Watford Junction Draft Development Brief

Showing comments and forms 1 to 30 of 171

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 449

Received: 02/09/2016

Respondent: Network Rail

Representation:

Network Rail would comment as follows:

Network Rail supports the principal of a council led regional regeneration proposal as previous commercially led property developer proposals made to Network Rail have appeared unviable. The masterplan includes railway operational land which Network Rail recognises may need reconfiguration and protection as part of a council sponsored scheme. If the council proceeds to use CPO powers to enable the masterplan then, as is normal procedure, Network Rail may object to the CPO seeking a Deed of Undertaking whereby the objection is withdrawn in return for the council's agreement to necessary railway protections.



Full text:

Watford - Draft Watford Junction Development Brief



Thank you for the opportunity to provide feedback to the proposed policy.



Network Rail is the public owner and operator of Britain's railway infrastructure, which includes the tracks, signals, tunnels, bridges, viaducts, level crossings and stations - the largest of which we also manage. All profits made by the company, including from commercial development, are reinvested directly back into the network.



Network Rail would comment as follows:



Network Rail supports the principal of a council led regional regeneration proposal as previous commercially led property developer proposals made to Network Rail have appeared unviable. The masterplan includes railway operational land which Network Rail recognises may need reconfiguration and protection as part of a council sponsored scheme. If the council proceeds to use CPO powers to enable the masterplan then, as is normal procedure, Network Rail may object to the CPO seeking a Deed of Undertaking whereby the objection is withdrawn in return for the council's agreement to necessary railway protections.



Object

Watford Junction Draft Development Brief 2016

Representation ID: 452

Received: 07/09/2016

Respondent: Mr Grant Wray

Representation:

(1) The plan self-contradicts regarding education school use
(2) No detail whatsoever regarding bus interchange
(3) No detail whatsoever regarding passenger drop off / pick up
(4) No detail regarding congestion issues at the front of the station
(5) Pedestrian boulevards across the site do not connect extensively or logically

Watford Junction is a travel hub, yet the document only focuses on the built-environment. There is a real danger that potential future travel changes will be prohibited by the development, e.g. dedicated bay platforms for shuttles to OOC hub. No infrastructure safeguard zones.

Full text:

(1) The plan self-contradicts regarding education school use
(2) No detail whatsoever regarding bus interchange
(3) No detail whatsoever regarding passenger drop off / pick up
(4) No detail regarding congestion issues at the front of the station
(5) Pedestrian boulevards across the site do not connect extensively or logically

Watford Junction is a travel hub, yet the document only focuses on the built-environment. There is a real danger that potential future travel changes will be prohibited by the development, e.g. dedicated bay platforms for shuttles to OOC hub. No infrastructure safeguard zones.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 453

Received: 07/09/2016

Respondent: Mr Chris King

Representation:

It is my understanding that you wish to develop Watford Junction and build 20 storey block of flats all over the shop. The country voted Brexit precisely because the government has let in more people than we have properties for. I completely oppose any such development, especially 20 storey high ones. It is 2016 not the 1970's. If the government let in more people than they have properties for, then I shouldn't have to deal with the consequences. What a mess.......

Full text:

It is my understanding that you wish to develop Watford Junction and build 20 storey block of flats all over the shop. The country voted Brexit precisely because the government has let in more people than we have properties for. I completely oppose any such development, especially 20 storey high ones. It is 2016 not the 1970's. If the government let in more people than they have properties for, then I shouldn't have to deal with the consequences. What a mess.......

Object

Watford Junction Draft Development Brief 2016

Representation ID: 454

Received: 07/09/2016

Respondent: Mr D Holden

Representation:

Plans are massive over development which will impact on the town's character.

Full text:

Excellent idea to redevelop Watford Junction, which is much needed. However the plans provided are a massive OVER development of the site and ensures this part of Watford loses all town character
The plans shows mass building of ugly tower blocks - particlarly flats which are totally unnecessary for this area
Much better a smaller/cheaper development of well designed retail, car parks, good travel communication and some sensitive planning of office space.
Back to the drawing board please.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 455

Received: 07/09/2016

Respondent: Miss Angela Simpson

Representation:

Parking impacts from the development

Full text:

Have misgivings regarding the height of the buildings and housing 3000 in the area. Parking nearby would be a nightmare for existing residences unless there is underground parking for the buildings.
Watford Junction needs expanding for pedestrians as well as vehicles

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 456

Received: 07/09/2016

Respondent: Mr Michael Foot

Representation:

Traffic and road safety impacts on Radlett Road

Full text:

I am concerned that in section 2.7 Movement Hierarchy - traffic will be using Imperial Way and Colonial Way and the impact on Radlett Road.

