Conceptual Masterplan, covering matters such as development zones, development parameters, infrastructure requirements and accessibility, is prepared by the Council in conjunction with relevant landowners. A detailed masterplan relating to the entire Opportunity Site is considered unnecessary and will delay the delivery of the site within ‘Phasing Period 2015 -2020’, which in turn will compromise the effectiveness of the Local Plan. It would also ensure a consistent approach with other Opportunity Sites within the Crossrail Corridor Investment and Growth Area.

The criteria relating to Policy LP1B King George and Goodmayes Hospitals states that the development should allow for “On site provision for a new primary and secondary school”. As drafted the Policy is ambiguous and inconsistent.

GOODMAYES HOSPITAL LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015 - 2030, PRE-SUMBISSION DRAFT (JULY 2016) 13

Draft Policy LP1B: Crossrail Corridor Investment and Growth Area states that that in terms of key infrastructure, the area will be required to provide a minimum of three new 8 x form entry secondary schools. This is consistent with paragraph 6.16 (page 22) of the Council’s Infrastructure Delivery Plan (2015 – 2030), which advises that:

1) Crossrail Corridor: land around King George and Goodmayes, has been identified for mixed use redevelopment, including secondary school provision (Site 46 in Local Plan Phase 1 2015-2020).

In a similar manner, whilst both Figure 8: Crossrail Corridor Investment and Growth Area of the draft Local Plan and the Council’s Infrastructure Delivery Plan (2015 – 2030) identify the Ford Sports Ground as being required to provide a secondary school, no mention of such a requirement is detailed within the policy criteria relating to the development of The Ford Sports Ground. Clarity is, therefore, required in relation to the infrastructure requirements for the site and the wider Crossrail Corridor Investment and Growth Area. Failure to provide this clarity will result in the policy being unsound, as it will not deliver objectively assessed infrastructure requirements.

The ambiguity regarding infrastructure provision on the site has implications in relation to both the viability and deliverability of the King George and Goodmayes Hospital site as a Development Opportunity Site. More specifically, at this stage, no information is provided on the: size; preferred location; or delivery mechanisms for the identified infrastructure requirements.

The provision of a secondary school, or both a secondary and primary school on the site, will require a significant amount of land. Whilst it is understood that land located toward the southern part of the Development Opportunity Site is local education authority owned, it is unclear if this area will be sufficient to deliver the required School. If the land is not of a sufficient size, it is unclear how land, that is not owned by the local education authority, will be acquired to deliver the necessary infrastructure.

In addition, if land is required to deliver the School, the impact on the ability of the Opportunity Site to deliver 500 residential units is unclear. This ambiguity highlights the need, as detailed above, for the Council to undertake further work prior to submission of the Local Plan, to assess the capacity of the site to ensure that the draft policy is, in accordance with the NPPF, positively prepared, justified and effective.

The Trust notes that the King George and Goodmayes Hospital sites are not one of the sample of sites tested in the Council’s viability evidence base. However, the Ford Sports Ground site, which lies adjacent, has been tested. The provision of infrastructure such as a secondary school will increase the costs associated with the redevelopment of the site and therefore will have an impact on the viability. Given this position, Policy LP1B requires further flexibility in the form of considering the viability impacts of such requirements, to ensure that it is effective. It will therefore be imperative that this is considered in future viability testing to support the detailed master planning guidelines for the site and this should be clearly stated within Policy LP1B.

In addition to the requirement for the provision of schools, Policy LB1B also sets out a requirement for, “The provision for decentralised energy networks, subject to feasibility. Any provision that is secured on this site must comply with policy LP29 in order to limit impacts on residential amenity”. The requirement for a decentralised energy network is not justified and will have significant cost implications for the development of the Opportunity Site. In addition, no such requirement is placed on other Opportunity Sites which are within single ownership; have less constraints than the King George and

INGLETON WOOD SEPTEMBER 2016 14

Goodmayes Hospital Sites; and are forecast to provide more dwellings. Accordingly, its requirement should be removed.

The Trust would also like to make the Council and Inspector aware of additional abnormal costs that will be incurred in the redevelopment of the Goodmayes Site. These are due to/include:

• high levels of asbestos, in buildings and underground in service ducts that will required specialised removal services;

• blanket tree preservation order; and

• locally listed buildings.

These abnormal costs will undoubtedly have an impact on the viability and will therefore need to be assessed in conjunction with the cumulative policy requirements on the Site, when considering the deliverability of the growth envisaged at the Opportunity Site.

GOODMAYES HOSPITAL LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015 - 2030, PRE-SUMBISSION DRAFT (JULY 2016) 15

QUESTION 5

Please set out what modification(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the test you have identified at question 5 above where this relates to soundness. (NB please note that any non-compliance with the duty to co-operate is incapable of modification at examination). You will need to say why this modification will make the Local Plan compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as detailed as possible.

At present, it is considered that the draft Local Plan is not based on a robust evidence base given that insufficient information has been provided by the Council to demonstrate that the site can deliver around 500 residential units and associated infrastructure. To make Policy LP1B ‘sound’, it is requested that further work is undertaken to assess the capacity of The King George and Goodmayes Hospitals Development Opportunity Site in order to confirm its ability to deliver objectively assessed development and infrastructure requirements. It is requested that the Council should work closely with land owners, who have undertaken capacity work in relation to site, when undertaking this additional work.

