LASALLE INVESTMENT MANAGEMENT 669 Reading Borough Council Pre-Submission Draft Local Plan November 2017 Representations Form Please return by Friday 26th January 2018 to: Planning Policy, Civic Offices, Bridge Street, Reading, RG1 2LU or email [email protected] PART A – YOUR DETAILS Personal Details Agent’s Details (if applicable) Title Mr First Name Robert Last Name Davies Job Title (if Partner applicable) Organisation (if LaSalle Investment Gerald Eve LLP applicable) Management Address 1 c/o agent 72 Welbeck Street Address 2 Address 3 Town London Post Code W1G 0AY Telephone 020 7333 6207 E-mail [email protected] PART B – YOUR REPRESENTATION (please use a separate form for each representation) B1. To which part of the Local Plan does this representation relate? Draft Local Plan Policy CR16 B2. Do you consider that the Local Plan: (please tick as appropriate) Is legally compliant? Yes x No Is sound? Yes No x Fulfils the duty to co-operate? Yes x No B3. Please provide details of why you think the Local Plan, or part of the plan, is or is not legally compliant, sound and/or complies with the duty to co- operate. Our client controls the site at 15-18 Friar Street, 2-16 Station Road and Harris Arcade. As such our client’s previous representations, submitted on 13 June 2017, in response to the Reading Borough Council’s (RBC) Draft Local Plan in respect of 15-18 Friar Street, 2-16 Station Road and Harris Arcade (‘the site’) still stand. Draft Local Plan Section 5 – Strategy for Central Reading / Station/River Major Opportunity Area / Draft Local Plan Policy CR11(a) and (b) We continue to support RBC’s wider strategy for Central Reading as set out in the Draft Policy CR11(a) and (b) and in particular support the objectives to significantly improve the wider station area as a gateway into a vibrant and successful town centre. LaSalle welcome the acknowledgement that large parts of the area are currently low density and that there is some inefficient uses of one of the most accessible locations in the South East (paragraph 5.4.1). At paragraph 5.2.15 it is stated that there is “undoubted physical capacity within the centre to incorporate a significant level of new development, by efficient use of underused land through carefully developing at higher densities”. This statement is fully supported along with the conclusion at paragraph 5.4.4 that “in order for the station area to become a destination in its own right, it should contain a wide mix of uses across the area”. The Policy Approach to Draft Policy CR16 Our client’s site is approximately 0.34ha and is comprises the majority of the draft designated ‘Area to the north of Friar Street and east of Station Road’, referenced within Draft Policy CR16. The extent of the landholdings is shown on the attached plan. Not Positively Prepared The Pre-Submission Draft of the Local Plan does not properly address the identified local development requirements at the site. According to the NPPF, in order to be thought of as ‘positively prepared’ the plan should seek to “meet objectively assessed development and infrastructure requirements…” The Local Plan as currently prepared would fail to deliver the significant level of development for which there is an acknowledged capacity and requirement, in Central Reading. This is because Draft Policy CR16 as drafted precludes ‘wholesale redevelopment’ within the ‘Area to the north of Friar Street and east of Station Road’, a key central development site. The site as existing comprises a mix of retail and main town centre uses (including leisure and drinking establishments) and is located immediately adjacent to the Station/River Major Opportunity Area boundary. The western side of Station Road, opposite the site, is included within Policy CR11a and is identified as a Site for redevelopment as set out above. The western side of Station Road is also the boundary of the Station Road Tall Buildings Cluster area where buildings of 10 storeys and above would be considered. It is recognised that the landholdings within Draft Policy CR16 are unlikely to accommodate tall buildings, although the policy ought to recognise that in accordance with good design principles there may be opportunities to make better use of parts of the site. Station Road is identified as an essential north-south link where a high quality public realm is vital to integrating the Station Area with the existing shipping core. In recognition of this, we support the cluster of small local businesses within the Harris Arcade and seek to enhance the fine-grain retail offer through comprehensive consideration of development opportunities. In addition, Friar Street is included within the Friar Street Business Improvement District which includes the main retail, financial and night time economy uses. Massing It is considered that the existing Site represents an opportunity for a phased redevelopment. A redevelopment scheme would have the potential to increase the efficiency of the site through careful and well considered increase in density as part of