What consideration has been made as to the effect on Radlett Road of these proposals. ?

How will Heavy commercial traffic be stopped or discouraged from using Radlett Road and Balmoral Road, where there is a school and a heavily used recreation park ?

Radlett Road is already used as a rat run by vehicles which consistently ignore the speed limit

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 457

Received: 07/09/2016

Respondent: Mr Nigel Kavanagh Brown

Representation:

Station development clearly required and must form major part of proposal.

Full text:

Station development clearly required and must form major part of proposal. Ensure adequate car drop-off / pick-up: I live on Hempstead Road, have no direct bus to station. Do not count on Abbey line conversion to light rail. Not convinced about need for high-rise buildings.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 467

Received: 08/09/2016

Respondent: Hertfordshire Constabulary

Representation:

Active edges overlooking public realm and appropriate CCTV required.

Full text:

Would look for active edges of buildings overlooking the public realm with appropriate defensible space, and for public realm to have appropriate CCTV coverage including the new proposed bridge over the railway line.
2.8 Car Parking - says about two decked parking areas next to the railway station. I would look for these to meet and achieve the safer parking award so as to reduce crime.
I would also look for all residential and office underground car parking to be secure with access control.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 468

Received: 08/09/2016

Respondent: Mr Ian Curran

Representation:

There is not enough reference given to secure cycle parking and improved provision for cycle infrastructure is required. Much more emphasis is needed on creating direct and safe routes for cycling and increased and secure parking for them.

Full text:

Currently more than 150 cycles are parked daily at the station despite difficult congested access roads and poor parking provision. Improved provision for cycling and cycle parking is mentioned in only two sentences in the plan with no indication or quantification of what should be provided and where. Improved car access and parking is covered comprehensively and will increase car use, congestion and air pollution in Watford generally. Much more emphasis is needed on creating direct and safe routes for cycling and increased and secure parking for them.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 469

Received: 13/09/2016

Respondent: Mrs Seema Rushton

Representation:

Some more shops in the station would be helpful.

Full text:

I would really welcome these plans to Watford junction. I live on the reeds estate and having some more shops around the station would make it much easier to pick up food on my way home. Additional things I would like to see is the removal of the additional fee to use Watford junction station when travelling to London. Why should we have to pay a supplement when users at Watford high street don't have to pay for this? Otherwise the service is generally good, it just costs a fortune!

Object

Watford Junction Draft Development Brief 2016

Representation ID: 472

Received: 17/09/2016

Respondent: Mr Richard Lally

Representation:

Watford Junction is busier than ever and will be even busier when the long awaited Croxley extension is finally complete.
It makes no sense to build thousands of new homes nearby if the station remains unfit for purpose!

Full text:

Watford Junction is busier than ever and will be even busier when the long awaited Croxley extension is finally complete.
It makes no sense to build thousands of new homes nearby if the station remains unfit for purpose!

Object

Watford Junction Draft Development Brief 2016

Representation ID: 477

Received: 27/09/2016

Respondent: Mr Jamie Thompson

Representation:

The development makes no allowance for the provision of more platforms and lines which is a necessity due to current and future capacity issues. Comprehensive suggestions and plan drawings have been provided detailing potential solutions.

Full text:

The primary purpose of a rail station is to provide capacity for passengers to access trains. Watford Junction is a major hub severely hampered by constraints on the wider rail network, but any redevelopment must provide for growth when these are removed lest Watford become a permanent bottleneck.

My primary objection is that the development seems to make no allowance for the provision of more platforms or lines. Given the dangerous levels of overcrowding the station already experiences, provision of more platforms is a necessity now, let alone after HS2 opens and more fast services will be able to serve the station. Consider also that with the Metropolitan Line extension, a potential Crossrail branch, improvements to the Abbey Line, as well as the increased demand from the redevelopment itself, the fact that the station platforms are already at capacity during the peaks means that more capacity will definitely be required moving forward.

As an illustrative example, conversion of platform 10 to another standard through platform would enable services to a) overtake if needed, b) terminate in platform 9 without any capacity-reducing conflicting movements, and c) would enable services from the north to be terminated and turned back in times of disruption.