The capacity studies prepared on behalf of NELFT and BHRUT demonstrate that that the Opportunity Site has potential to provide significantly more than the 500 dwellings identified in the draft Local Plan. To ensure that the opportunities afforded by the site and its contribution toward meeting objectively assessed housing needs are maximised, the draft policy should refer to ‘at least’ 500 dwellings on the site. This approach will ensure that the Local Plan has been planned positively.

A key part of the additional work required to be undertaken by the Council relates to the provision of infrastructure requirements for the site, particularly the type and size of school required, along with mechanisms for deliverability. This is required in order to enable the extent of land potentially required for a School to be identified; which in turn will establish how much of the site could be developed for residential purposes.

The provision of this additional information will ensure that the proposed allocation of the site is based on the most appropriate strategy and proportionate evidence and accordingly is justified in accordance with paragraph 182 of the NPPF.

This additional information needs to be incorporated into the Council’s Viability Assessment to confirm that the site is, when considered against a robust evidence base, deliverable over the plan period. The provision of the required infrastructure will have a significant impact on development viability; the impacts of which need to be fully assessed to ensure the scheme is deliverable.

To ensure that the policy is both effective and justified, a degree of flexibility needs to be incorporated. Given the scale of the site and the different landowners, as well as ongoing operational requirements, it is extremely likely that the proposal will be delivered in phases. Accordingly, the policy should recognise that provided it can be demonstrated that a proposal would not prejudice the wider redevelopment of the Opportunity Site, applications can come forward that relate to individual parcels of land within the allocation. It is considered that this can achieved through the preparation of a high level Planning Brief / Concept Masterplan, which identifies key parameters to guide future development, including the delivery of related infrastructure.

INGLETON WOOD SEPTEMBER 2016 16

Based on the foregoing, the following amendments, which are supported by BHRUT (the owners of the King George Hospital) are requested to Policy LP1B: King George and Goodmayes Hospitals.

“The Council expects a comprehensive coordinated housing-led mixed use developments to come forward at King George and Goodmayes Hospitals in accordance with the following criteria:

• Land in and around King George and Goodmayes Hospitals will be developed to provide around at least 500 high quality new homes (including affordable in accordance with Policy LP3: Affordable Housing);

• Maximising densities compatible with local context, sustainable design principles and public transport capacity, in line with the Density Matrix of the London Plan;

• On site provision for a new primary and secondary school

• A pPermeable design – a walkable neighbourhoods with routes and spaces defined by buildings and landscape;

• Improved east-west pedestrian and cycle routes to link the new neighbourhoods together;

• Development to be of the highest quality design, respecting the nature and character of the area;

• At Goodmayes development should maximise the opportunity to create a centerpiece for the new neighbourhood with opportunities to enhance the setting of the former mental health asylum;

• The provision for decentralised energy networks, subject to feasibility. Any provision that is secured on this site must comply with policy LP29 in order to limit impacts on residential amenity;

• Development of this site should also comply with all other relevant policy requirements of this plan; and

• Development of this site should be considered in the context of a Masterplan for the site as a whole. A Planning Brief/Concept Masterplan will be prepared in consultation with the owners of the sites to ensure that a coordinated approach is taken to the development of the sites and the provision of infrastructure. strikethrough = text to be deleted italics = text to be added

GOODMAYES HOSPITAL LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015 - 2030, PRE-SUMBISSION DRAFT (JULY 2016) 17

QUESTION 8

If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary

INGLETON WOOD SEPTEMBER 2016 18

CONTACT DETAILS

Simon Jones Iain Hill Head of Estates Strategy and Major Capital Developments Director of Planning NELFT Ingleton Wood LLP Goodmayes Hospital 8 Whiting Road 157 Barley Lane Norwich Buisness Park Ilford Norwich Essex Norfolk IG3 8XJ NR4 6DN

Tel: 0300 555 1201 Ext: 64321 Tel: 01603 666847 Mob: 07968 826265 Mob: 07793 758560 Email: [email protected] Email: [email protected]

GOODMAYES HOSPITAL LONDON BOROUGH OF REDBRIDGE LOCAL PLAN 2015 - 2030, PRE-SUMBISSION DRAFT (JULY 2016) 19

Appendices

Plan A - Contraints Plan Plan B - Illustrative Masterplan Plan C - Site A: Indicative Layout

INGLETON WOOD SEPTEMBER 2016 King G eorge Hospital

C B

Barley Lane

F l o o d Z o n e D

Locally Listed Buildings

Sites of Importance for Nature Conservation

SFRA Flood Zone 3a High Probability

SFRA Flood Zone 3b F Functional Floodplain

SFRA Flood Zone 2 Medium Risk

Extent of NELFT Ownership

Indicative Site Boundaries

All trees within ownership Subject to T.P.O

Goodmayes Hospital NELFT Plan A - Constraints Plan Site Plan 1:2500 @A3 King George Hospital

C B

Barley Lane Barley

Flood Zone Flood D

Proposed Cycle Route Cycle Proposed

Proposed Site Access Site Proposed

Extent of NELFTOwnership of Extent E

Proposed Residential Site: Residential Proposed W ith Illustrative Masterplan Illustrative With A 8.39ha (250-300 Units 30-36dph) Units (250-300

Proposed Retained Retained Proposed B/F Use Health F Existing Sports Field/ Sports Existing C PumpHeat GroundSource

