Your ref: Our ref: SM/ncb DD: 01245 505071 E: [email protected] Date: 30/09/2016 Planning Policy Team Redbridge Local Plan 2015-2030: Pre-submission Draft London Borough of Redbridge Freepost RSLR-JACE-HSUG Ilford IG1 1DD Dear Sir/Madam REDBRIDGE LOCAL PLAN 2015 - 2030: PRE-SUBMISSION DRAFT CONSULTATION REPRESENTATIONS SUBMITTED ON BEHALF OF BARKING, HAVERING AND REDBRIDGE (UNIVERSITY HOSPITALS) NHS TRUST REGARDING LAND AT KING GEORGE HOSPITAL I am writing on behalf of Barking, Havering and Redbridge (University Hospitals) NHS Trust (‘BHRUT’) in response to the Council's consultation on above. Bidwells is acting on BHRUT’s behalf to promote surplus land within its control at King George Hospital, Goodmayes. These representations relate to policy LP1B and the Crossrail Corridor Investment and Growth Area (CCIGA). BHRUT fully supports policy LP1B’s proposed removal of its surplus land at King George Hospital from the Green Belt and its proposed allocation for housing led development. BHRUT is, however, seeking to secure some amendments to draft policy LP1B, primarily to minimise risks to its deliverability and effectiveness. It is therefore submitting objections on matters of detail as set out below. The surplus land at King George Hospital is identified in the Conceptual Masterplanning Study (CMS) accompanying these representations. The CMS has been prepared to illustrate how surplus parts of the site could come forward and test their capacity. It has taken account of the constraints of the site and estimates that circa 190 dwellings could be delivered on surplus land to the north and east of the existing Hospital buildings, which are to be retained for healthcare use for the foreseeable future. The principle constraints of the site, including the proposed designation of part of it as a Site of Importance for Nature Conservation (SINC), have been analysed via the submitted Ecological Appraisal and Transport Statement and taken account in the CMS. The CMS provides an initial review to support the Local Plan process and there may be potential for further development capacity when the site is fully tested as part of a planning application. Taking account of the acute need for new housing and other forms of development that the Council is seeking to address via the emerging Local Plan, this site offers an exceptional opportunity to address housing needs whilst releasing redundant public sector land for development and raising capital for reinvestment in NHS services. BHRUT submitted representations to the Council's consultation on its 'Core Strategy Review – Preferred Options Report' in February 2013 and ‘Preferred Options Extension – Alternative Strategies’ in December 2014. These representations identified land surplus to healthcare requirements and available Saxon House, 27 Duke Street, Chelmsford CM1 1HT T: 01245 250998 E: [email protected] W: bidwells.co.uk Bidwells is a trading name of Bidwells LLP, a limited liability partnership, registered in England and Wales with number OC344553. Registered office: Bidwell House Trumpington Road Cambridge CB2 9LD. A list of members is available for inspection at the above address. Redbridge Draft Local Plan: Preferred Options Extension – consultation on Alternative Development Strategies for alternative forms of development. The land was also put forward to the London-wide Strategic Housing Land Availability Assessment (SHLAA) 'call for sites' undertaken by the Mayor in conjunction with the London Borough's in January 2013 and June 2016. Availability of land for development at King George Hospital BHRUT's freehold ownership at King George Hospital extends to almost 17 hectares, a significant proportion of which is surplus to NHS requirements. The availability of the land for non-healthcare uses was confirmed by BHRUT’s approved Estates Strategy for the period 2014 to 2019. Most of this land has been redundant for some time but could not be released for development due to current planning policy constraints. The Estates Strategy is set in the context of the wider Health for North East London (Health4NEL) Review and BHRUT's adopted Clinical Strategy. Neither anticipate the development of any surplus land at King George Hospital for new healthcare services in the foreseeable future. Indeed, as a consequence of the changes proposed to local service provision by Health4NEL and the Clinical Strategy, which focus on the transfer of acute care and emergency services to BHRUT’s principal service centre at Queen's Hospital in Romford, a substantial reduction in services located at King George Hospital is anticipated. Relationship with Goodmayes Hospital site BHRUT does not own or control land at Goodmayes Hospital which lies directly to the south of King George Hospital and forms part of the joint allocation for development proposed by draft policy LP1B. North East London NHS Foundation Trust (NELFT) owns the freehold of 18 hectares of land at Goodmayes Hospital. The extent of this land will be identified in separate representations submitted by NELFT. Although the ownership of both sites falls under the overarching NHS ‘banner’, King George and Goodmayes Hospitals are owned by separate NHS Trusts which have separate management structures and decision making processes. Indeed, NELFT is a Foundation Trust with greater decision making freedoms than BHRUT. Our representations therefore seek to ensure that either site could come forward independently of the other, providing that a coordinated approach is taken to their development, to ensure that both sites can make a valuable contribution to housing land supply as early as possible in the Plan period. Suitability of surplus land at King George Hospital for development BHRUT fully supports the Council’s vision for the Crossrail Corridor Investment Area (CCIGA) and agrees that it presents a significant opportunity for the delivery of new homes, jobs and social infrastructure. The surplus land at King George and Goodmayes Hospitals is ideally placed to make an important contribution to this objective. The Green Belt reviews commissioned by the Council to support the emerging Plan confirm that the sites occupied by King George and Goodmayes Hospitals no longer serve the purposes of including land within the Green Belt and should therefore be removed from its designation. The latest Green Belt Review undertaken by Wardell Armstrong in January 2016 notes that the site: “does not prevent sprawl nor does it prevent the merging of local centres as it is surrounded by development at all sides. Furthermore, its physical and visual connection to…the wider Green Belt is weak due to the presence of the A12 and the urbanised nature of the hospital site. In that regard it does not safeguard the countryside from encroachment. The western and southern parts of the parcel can be considered locally important open space, particularly Fords Sports Page 2 Redbridge Draft Local Plan: Preferred Options Extension – consultation on Alternative Development Strategies Ground; Goodmayes Hospital Sports Ground; Seven Kings Park; and Barley Lane Allotments. These spaces also help to retain the biodiversity of the area. The hospital site is urbanised in character and does not meet any Green Belt purpose.” (p28). BHRUT fully supports this conclusion. It is clear from the evidence base supporting the emerging Plan that there are acute planning challenges facing the Borough, primarily as a consequence of the considerable rise in population that is projected to continue and an undersupply of new housing over recent years. The Council is to be commended for facing up to this challenge and seeking to plan positively for the needs of the Borough. It is clear that there are no easy answers to the challenges arising, but it will be essential to grasp the opportunities presented by the potential development of sites in the CCIGA that no longer serve the purposes of the Green Belt to seek to address the Borough’s objectively assessed housing and development needs. King George Hospital is in a sustainable location close to existing services, employment, schools and public transport connections, as explained in detail in the accompanying Transport Strategy. Furthermore, there is significant potential for the sustainability of the site to be enhanced by the impending arrival of Crossrail services in 2019. Nevertheless, it already has a PTAL rating of 2 where the London Plan’s Density Matrix suggests that development at between 45-170 dwellings per hectare (dph) is appropriate for 'urban' locations. BHRUT would urge the Council to maximise the opportunity presented by the site to address objectively assessed housing and development needs and commends the parts of draft policy LP1B which seek to achieve this. BHRUT has commissioned the submitted Conceptual Masterplanning Study and supporting Ecological Assessment and Transport Strategy to analyse the constraints of the King George Hospital site, test its minimum capacity and demonstrate its deliverability. The CMS has been prepared in consultation with NELFT, which has prepared its own capacity study to support its separate representations. The CMS concludes that the development of around 190 dwellings to the north and east of the existing hospital buildings is feasible as a minimum, with further potential available through intensification of residential and healthcare uses and development of other parcels of land to the west. NELFT’s estimate of capacity at Goodmayes Hospital is at least 500 dwellings. It is therefore clear that the sites have capacity to achieve the amount of development anticipated by draft policy LP1B and potentially to significantly exceed it. Changes required to policy LP1B to make the Plan sound Whilst BHRUT supports the overarching objectives of the proposals for the CCIGA and policy LP1B, it is raising objections to certain elements of it, as follows: ● The policy requires “around” 500 dwellings to be developed across the two sites, but the capacity studies undertaken by BHRUT and NELFT suggest that they may have potential for significantly more development. The policy requirement for “around” 500 dwellings may artificially restrict the contribution that the sites can make to housing delivery.