As another example, today, fast services barely stop at Watford Junction due to capacity constraints - the fast lines have to serve Euston to Liverpool, Manchester and Glasgow, and all major stations between, and stops at Watford reduce the number of trains that can operate. Once HS2 opens, the case for more fast line stops at the major stations between Birmingham and Euston will greatly increase, we are likely to see regular services between Birmingham and Euston serving Watford, Bletchley, Milton Keynes, Rugby, Coventry etc. These will require more platforms as well, and as Iveco House/The Junction isn't going anywhere any time soon, this could be achieved by adding new capacity on the eastern side of the station, giving the fast lines use of platforms 6, 7, and 8, with the slow lines then using platform 9 and new through platforms 10 & 11.

Having 3 platforms for both the fast and slow services would be a massive improvement, but to really future-proof the station and to cater to the ambition for the town we all share, the construction of another full island platform on the east side of the station would enable, with the other works listed above (and the redevelopment of Iveco House/The Junction to restore platform 5 as a through platform), 8 platforms - 4 for the slow lines, and 4 for the fast lines (or 3 fast line platforms without the platform 5 works). Services would be able to arrive into a platform as the previous service was still departing, increasing capacity massively, and increasing the time services could dwell, improving the ability for passengers to switch trains.

The primary impact to the plans you have produced is that the buildings alongside the railway will need to be altered to enable this work to happen in the future when required. Looking at the plans, I believe these to be 21, 13, 16A, 16C.

I also note that the plans make no consideration for re-routing the Abbey line back along its original alignment. It was rerouted to its current alignment to increase the level of car parking available without requiring a crossing at the cost of making the interchange much, much worse, and as this car parking is now going to be redeveloped the opportunity to restore the interchange presents itself once more by moving the Abbey Line platforms back closer to the mainline platforms. The Abbey Line is an essential heavy-rail link and has a lot of potential for regional growth (i.e. a short connection to the proposed Radlett freight facility would open a great deal of rail freight options), so conversion to light rail is not a viable proposition and the plans have to consider the best way to deal with a standard rail line passing through the development site whilst retaining the ability for expanding it in the future to a full double track line.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 478

Received: 18/09/2016

Respondent: Mr Jamie Thompson

Representation:

The masterplan proposals provide no consideration to improving station capacity, they must be altered to enable the railway to grow. This particular to relates to additional platforms capacity.

Full text:

The primary purpose of a railway station is to enable passengers to change trains. Watford Junction is a major station that is hampered by both the capacity available from its infrastructure as well as wider network constraints. Those network constraints however are going to be greatly reduced once HS2 opens, and this unlocks the opportunity to remove the constraints at Watford Junction and unleash its full potential.

The masterplan proposals, as they stand, provide no consideration to improving the railway station's capacity, hemming the railway within its current boundary. They must be altered to enable the railway to grow - mainly by adding more platforms, but also by improving the safety of the station by widening the existing platforms to handle the dangerously larger crowds that are so prevalent.

Few fast services currently stop at Watford Junction due to the network constraints of having to provide capacity to serve Birmingham, Liverpool, Manchester and Glasgow. Every train that stops at Watford Junction means less trains can run on the fast lines, so it's understandable why Watford stops have been reduced to nearly nothing over the years as trains speeds have increased.

HS2 changes all of this though, there will suddenly be capacity to run fast services calling at all of the regional major stations once again: Euston, Watford, Leighton, Bletchley, Milton Keynes, Rugby, Coventry, Birmingham, etc., unlocking connectivity and growth across the region.

To maximise the benefits of this, additional platforms at Watford Junction will a) enable more services to call, b) those services to dwell longer without impacting capacity or safety, improving the passenger interchange experience, and c) they provide flexibility in operational matters: i.e. overtaking, managing disruption, etc.

There are 3 opportunities to add platforms at Watford Junction, each requiring more of the master plan to be altered than the previous.

The first is to reinstate platform 5 as a through platform. This requires Iveco House to be altered, or more likely demolished.

The second is to rebuild platform 10 as a through platform. This provides the slow lines with three platforms, which means the terminating services from the south can use platform 9 without any conflicting movements as they will not have to cross the southbound line. It also means services can terminate from the north if required, as well as overtake services serving a platform.

The third and final stage is the construction of a new island platform alongside platforms 9+10. This along with the other works would provide 8 platforms, thus enabling the fast and slow lines to both have 4 platforms, two in each direction.