Proposed Residential Site: Residential Proposed Indicative Capacity Indicative 4.04ha 4.04ha D 57dph) Units (200 Exc Flood Zone Flood Exc

E Allotments Existing

GoodmayesHospital NELFT Plan B - Illustrative Masterplan @ A31:2500 Plan Site Plan C - Site A, Indicative Layout Layout Indicative A, Site - C Plan Norwich 8 Whiting Road Norwich Business Park Norwich Norfolk NR4 6DN

T: 01603 666847 F: 01603 629 798 www.ingletonwood.co.uk

Goodmayes Hospital The Redbridge Local Plan 2015-2030 Pre-Submission Draft

Technical Response – Transport & Accessibility

On behalf of NELFT

34167 | Rev: - | September 2016 Telford House Cambridge CB21 5HB T: 01223 882000 F: 01223 881888 Technical Response – Transport & Accessibility Local Plan Representations Goodmayes Hospital

Document Control Sheet

Project Name: Goodmayes Hospital Project Ref: 34167 Report Title: Transport Strategy to Support Local Plan Representations Doc Ref: Local Plan Representations Date: 28.09.2016

Name Position Signature Date

Assistant Transport Prepared by: Jack Smith 28/09/16 Planner

Reviewed by: Elliot Page Senior Associate 28/09/16

Approved by: Ron Henry Partner

Revision Date Description Prepared Reviewed Approved

Hannah Reed & Associates Limited disclaims any responsibility to the Client and others in respect of any matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence within the terms of the Contract with the Client and generally in accordance with the appropriate ACE Agreement and taking account of the manpower, resources, investigations and testing devoted to it by agreement with the Client. This report is confidential to the Client and Hannah- Reed accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk.

J:\34167 Goodmayes ii Hospital\Reports\Transport\Local Plan Reps \Transport Note for Local Plan Reps_FINAL.docx Technical Response – Transport & Accessibility Local Plan Representations Goodmayes Hospital

J:\34167 Goodmayes iii Hospital\Reports\Transport\Local Plan Reps \Transport Note for Local Plan Reps_FINAL.docx Technical Response – Transport & Accessibility Local Plan Representations Goodmayes Hospital

1 Introduction & Context

1.1 Background to Report

1.1.1 Peter Brett Associates (PBA) have been instructed by Ingleton Wood on behalf of North East London Foundation Trust (NELFT) to advise on the highway and wider transportation issues associated with the Redbridge Local Plan and the potential development of land at Goodmayes Hospital in particular.

1.1.2 Goodmayes Hospital is part of Opportunity Site 46 which is proposed to be allocated in the Local Plan as part of LP1B: Crossrail Corridor Investment and Growth Area.

1.1.3 The Redbridge Local Plan: Pre-Draft Submission proposes to allocate the site for housing led mixed use development for around 500 homes with on-site provision for a new primary and secondary school. It provides an indicative commencement within Phase 1 of the plan period (2015 – 2020). NELFT considers that land within their ownership can accommodate the number of residential units specified and this report therefore sets out the associated justification and deliverability of the site in Transport terms, through the Emerging Transport Strategy, for the appropriateness of this draft allocation within the Redbridge Local Plan: Pre- Draft Submission with regard to the Goodmayes Hospital Site.

1.1.4 This document therefore forms part of the evidence base response to the Redbridge Local Plan: Pre-Draft Submission.

1.2 The NELFT Land Holdings

1.2.1 The NEFLT land holdings include the Goodmayes Hospital and the Goodmayes playing fields (Site D) to the south of Sunflower Court. Appendix A includes the Illustrative Masterplan which shows the NEFLT land holdings. Appendix B includes a plan of the areas allocated in Crossrail Corridor Investment and Growth Area as part of the draft Local Plan.

1.2.2 Goodmayes site is located within the Seven Kings district of the London Borough of Redbridge (LBR). The site is located at the eastern edge of the borough, just south of the A12 (Eastern Avenue) and to the north of the A118 (High Road). The site is approximately 1.4km north of Goodmayes, where the nearest railway station can be accessed. The site covers an area of 18.6 hectares and is owned by the NELFT.

1.2.3 The site is bound by Barley Lane (B177) to the east, Barley Lane Allotments to the south, and a playing field to the west. To the north, King George’s Hospital borders the site and is interconnected to the Goodmayes hospital via a number of internal footpaths, although internal vehicular movements between the two developments are restricted.

1.2.4 Goodmayes Hospital provided mental health services for the NHS, dating back to the original buildings in the north of the site originally opened as the West Ham Borough Asylum in 1902. The Asylum became Goodmayes Hospital in 1948 and remained in use to the present day. However, from early 2008 it was apparent that the original early 20th century buildings were no longer fit for purpose and were in various states of disrepair.

1.2.5 The buildings associated with the former Goodmayes Hospital cover a footprint of some 18,182m² with 248 car parking spaces associated and no dedicated cycle parking. As part of the wider NELFT strategy, a new mental health medical facility known as Sunflowers Court has been built to the south of the old Goodmayes Hospital and this is also accessed from the un-named road leading from Barley Lane. The opening of Sunflowers Court in early 2011 signalled the most recent closure of Goodmayes Hospital in 2013. Sunflowers Court consists of a new 91-bed campus covering a footprint of 6,500m², it provides a new 120-bay car park and cycle parking facilities for 42 cycles.