comprehensive proposals that consider the individual components, but also the site as a whole. Additional development across very low density parts of the site could be explored subject to good design and appropriate consideration of the townscape. It is recognised that County House provides a very strong element of the overall massing at the crossroads. It is considered that there is potential for at least, an extension into the service yard off Winston Terrace and for additional height, and massing to the predominantly single storey western part of the site. Uses The Site is located within the RCAAP which will be “promoted and maintained as a top-class location for business, retail, leisure, culture and learning… the focus for continued high class mixed use development”. It is therefore considered that the Site represents an opportunity for redevelopment for a range of uses with active frontages on the ground floor and a mix of uses on the higher floors. In our view, a broad range of uses could be explored for the site, as follows:- a. Retail and main town centre uses (including leisure and drinking establishments) as the Site is in the Primary Shopping Area, Central Core and an Active Frontage location; b. Hotel uses – as the Site is in the Central Core with the Central Area identified as the prime focus for major leisure, cultural and non-regionally significant tourism development; c. Office use – as the Site is in the Office Core; d. Student Accommodation given the accessibility to higher education and further education institutions in terms of walking, cycling and accessibility of all town centre bus services; e. Residential use in accordance with town centre aspirations. Therefore the document is unsound as it fails to maximise the development potential of the ‘Area to the north of Friar Street and east of Station Road’. Please continue on another sheet if necessary B4. Please set out the modifications that you think would make the Local Plan, or part of the plan, legally compliant and/or sound. Please provide specific wording where possible. RBC should reconsider its Local Plan. There is a clear opportunity for positive and significant development at the site to deliver vital town centre uses to Central Reading, a need and capacity for which RBC acknowledge at paragraph 5.2.15. The Local Plan as drafted would preclude such levels of development and is overly restrictive. The following wording is suggested for Draft Local Plan Policy CR16: “The function of the area east of Station Road and north of Friar Street, as shown on the Proposals Map, makes a positive contribution to the character of the town centre. Where possible, development proposals should seek to enhance and sustainT the character of the retail units within the Harris Arcade and the buildings fronting the streets will be conserved and, where possible, enhanced. Whilst Tthere will beis potential for some the conversion of buildings and , potentially, some development within the site that does not detrimentally affect its overall character., Pproposals for wholesale comprehensively considered redevelopment and enhancement of the area will not be supported as a positive opportunity to contribute to the mix of uses within this part of the town centre, in the context of wider town centre policies and other material considerations.” Please continue on another sheet if necessary B5. If you are seeking a modification to the plan, do you wish to appear in person at the public examination? Yes x No B6. If you wish to appear in person, please briefly outline why you consider this necessary. To enable the Planning Inspector to fully understand the key reasons why our requested amendment to the Local Plan is required to make the plan ‘sound’ and to facilitate a thorough examination of the issues. B7. Do you wish to be kept informed of planning policy matters? (please tick as appropriate) Please keep me informed of the progress of this Local Plan: x Please keep me informed of all planning policy matters: x Friar Street, Station Road and Harris Arcade Reading RG1 Posts C y c le H i re S ta t io n 43.9m TCBS 1 s 4 r o e t t l e 7 Statue h 3 S Shelters 42.5m 4 9 t o 5 1 5 STREET 3 GARRARD 5 3 Aquis House 3 2 3 4 0 0 o PH t 7 3 9 2 El Sub Sta PH 1 8 7 1 H I 2 c s t B o 1 r o o o t 6 u e L t n 4 l s A 7 S 1 e e 1 G T ection h S A R 1 3 ast T 4 3 A E I V O E N to 29 1 S 5 2 R 1 T O R 3 E A 1 1 E D 0 7 T 17 1 1 1 2 1 0 1 1 1 1 4 1 5 1 o 6 t 8 9 H 7 5 8 a 1 r r o i t s A 9 7 r c 5 6 a 2 d 3 e 3 6 7 o t 4 2 4 W 4 I S T O 3 1 N T E El Sub Sta a R 5 R 2 1 A otel 6 H C 20 P E to 25b 25a to 23 22 16 to 18 15 TCBs 12 to 14 PH 11 6 Shelters Shelter 5 4 FRIA Posts R STR 1 E 4 4 5 4 1 4 6 1 E 1 4 3 1 4 T 2 1 4 8 1 4 9 0 5 1 3 5 1 5 5 1 6 5 1 8 5 1 9 5 1 7 4 1 1 3 8 t o Shelter LB 1 2 PH 3 1 6 1 3 6 5 1 2 6 t 1 r 4 5 u o 1 7 C 1 t o t e 4 e 7 f 6 i 1 1 e F r 0 t S 9 1 t a i 2 e 7 r e 1 o r t t 1 c i 1 S 4 V s s n 1 o e r 1 e C u 1 6 Q 4 1 2 E 0 6 9 l 1 1 1 S 3 u 2 b t o 0m 10m 20m 30m 2 1 S 2 2 t 3 a 3 2 2 4 Ordnance Survey © Crown Copyright 2017.