The track alignments required for this mean that some of the buildings in the plan need to be altered or removed. I believe that 21 would require the loss of the buildings alongside the railway, 13 would require some alterations to the southern end, and 16A and 16 C would be lost, though enlargement of 16B would enable most of the capacity to be maintained. I have taken the liberty of making some annotations to a diagram taken from the document to illustrate my concepts and attached it to my representation. The illustration assumes no platform widening, and would obviously alter accordingly should that be factored in.

One final point is that concerning the St. Albans branch line (the "Abbey Line"). The line as it stands cuts through the development, creating a barrier. The report raises the conversion of the line to light rail once again, but it is essential that the line is retained as a heavy rail link as its potential uses in that regard are far higher than is widely considered, i.e. a connection to the proposed Radlett freight facility would give heavy rail access to the line through Watford, connections to the Midland line could give access to City station, and similar works could give access to Hatfield should the disused rail route be reinstated.

I would like to ensure that consideration has been made to investigate whether burying the line underground in a shallow tunnel through the development has been investigated. Doing so would remove the barrier, but would also facilitate the future connection of the line through to the London Overground tracks on the opposite side of the station in the future, creating a single through route which would be far more efficient to operate more frequently than the current branch shuttle, and far more usefully than conversion to light rail.

Orphanage Road is the primary obstacle to this as any tunnel would need to pass beneath this road, necessitating some challenging gradients. Given the scope of the master plan, I would like to know if consideration been made to replacing the link that Orphanage Road provides with a new route through the development. Failing that however, new underground platforms at Watford Junction could be located far closer to the mainline platforms, greatly improving the passenger experience and promoting use of the line.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 480

Received: 19/09/2016

Respondent: Mr John Snell

Representation:

It is unreasonable to expect comment to be made on the many complex issues raised in just 100 words. Is the option to write a WORD file and upload that as an attachment? JCS

Full text:

It is unreasonable to expect comment to be made on the many complex issues raised in just 100 words. Is the option to write a WORD file and upload that as an attachment? JCS

Object

Watford Junction Draft Development Brief 2016

Representation ID: 485

Received: 22/09/2016

Respondent: R Kowalewski

Representation:

In agreement with this, and to use this land for this new homes

Full text:

The development is trying to squeeze too much into too small an area. Numbers need to be reduced. See attached letter

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 491

Received: 18/09/2016

Respondent: Mr David Bryett

Representation:

Watford station in that there is a highly valuable rail freight facility which should be safeguarded and not fall to Development

Full text:


I would like to respond on Watford station in that there is a highly valuable rail freight facility which should be safeguarded and not fall to Development.
The site is connected to the West Coast Main Line which makes it a major asset with the connection alone worth circa £7 million as that would be cost of a new facility.
A worst case scenario should be that a teammate's facility is provided close to Watford area within 5 miles

Support

Watford Junction Draft Development Brief 2016

Representation ID: 492

Received: 02/09/2016

Respondent: Network Rail

Representation:

Supports principal of a council led regional regeneration proposal.

Full text:

Thank you for the opportunity to provide feedback to the proposed policy.
Network Rail is the public owner and operator of Britain's railway infrastructure, which includes the tracks, signals, tunnels, bridges, viaducts, level crossings and stations - the largest of which we also manage. All profits made by the company, including from commercial development, are reinvested directly back into the network.
Network Rail would comment as follows:
Network Rail supports the principal of a council led regional regeneration proposal as previous commercially led property developer proposals made to Network Rail have appeared unviable. The masterplan includes railway operational land which Network Rail recognises may need reconfiguration and protection as part of a council sponsored scheme. If the council proceeds to use CPO powers to enable the masterplan then, as is normal procedure, Network Rail may object to the CPO seeking a Deed of Undertaking whereby the objection is withdrawn in return for the council's agreement to necessary railway protections.
Additionally, on land beside the car park owned by HSBC Pensions Network Rail are aware that there may be an upcoming planning application. Network Rail would ask the LPA to notify us of any such proposal to determine if the proposal is consistent with Watford's masterplan and the access the masterplan offers the station.
Please ensure that the notification is sent to the usual planning application address - TownPlanningLNW@networkrail.co.uk

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 493

Received: 13/09/2016

Respondent: Watford and West Herts Chamber of Commerce

Representation:

Sees the plan as a potential opportunity loss to establish a significant expansion to office and industrial workspace. This is needed given pressures elsewhere as it is key to retain local employment.

Full text:

In respect of the proposed plans for Watford Junction we circulated our membership asking them to submit any individual comments they may have over the development plans.

At the same time I have been getting a more general opinion from local business as part of my ongoing business communication / visit programme.