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1.3 Report Structure

1.3.1 This report provides comment and response on all transport related elements of the allocation and considers the impact that any development would have on the wider network and environs. It is set out and structured as follows:

 Section 2: Local Plan and LBR Transport Impact Conclusions Summary

 Section 3: Response to Local Plan Conclusions

 Section 4: Justification and Support for Draft Allocation

 Section 5: Summary and Conclusions

2 Local Plan and LBR Transport Impact Conclusions Summary

2.1 Local Plan Process

2.1.1 LBR conducted an initial consultation with residents, businesses and other stakeholders during September and October 2011 to identify the key issues for a new local plan.

2.1.2 A Preferred Options Report (January 2013) identified those places where change and development could be accommodated and used to enhance the local environment through “Investment Areas” and recognised that the Borough must be protected from inappropriate development.

2.1.3 Following the 2013 Preferred Options consultation, a “Preferred Options Extension- Alternative Development Strategies” Report was produced which presented four options to consider how to meet part of the Council’s housing and infrastructure needs.

2.2 Local Plan Conclusions Relative to Opportunity Site 46

2.2.1 There will be five Investment and Growth areas to accommodate new development including new homes, shops, leisure facilities and infrastructure:

 Ilford;

 Crossrail Corridor;

 Gants Hill;

 South Woodford; and

 Barkingside.

2.2.2 Of these Policy Areas for Development and Change, LP1B: Crossrail Corridor Investment and Growth Area includes the proposed development site. This section of the report states and concludes the following which is provided only in summary.

2.2.3 The ‘Redbridge Local Plan 2015-2030: Pre-Submission Draft’ was approved for consultation by the Council on Thursday 21 July 2016. The draft of the Local Plan is subject of this Transport representation for Opportunity Site 46 which includes the Goodmayes and King George Hospital sites.

Opportunity Site 46: King George and Goodmayes Hospitals

2.2.4 The Council expects a comprehensive housing led mixed use development at King George and Goodmayes Hospitals in accordance with the following criteria:

 Land in and around King George and Goodmayes Hospitals will be developed to provide around 500 high quality new homes (including affordable);

 Maximising densities compatible with local context, sustainable design principles and public transport capacity, in line with the Density Matrix of the London Plan;

 On site provision for a new primary and secondary school;

 A permeable design – a walkable neighbourhood with routes and spaces defined by buildings and landscape;

 Improved east-west pedestrian and cycle routes to link the new neighbourhoods together;

 Development to be of the highest quality design, respecting the nature and character of the area;

 At Goodmayes development should maximise the opportunity to create a centrepiece for the new neighbourhood with opportunities to enhance the setting of the former mental health asylum;

 The provision for decentralised energy networks, subject to feasibility. Any provision that is secured on this site must comply with policy LP29 in order to limit impacts on residential amenity;

 Development of this site should also comply with all other relevant policy requirements of this plan; and

 Development of this site should be considered in the context of a Masterplan for the site as a whole.

2.3 High Level Transport Study (TS) Report

2.3.1 This report was undertaken by Atkins on behalf of LBR and provided a review and feasibility study of two sites for potential Local Plan Allocation. The two key opportunity sites that were tested in this high level transport study were Oakfields Playing Fields (Site One) to the north of Barkingside Town Centre and land in and around King George and Goodmayes Hospitals, including the Ford Sports Ground (Site Two). Location plans for both Site One and Two are included within Appendix C.

2.3.2 Early-stage indicative site assessments show that the two opportunity sites could yield between 1,474 and 2,849 new homes (between 614 – 899 for Site One depending on Site Development Yield, and between 860 and 1950 for Site Two depending on Yield) with supporting community infrastructure such as new schools also provided.

2.3.3 The scenarios tested for the King George and Goodmayes Hospitals, including the Ford Sports Ground (Site Two) site are as follows:

Low Yield Scenario

2.3.4 The Low Yield Scenario for Site Two comprises approximately 900 new homes with an overall mix of 41% flats and 59% houses.

 Potential Access Point A - housing plus a new 4FE Primary School and a new 10FE Secondary School - accessed via Aldborough Road South;

 Potential Access Point B – housing – accessed via the A12 Eastern Avenue and the B177 Barley Lane;

 Potential Access Point C – housing – accessed via the B177 Barley Lane; and

 Potential Access Point D – housing – accessed via the B177 Barley Lane.

Medium Yield Scenario

2.3.5 The Medium Yield Scenario for Site Two comprises approximately 1,100 new homes with an overall mix of49% flats and 51% houses.

 Potential Access Point A - housing plus a new 4FE Primary School and a new 10FE Secondary School - accessed via Aldborough Road South;

 Potential Access Point B – housing – accessed via the A12 Eastern Avenue and the B177 Barley Lane;

 Potential Access Point C – housing – accessed via the B177 Barley Lane; and

 Potential Access Point D – housing – accessed via the B177 Barley Lane.

High Yield Scenario

2.3.6 The High Yield Scenario for Site Two comprises approximately 2,000 new homes with an overall mix of 77% flats and 23% houses.