Members have not particularly raised specifics about the plan, rather a general disappointment of the potential loss an opportunity to establish a significant expansion to office and industrial workspace.

Whilst the need for a mixed use development is understood it was felt that these plans do not fully reflect the amount of commercial accommodation already lost / under threat by conversion to residential, particularly in and around the Clarendon Road area.

It is no good having housing if we cannot attract and retain local employment. I have spoke to a number of businesses who have concerns that the town will not be able to accommodate their future growth plans, plus is there sufficient new commercial development on the site to attract new companies from other areas. Conversion of existing unsuitable empty office space to residential is OK if it is replaced by new space designed to accommodate the needs of business in the 21 century.

Watford Junction has the potential, with its exceptional location & transportation links, to become a major regional business hub and there is a feeling that the current plans are not fully capitalising on this opportunity.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 494

Received: 16/09/2016

Respondent: N/A

Representation:

There is an opportunity to provide additional access onto St. Albans which would ease the congestion on the business park and provide much better access if car parks are inaccessible.

Full text:

With the recent draft I wanted to make two points about the plan on page 20.

Firstly - there is a huge amount of congestion on Colonial Way currently, although there is a way here for traffic to be able to go south it this would be an opportunity to provide additional access onto St Albans way which would ease the congestion on the business park. Secondly this would also provide much better access should one of the car parks proposed either be full or closed (for maintenance or whatever) - without this link shown in purple) the drivers would need to go a long way round to get from one car park to another.

Secondly I wanted to highlight that there are a very large number of people in an evening walking along St Albans road - these people would, in the future, walk through the pedestrian area but I am a little concerned that in your draft that the area in blue is not considered a "Main Pedestrian Area" which it will become if the work is completed.

Although this covers the area around the station without firmer plans for the station itself I fear that two different visions will emerge between this and a station redevelopment plan. To me these should both be considered at the same time so that the vision for the surrounding area and the station are in sync.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 495

Received: 22/09/2016

Respondent: N/A

Representation:

High Density Milton Keynes in the form tower block arrangement not suitable near a conservation area.

Full text:

I have looked at the above document along with the Skyline document. As a resident of Church Road I was not happy to see a Milton Keynes arrangement on the doorstep of a conservation area. By all means improve access to Watford Junction and provide more car parking spaces. Taxis or access for the disabled have not been mentioned in either of these two bulky documents.

What might also be more important to residents is the quality of the train service which as everyone knows has deteriorated in the last few years. The increased housing in the planning area would make this worse as more commuters arrived. No amount of architecture would resolve this problem.

The greatest threat to our peace of mind would be the tower blocks. We already have the Holiday Inn blocking our light . The towers would alter the whole landscape enticing people to live in a very unappealing area. St Albans Road would become even more of a ghetto. We don't need more shops or restaurants in this area.

Church Road has already had huge housing developments on the Cassio College site, British Waterways and more planned for Stratford and Langley Road. Tower blocks are not an appealing buy for first time buyers but a gift for greedy developers who want to charge high rents.

Two schools are planned for this choked area. What about garages to cater for the vast increase in cars. Not everyone can cycle. We don't need more shops as we are having a new shopping centre in the town. Could we not concentrate on the town centre development, the Croxley Rail Link and the new hospital . These latter two seem to have gone very quiet recently.

Finally, such an ambitious project will take years and nothing in this time will have been done to resolve the housing crisis. Why not change the law so that empty or neglected buildings can be refurbished at far less cost. Cancel the VAT on refurbishments. After all we no longer need to be dictated to by Europe. The resulting savings could be used to help small community projects
creating variety, diversity and far less misery for us all.😇

Support

Watford Junction Draft Development Brief 2016

Representation ID: 502

Received: 27/09/2016

Respondent: Hertfordshire County Council - Hertfordshire Property

Representation:

The inclusion of two school sites is supported

Full text:

The representations made on behalf of Hertfordshire County Council Property (Development Services) are given in the attached document.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 503

Received: 27/09/2016

Respondent: Mr Tim Bracey

Representation:

No recognition of the Croxley tube to link, and therefore section 1.2 is flawed.