 Potential Access Point A - housing plus a new 4FE Primary School and a new 10FE Secondary School - accessed via Aldborough Road South;

 Potential Access Point B – housing – accessed via the A12 Eastern Avenue and the B177 Barley Lane;

 Potential Access Point C – housing – accessed via the B177 Barley Lane; and

 Potential Access Point D – housing plus a new 4FE Primary School – accessed via the B177 Barley Lane.

2.3.7 The High Level Transport Study concludes that for Site 2:

‘It is considered that with suitable provision of infrastructure to access the sites, the proposed site offer the opportunity to deliver development that is sustainable in transport terms in accordance with NPPF.’

‘The assessment has identified that in Plan Year 2030, irrespective of yield development at Site Two is likely to have will have a Major Impact on the A118 High Road and Moderate Impacts on the B117 and Aldborough Road South.’

2.4 Section Summary

 The local plan includes for LP1B: Crossrail Corridor Investment and Growth Area which includes the proposed development site.

 High level Transport Study identifies Opportunity Site 46, which includes King George and Goodmayes Hospitals and the Ford Sports Ground, as being suitable to accommodate between 860 and 1950 units.

 The Local Plan suggests that specifically the land in and around King George and Goodmayes Hospitals will be developed to provide around 500 high quality new homes (including affordable) and an on-site provision for a new primary and secondary school;

 High level Transport Study indicates that irrespective of yield development at Site Two is likely to have will have a Major Impact on the A118 High Road and Moderate Impacts on the B117 and Aldborough Road South.

 High level Transport Study for Opportunity Site 46 states that a detailed modelling exercise is required to consider the impact of development proposals in terms of highway network capacity with localised junction capacity assessments to arrive at necessary interventions to mitigate the traffic impact of development

3 Site Development Potential

3.1 Introduction

3.1.1 The High Level Transport Study undertaken to assess the potential of Opportunity Site 46 to accommodate development, identifies the King George and Goodmayes Hospitals site capacity as 500 units. NELFT supports the allocation of 500 units on the Goodmayes site and site D of the NELFT land holdings.

3.1.2 This section of the report further justifies why NELFT consider the conclusions to be valid and robust and that the site can be developed accordingly given the availability of existing transport infrastructure, wider programmed improvements and site specific measures that would be implemented to reduce the impacts from development.

3.2 Masterplan Development Undertaken To Date

3.2.1 Ingleton Wood on behalf of NELFT and with the support of PBA has prepared, developed and tested a masterplan for the northern part of the NELFT land holdings, which primarily relates to the existing hospital buildings which are now underused. This work has shown that the site has physical capacity for around 250-300 units.

3.2.2 Whilst less detailed design exercises have been undertaken for site D of the NELFT land holdings, the site is green field and less constrained and Ingleton Wood consider that a further 200 units could be developed at a density of 55dph.

3.2.3 The combined total for the NEFLT Land Holdings would therefore be in the region of 500, irrespective of any units that may be accommodated on the draft Local Plan allocation for the King George Hospital site.

3.2.4 The capacity studies undertaken by NELFT and BHRUT suggest that the sites have capacity to achieve the amount of development anticipated by draft policy LP1B and potentially to significantly exceed it.

3.2.5 The scale of a development of at least 500 residential units allows for comprehensive planning and masterplanning to be undertaken. As such, the proposals will be developed and designed to provide a balanced mix of uses encompassing residential units and recreational facilities. The proposed development will aim to create a mix of uses which will reduce the need to travel to off-site destinations and maximise the containment of trips within the development site, so that a high proportion of trips can be undertaken by non-car modes.

3.2.6 Through the detailed design process it will be necessary, to ensure that the new development to incorporate the following accessibility principles:

 Ease of movement – a place that is easy and direct to get to and move through.

 Promote accessibility and local permeability by making places that connect with each other and are easy to move through, putting people before traffic and integrating land uses and transport.

 Legibility – a place with a clear image that has a clear understanding for residents and visitors.

3.2.7 These themes are being taken forward as indicated in the Illustrative Masterplan, and will help to ensure a pleasant and high quality environment is developed for the benefit of existing and future communities alike.

3.3 Existing Transport Infrastructure

Pedestrian & Cyclists

3.3.1 The main pedestrian access to the Goodmayes Hospital site is from Barley Lane which has a pedestrian footpath from a gate adjacent to the main vehicular access point into the site. The footpath takes pedestrians across the grounds and into the heart of the development site.

3.3.2 Along Barley Lane wide footways are provided which offer dropped kerbs and tactile paving at all junctions. The available footway width is however reduced due to legal on street footway parking.

3.3.3 Visitors and employees can access the site within a 17-minute walk from Goodmayes railway station, 1.37km south of the site, with the closest bus stop being accessible in under five minutes, assuming a standard walk speed of 4.8km/h.

3.3.4 There are a number of traffic islands on Barley Lane to facilitate and aid pedestrian movement to the ‘Goodmayes Hospital’ bus stop for southbound services.

3.3.5 A further pedestrian path lies between the bus stops located on Eastern Avenue, north of Barley Lane, and King George Hospital. This access provides pedestrians with a shortcut through the hospital campus. It is controlled by a gate on Eastern Avenue, which is closed during the hours of 22.00hrs until 06.30hrs from Monday to Friday.

3.3.6 Pedestrian crossing facilities are provided at the following locations:

 Zebra crossing – to the immediate north of the Barley Lane/Gresham Drive junction.

 Traffic islands – along Barley Lane

 Zebra crossings – within King George’s Hospital

3.3.7 To the west of the site runs the Seven Kings Cycle Path which connects the Seven Kings Park up to Hainault. London Cycle Network (LCN) Route 12 can be accessed from Barley Lane. Westbound, the LCN12 connects to Goodmayes and Ilford. From Ilford, cycle access is granted to the LCN55. The LCN55 connects to a number of onward destinations such as Wanstead, Barking and Central London.

3.3.8 Eastbound, LCN12 connects to a number of onward routes, providing access to a number of destinations such as Romford; Hornchurch, Upminster, Dagenham and Rainham.

3.3.9 In the immediate locality of the site, Barley Lane also connects to a network of marked on road routes and routes on quieter roads recommended for cyclists to destinations including Ilford, Goodmayes and Little Heath.

Buses

3.3.10 There are bus stops along Barley Lane and additional bus stops are located to the north of the site outside of King George Hospital.

3.3.11 The corridor is served by Bus Services 173, 362 and 396. There is a high quality segregated pedestrian access to this bus stop via the internal footpaths that interconnect King George and Goodmayes Hospitals.

Rail

3.3.12 The closest rail services are available at Goodmayes Railway Station, which is approximately 1.37km (a 17-minute walk) from the development site. Because the station is located beyond the 960-metre walking distance from the POI, it is not material to the PTAL calculation. However, it is acknowledged that the station is still within easy reach from the development site as it is less than 2km away, therefore still under the preferred maximum walking distance according to the IHT classification. It can also be accessed by a short 5-6 minute bus journey on the 387 service.

3.3.13 Goodmayes railway station is located on the Great Eastern Main Line, in Travelcard Zone 4. Services are operated by Greater Anglia providing connections to London Liverpool Street, Shenfield, Essex and beyond in East Anglia. There are currently 10 cycle parking racks located at the station.

3.3.14 Services are operated by TfL Rail and in 2017 new Class 345 trains will enter service as Crossrail partially opens. The route will be extended through central London to London Heathrow Airport and Reading in 2019. The four platforms at Goodmayes will be extended from their current length of 184 metres to accommodate the Crossrail trains which will be over 200 metres long. New lifts, signage, help points, customer information screens and CCTV will be installed in preparation for the opening of Crossrail.

London Underground

3.3.15 In addition to the railway station at Goodmayes, the site also benefits from having close and convenient access to the London Underground network. The nearest station is Newbury Park, on the Hainault loop of the Central Line, in Travelcard Zone 4, located west of the site.

3.3.16 Bus Service 396 can take site users from King George Hospital to Newbury Park station in approximately 9 minutes.

Public Transport Accessibility Levels

3.3.17 In order to review the existing public transport services in the vicinity of the development site, the Public Transport Accessibility Level (PTAL) methodology developed by Transport for London has been used. The PTAL methodology assesses the accessibility of any given site or point of interest by attributing a PTAL score to it.

3.3.18 A PTAL score ranges from 1a, the lowest possible score denoting very poor accessibility, to level 6b, which indicates excellent accessibility by public transport. TfL’s WebCAT service has been used to establish the 2011 PTAL Baseline. It is therefore apparent that Goodmayes Hospital has a PTAL level ranging between 1b and 2, subject to where the PTAL POI start point is calculated from.

3.3.19 Although endorsed by the Greater London Authority and Transport for London (TfL), it is acknowledged that the PTAL methodology does not take account of the following:

 The quality of the walking route to the public transport services. Goodmayes has high quality routes through the site, whilst there are also well maintained footways and crossing facilities along Barley Lane to Goodmayes railway station

 The convenience of the public transport routes. A large number of bus routes are available just outside the limit for consideration within the PTAL methodology; this includes the bus services situated along the A12 (Eastern Avenue) within

approximately a 10-minute walk. Furthermore, Goodmayes railway station is accessible from the site within approximately a 17-minute walk

 The potential for interchange

 The destinations that can be reached using a combination of public transport services, walk and cycle facilities – Liverpool Street can be reached within 21 minutes from Goodmayes railway station

 The capacity of public transport services.

Existing Highway Network and Vehicular Access Arrangements

3.3.20 The existing vehicular access into Goodmayes Hospital leads to Sunflowers Court and Goodmayes Hospital with signed restrictions prohibiting internal vehicular movements between Goodmayes and King George Hospitals. A 5mph traffic calming zone has been implemented within the hospital site and access routes are marked with double red lines to prohibit stopping or parking at any time.

3.3.21 Access into the Goodmayes Hospital Sports Ground is currently through the hospital site.

3.3.22 Wider vehicular access to the site can be considered good, with strategic access achievable from a number of key arterial routes into London.

3.3.23 Primary access to the site is via the B117 (Barley Lane) which runs north-south. To the north, Barley Lane connects to the A12 (Eastern Avenue). The A12 (Eastern Avenue) forms part of the Transport for London Road Network (TRN). Westbound, it provides access onto the A406 (North Circular) which is a main arterial road. Further westbound, the A12 also connects to the A102, a key north-south route across the River Thames. Eastbound, the A12 provides access onto the M25, a major orbital motorway encircling Greater London.

3.3.24 To the south, the B117 (Barley Lane) connects to the A118, A1083 and the A124; all of these road provide onward access eastbound to the M25, and westbound to the A406.