Full text:

i)there is NO recognition of the Croxley tube link to Watford Junc.Despite the doc dated Aug 16 when the construction is underway!Thus all the info on section 1.2 is flawed.ii)having 2777 residential units does not make sense when looking at access to the site for vehicles.There appears to be no new roads to the site, so having 4k vehicles going to/from from the site for the residents, even if there is adequate parking, will not work with the current roads in the area.The roads(e.g. St Albans Rd)are ALREADY congested,so adding traffic,+ all the station parking &business road transport,will not work.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 504

Received: 27/09/2016

Respondent: mr chand patel

Representation:

generally support the proposal

Full text:

generally support the proposal but would like to add,

1)lack of on street parking is currently a major issue in the area and I think additional residential spaces are required.

2) in order to support the above point, I would suggest that additional height and residential unit numbers should be included, especially near the station.

3) a pedestrian access point into the station should be created directly off St Alban's Road.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 507

Received: 27/09/2016

Respondent: Mr Jamie Thompson

Representation:

Masterplan proposals provide no consideration to improving station capacity, they must be altered to enable the railway to grow. This is in the context of future capacity issues as new projects are rolled out.

Full text:

The primary purpose of a railway station is to enable passengers to change trains. Watford Junction is a major station that is hampered by both the capacity available from its infrastructure as well as wider network constraints. Those network constraints however are going to be greatly reduced once HS2 opens, and this unlocks the opportunity to remove the constraints at Watford Junction and unleash its full potential.

My primary objection is that the masterplan proposals, as they stand, provide no consideration to improving the railway station's capacity, hemming the railway within its current boundary. Given the dangerous levels of overcrowding the station already experiences, provision of more (and wider) platforms is a necessity now, let alone after HS2 opens and more fast services will be able to serve the station. Consider also that with the Metropolitan Line extension, a potential Crossrail branch, improvements to the Abbey Line, as well as the increased demand from the redevelopment itself, the fact that the station platforms are already at capacity during the peaks means that more capacity will definitely be required moving forward.

Few fast services currently stop at Watford Junction due to the network constraints of having to provide capacity to serve Birmingham, Liverpool, Manchester and Glasgow. Every train that stops at Watford Junction means less trains can run on the fast lines, so it's understandable why Watford stops have been reduced to nearly nothing over the years as trains speeds have increased. HS2 changes all of this though: there will suddenly be capacity to run fast services calling at all of the regional major stations once again; Euston, Watford, Leighton, Bletchley, Milton Keynes, Rugby, Coventry, Birmingham, etc., unlocking connectivity and growth across the region.

To maximise the benefits of this, additional platforms at Watford Junction will a) enable more services to call, b) those services to dwell longer without impacting capacity or safety, improving the passenger interchange experience, and c) they provide flexibility in operational matters: i.e. overtaking, managing disruption, etc. However, as Iveco House/The Junction isn't going anywhere any time soon this could be achieved more easily by adding new capacity on the eastern side of the station, giving the fast lines use of platforms 6, 7, and 8, with the slow lines then using platform 9 and new through platforms 10 & 11.

Having 3 platforms for both the fast and slow services would be a massive improvement, but to future-proof the station and to cater to the ambition for the town we all share, the construction of another full island platform on the east side of the station would enable, with the other works listed above (and the redevelopment of Iveco House/The Junction to restore platform 5 as a through platform), 8 platforms - 4 for the slow lines, and 4 for the fast lines (or 3 fast line platforms without the platform 5 works). Services would be able to arrive into a platform as the previous service was still departing, increasing capacity massively, and increasing the time services could dwell, improving the ability for passengers to switch trains.

The track alignments required for this mean that some of the buildings in the plan need to be altered or removed. I believe that #21 would require the loss of the buildings alongside the railway, #13 would require some alterations to the southern end, and #16A and #16C would be lost, though enlargement of #16B would enable most of the capacity to be maintained. I have taken the liberty of making some annotations to a diagram taken from the document to illustrate my concepts and attached it to my representation. The illustration assumes no platform widening, and would obviously alter accordingly should that be factored in. We can already see the consequences of short-sighted redevelopment have cost us dearly with the inability to restore through platform 5 without justifying the redevelopment of Iveco House/The Junction, so getting developments on the eastern side right first time is crucial.

One final point is that concerning the St. Albans branch line (the "Abbey Line"). The line as it stands cuts through the development, creating a barrier. The report raises the conversion of the line to light rail once again (and shows the line as essentially a shared road), but it is essential that the line is retained as a heavy rail link as its potential uses in that regard are far higher than is widely considered, i.e. a connection to the proposed Radlett freight facility would give heavy rail access to the line through Watford, connections to the Midland line could give access to City station, and similar works could give access to Hatfield should the disused rail route be reinstated.