3.4 Proposed Transport Infrastructure and Strategy

3.4.1 This section of the report sets out a series of possible further interventions that are considered to be effective enough to address any associated impacts relating to Opportunity Site 46 but would also have wider benefits for Goodmayes and support the delivery of Local Plan growth in this location.

Wider Future Transport Improvements

3.4.2 The following committed transport improvements are being delivered within the local area to Opportunity 46 and will support development at this site.

 Crossrail at Goodmayes - In May 2015, TfL took over the operation of the stopping services from Goodmayes station. From May 2017, new trains will be introduced between Shenfield and Liverpool Street. From December 2019, when the route fully opens, passengers will be able to travel through central London without having to change trains. At peak times 12 trains an hour will run between Shenfield and central London, calling at all stations. An additional four trains an hour will run between Gidea Park and the existing Liverpool Street station, westward in the morning peak and eastward in the evening peak.

 A12/ Barley Lane - TfL are proposing improvements to the existing signalised junction of the A12 and Barley Lane. This will result in improvements to pedestrian and cyclist crossing facilities and proposals intend to help traffic flow more smoothly, reduce delays

experienced by right turning traffic at the junction, and make it safer for pedestrians and cyclists to cross the road.

TfL expect to start work early in 2017.

 EL3 Bus Service - TfL are proposing the following changes to change route 387 to route EL3:

o Re-route 387 through Barking town centre along the more direct bus-only roads used by East London Transit routes, to improve journey times and reliability for passengers.

o Route 387 would be renamed EL3 making it part of the East London Transit network that uses roads with higher levels of bus priority.

o The daytime frequency of the EL3 would increase to a bus every 10 minutes on Monday to Friday.

Site Specific Transport Strategy

3.4.3 The location of Opportunity Site 46 and the existing local transport infrastructure provides any development of NEFLT Land Holding a solid basis from which to encourage sustainable travel, rather than through the use of private cars.

 A permeable layout providing convenient links to the local amenities and public transport facilities with access to the important north / south Seven Kings Cycle Path which runs through the NELFT land holdings;

 Car parking provision based on the minimum levels of LBR car parking standards as proposed within the Draft Submission Local Plan whereby we will look to ensure that parking is not over-provided but will recognise and respect that people may wish to own a car and thus ensure that adequate levels of off-street parking is provided. At least 5%of this parking stock will be suitable for people with disabilities and 20% of the stock accessible to electric charge points for the use of electric and hybrid vehicles;

 The development will provide secure accessible and sheltered cycle parking which would be conveniently located cycle parking throughout the development;

 A full Travel Plan will be prepared and implemented which will include an integrated package of measures designed to reduce the need for travel overall and to encourage uptake of more sustainable modes of transport among residents, employees, visitors and suppliers of an organisation.

 Safe vehicular access into the NELFT land holdings can be delivered from Barley Lane in accordance Atkins Local Plan High Level Transport Study assumptions with an appropriate location identified as being between Heathfield Park Drive and Gresham Drive. This new access would be designed to serve development, and has been designed as a priority junction in keeping with other similar junctions along Barley Lane. The design principles contained within Manual for Streets and Manual for Streets 2 have been utilised to guide the design. This includes providing suitable access width on entry and junction visibility splays for a 30mph road with appropriate visibility to both the north and south along Barley Lane being possible.

 Access to the southern NELFT land holdings would be through Medici Close where a right of access to the land to the rear exits and could be utilised to support development in this location.

 The ability to travel east / west using the A12 and the soon to be improved Barley Lane junction would negate the need in most instances for car based travel to use the A118 High Road where capacity has been identified as a concern.

3.5 Section Summary

 Significant investment in local transport infrastructure presents an opportunity to deliver development along the Barley Lane corridor;

 Site proposals are well progressed and these incorporate ‘best practice’ land use and transport planning principles and design.

 Increased accessibility will mitigate car based transport demands and allow reduced car parking to further support more sustainable travel choices.

 The proposed scale of the development will allow the delivery of both the necessary supporting infrastructure and mitigation but also can help to contributing to strategic objectives that can assist in alleviating other existing issues in the wider area particularly relating to transport.

 Safe access arrangements can be provided to deliver development as part of the Goodmayes Hospital proposals and also on the Goodmayes Sports Fields to the south of the allocation site.

 Access to the A12 allows for East/ West movements to be undertaken without impact on local more sensitive routes to the south.

4 Impact Assessment

4.1 Introduction

4.1.1 The ‘impact’ of a development in transport terms is ultimately driven by the external trip making patterns and demands on transport networks. The accurate forecast of demand is therefore a pre-requisite of any transport strategy or assessment. Any under-estimation of trips can result in insufficient mitigation being provided whilst over-estimation can result in the undue penalisation of potential development sites and the need to deliver over-designed mitigation and improvements.

4.1.2 The development team have previously engaged in a scoping process with officers at LBR to agree the forecasting of trips. This section of the report therefore presents the likely trip generation from a redeveloped Goodmayes Hospital and compares these to extant uses.

4.2 Goodmayes Hospital Forecast Trip Demands and Extant Trip Comparison

4.2.1 The proposals would see the change of use from an existing Hospital to a residential development. Previously scoped and accepted technical assessments pertinent to the Sunflowers Court Development and a previous proposal to redevelop the part of the site would indicate that the operational vehicular trip generation from the extant use could be significantly in excess of the number of vehicle trips that would be generated by the proposed uses.

Table 4-1 Proposed Vs Extant Trips

AM (0830-0930) PM (1630-1730) Daily Trip Generation Total 2 Total 2 Total In Out In Out In Out Way Way 2 Way Existing Goodmayes 162 12 174 8 185 193 790 875 1,665 Hospital The existing Goodmayes Hospital Trip Generation has been taken from the WSP Transport Assessment (2008) for the Sunflower Court Redevelopment

4.2.2 Given the above, the operational impact of a residential development in this location is considered to be less than the vehicular traffic impact of the extant use. A residential scheme of 500 units would be expected to generate in the region of 120 car trips in the AM peak and 100 in the PM peak which would be substantially less than those recorded through surveys of the hospital and less again if underused but consented hospital buildings were to become operational again. It is important to note that when Goodmayes

4.2.3 In addition the capacity of existing public transport services is also not considered likely to be materially affected in terms of user capacity, given any quantum of development relative to the overall residential population within the surrounding area. Further evidence and assessment will be cited through a full Transport Assessment and supporting Travel Plan to mitigate any impacts further.

4.3 Off Site Parking Impact

4.3.1 Surveys undertaken indicate that on street / off-site parking stress occurs between the hours of 09:00-14:00. Comparison with the night time surveys also undertaken and with reference to the on-site surveys would indicate that much of this on street stress could be associated with the daytime hospital uses. The removal of these uses and the provision of suitable on site car parking would result in a better and less parked external environment.

4.4 Section Summary

 The operational vehicular trip generation from the extant use would be significantly in excess of the number of vehicle trips that would be generated by the proposed uses.

 Significant public transport services would accommodate increased demands without material impacts.

 Some betterment would be realised as a result of reduced off site car parking stress.

 In summary, it is not considered that there will be any significant transport impacts that cannot be mitigated satisfactorily and that the scale of the development is not significant in the context of the existing road and transportation infrastructure within the vicinity of the site.

5 Deliverability

5.1 Site Control & Willingness to Develop

5.1.1 The site is controlled by NELFT who is willing to facilitate development at the Goodmayes Hospital site at the earliest opportunity subject to planning.

5.1.2 The site has been subject to numerous pre-planning studies and assessments and an Illustrative Masterplan for land within NELFT’s ownership has been developed.

5.1.3 The integration of the proposals with the other areas of Investment and Growth Area LP1B will be a key opportunity of the detailed proposals for the site.

5.2 Infrastructure Investment Opportunity

5.2.1 There are a number of aforementioned committed Transport schemes in the local areas which will support the site and further strengthen the sites deliverability. These are:

 Crossrail

 The A12/Barley Lane junction improvement scheme

 The EL3 Bus Route

5.2.2 An outline planning submission could be made during 2017 and development could be commenced by 2017/18 which indicates the particular ease of delivery of this site. These timings would also ensure consistency with the Council forecast for the delivery of the site between 2015-2020.

6 Summary Critique of Local Plan Conclusions

6.1 Summary

6.1.1 This report has been prepared to inform and provide evidence to support the representations on the draft Local Plan on behalf of NELFT for redevelopment of Goodmayes Hospital and the surrounding land.

6.1.2 The draft Local Plan prepared by LBR indicates that the King George and Goodmayes Hospitals site is suitable for 500 dwellings. PBA, on behalf of NELFT, have considered and tested the clients proposals against the requirements set out and we summarise the findings as follows:

 The network can accommodate in excess of 500 units with the measures that have been identified and achievable as part of the development.

 NELFT land holdings can deliver 500 units. Therefore, with the number of units that can be provided on BHRUT land, the allocation for Opportunity Site 46 has the potential to provide in excess of the 500 units stated within the draft Local Plan.

 The high quality and advanced masterplan for Goodmayes Hospital incorporates best practice land use and transport planning with emphasis will placed on making journeys by modes other than the private car.

 The site presents opportunities to provide more sustainable journey patterns to and from the local area. Additional strategically important walk and cycle connections can also be explored.

6.1.3 Given the above, PBA consider that in transport terms the redevelopment of Goodmayes Hospital and surrounding land as part of Opportunity Site 46, as shown on the Masterplan in Appendix A, is an entirely suitable location to assist meet the councils strategic housing requirements.

Appendix A Goodmayes Hospital Illustrative Masterplan

J:\34167 Goodmayes Hospital\Reports\Transport\Local Plan Reps \Transport Note for Local Plan Reps_FINAL.docx King George Hospital

C B

e l r

l F D

Extent of NELFT Ownership E

Proposed Residential Site: With Illustrative Masterplan A 8.39ha (250-300 Units 30-36dph)

Proposed Retained B/F Health Use F Existing Sports Field/ C Ground Source Heat Pump

Proposed Residential Site: Indicative Capacity 4.04ha D (200 Units 57dph) Exc Flood Zone

E Existing Allotments

Goodmayes Hospital NELFT Plan B - Illustrative Masterplan Site Plan 1:2500 @ A3 Technical Response – Transport & Accessibility Local Plan Representations Goodmayes Hospital

Appendix B Crossrail Corridor Investment and Growth Area

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Technical Response – Transport & Accessibility Local Plan Representations Goodmayes Hospital

Appendix C Location Plan of High Level Study Opportunity Sites

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