I would like to ensure that consideration has been made to investigate whether burying the line underground in a shallow tunnel through the development during construction has been investigated. Doing so would remove the barrier, but would also facilitate the future connection of the line through to the London Overground tracks on the opposite side of the station in the future, creating a single through route which would be far more efficient to operate more frequently than the current branch shuttle, and far more usefully than conversion to light rail.

Orphanage Road is the primary obstacle to this as any tunnel would need to pass beneath this road, necessitating some challenging gradients. Given the scope of the master plan, I would like to know if consideration been made to replacing the link that Orphanage Road provides with a new route through the development. Failing that however, new underground platforms at Watford Junction could be located far closer to the mainline platforms, greatly improving the passenger experience and promoting use of the line. I also note that the plans make no consideration for re-routing the Abbey line back along its original alignment, even if only on the surface. It was rerouted to its current alignment to increase the level of car parking available without requiring a crossing at the cost of making the interchange much, much, worse, and as this car parking is now going to be redeveloped the opportunity to restore the quality of interchange by moving the Abbey Line platforms back closer to the mainline platforms presents itself.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 509

Received: 28/09/2016

Respondent: Emma Brading

Representation:

Too much emphasis on car parking spaces as there currently exists awful road congestion and there are breaches in air pollution limits.

Full text:

The plan set out does not address any strategy whatsoever for cycling or bus routes and has a huge emphasis on car parking spaces. The town centre location, with good amenities and busy train station, already has awful road congestion and is breaching air pollution limits. It should be a prime site to limit car use and encourage other modes of transport which is more a effective movement of people and better for our environment. Setting out a strategy for cycle lanes and bus stations should be a top priority and needs to be put out for consultation now.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 511

Received: 30/09/2016

Respondent: Mr Richard Harrington

Representation:

I support the broad ideas behind the development brief including regeneration, providing homes, services and shops.

Full text:

As the Member of Parliament for Watford, the full redevelopment of Watford Junction Station is one of my key priorities. I am glad to note that the Council shares my commitment to improving the station and wider area.

I would encourage the council to continue working with the stakeholders that I have introduced you to and get somewhere with the various proposals which already exist from outside sources for the station. I have been holding meetings with yourselves to this aim as well as with Network Rail, landowners, Transport Ministers and London Midland.

As the brief states, since the 1970s there have been several proposals to redevelop the station and the area.

In my opinion it is now urgent that we get this done as footfall continues to increase at the station.

I am glad that the report recognises that the forecourt which was redesigned at large cost just a few years ago is not fit for purpose and exacerbates problems with bus travel, passenger drop off, taxis and accessing the car park. I have demanded action on these points several times but we need major change.

I also want at least one more access point to the station, preferably from St Albans Road and an easily accessible multi-level car park along with more retail and food outlets.

As I know officials are aware, this brief would completely change the character and use this central area. We need homes for local people and the area, as you recognise, could be so much more than it currently is. For that reason I welcome the broad ideas contained within the brief. I will look closely at detailed plans when available.

To my mind the co-objective with equal primacy to regenerating the area is improving the station, along with the passenger experience, station use and safety. I do not want this objective to be forgotten. Our town needs a better station.

You may note a petition supporting my aims has been circulated. I am sure this will be presented to you by the organisers in due course.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 515

Received: 30/09/2016

Respondent: Intu Properties plc

Agent: NLP Planning

Representation:

Intu supports the redevelopment of the Watford Junction area for a residential
led, mixed use development

Full text:

Please see attached.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 518

Received: 28/09/2016

Respondent: Hille Holdings

Agent: Planning Potential

Representation:

We support the principle of the development brief and the broad quantum of development that is proposed.

Full text:

Watford Junction Draft Development Brief 2016 Consultation
Land between St Alban's Road and the railway line (including Hille Business Centre), Watford, WD24 4AE
Please accept this letter as formal representations to the Watford Junction Draft Development Brief ("WJDDB") 2016
Consultation on behalf of our client, Hille Holdings. These representations should be read in conjunction with the submitted
representations for the Local Plan Part 2 - Site Allocations and Development Management Policies Consultation.
Our client is the freehold landowner of the land between St Alban's Road and the railway line (including Hille Business Centre),
Watford, WD24 4AE, as identified on the enclosed site plan.
This letter sets out a brief introduction to the Site and considers the Site's inclusion within the WJDDC as proposed "additional
sites" for residential development.
The Site
The Site is located to the east of St Alban's Road and measures c. 1ha. The site comprises a number of buildings varying from
1 to 3 storey development. There are a number of existing tenants on site that undertake a variety of B1 and B8 uses. Hille
House occupies the frontage of St Alban's Road.
Development Plan
The site is identified as an employment site (Policy E1) on the District Plan Proposal's Map for protection where B class uses
may be acceptable, as per Figure 1 below. Employment Areas a) (of which the site is within) and b) have been identified as key
development sites, but the primary designation remains employment.
2
The policy states that land within the defined employment area may be released for the purposes of regeneration, in the form
of housing or mixed-use development, where it is demonstrated that the site is no longer required to meet future employment
and business needs.
The Watford Local Plan Part 1 Core Strategy 2006-2031 (January 2013) allocates a Special Policy Area at Watford Junction:
SPA2, as per Figure 2 below. This allocation establishes the principle of a major mixed use regeneration scheme, seeking to
deliver the regeneration aspirations of the District Plan; including but not limited to: a new station interchange building and
access bridge; 1,500 residential units, offices, retail, hotel and conference centres; communal or district heating systems and
open space.
Figure 2: SPA2 Boundary (Local Plan Part 2 Development Management
Policies and Site Allocations Consultation
Figure 1: District Plan Proposals Map Extract
3
The Watford Junction area has been subject to a number of redevelopment plans and proposals, including the Watford
Junction Brief SPD (2004) but due to a number of delivery and viability challenges, the majority of these proposals have not
been delivered. The Council has therefore taken the decision to produce the Watford Junction Draft Development Brief (2016).
Watford Junction Draft Development Brief (WJDDB) 2016
The WJDDB will provide additional guidance for the Special Policy Area and will be a material consideration for planning
decisions. The illustrative masterplan proposes a comprehensive redevelopment of the area, including: residential use (2,777
dwellings), employment use (73,920 sqm GEA), retail use (6,135 sqm GEA), a gym (789 sqm GEA), primary schools (3,000 x2
sqm GEA), community use (1,883 sqm GEA) and car parking (3,771 spaces/ 177,274sqm GEA).
The WJDDB now includes the Hille Holdings' site within its boundary, the site was not included within the Watford Junction
Brief SPD (2004). The site is identified for residential development on the illustrative masterplan (pg. 15), with a variety of storey
heights ranging from 1 to 4 storeys (pg. 19). The Area Schedule identifies 'additional sites' numbers: 23, 24, 25, 26 and 27
as within the site's boundary which is proposed as residential development comprising a total of 113 dwellings.
We support the principle of the WJDDB and the proposed regeneration for this area of Watford. We also support the broad
quanta of development that is proposed within the Development Brief, specifically the proposed residential development and
the significant increase in dwelling capacity over the Core Strategy. We understand that the Council do not need 2,777
dwellings from this masterplan to meet their Housing Target, but the Council is seeking to significantly boost their supply of
housing in accordance with Paragraph 47 of the National Planning Policy Framework, which is supported.
My client supports in principle the inclusion of the site(s) (Site numbers: 23, 24, 25, 26 and 27) for residential development
within the overall masterplan. We consider the site suitable for residential re-development owing to its sustainable location
close to local transport infrastructure, local services and amenities, and the character of the surrounding area. There are no
known constraints for the site as to why it cannot be re-developed for a residential use.
Notwithstanding this, my client would like to emphasise that the development proposals must be deliverable in order for the
proposals to make progress. We note the Watford Junction Development Brief Viability Appraisal (2016) and the analysis set
out that concludes that the regeneration scheme as a whole is viable, with a surplus of c£31m, and compliant with all adopted
planning policies and draft Local Plan policies, but does not contribute towards infrastructure requirements. We have
considered the Council's Community Infrastructure Levy (CIL) Regulation 123 list and the Infrastructure items set out within
the Viability Report, and whilst we note that there is some duplication, not all items can be funded through CIL. We therefore
note PBA's conclusion that in order to fund required infrastructure the affordable housing policy of 35% needs to be reduced
to 20% to enable the infrastructure costs to be met in full. An alternative proposal is set out to seek external funding, requesting
sums from those stakeholders who will benefit from the proposals.
We support the approach to amend the affordable housing policy in the WJDDB area, as set out within our consultation
comments to the Local Plan Part 2, to enable delivery of the illustrative masterplan including the infrastructure items. We
consider that for a masterplan to be delivered there must be clear steps in place to enable the delivery of the infrastructure, as
it's funding and delivery requires multiple stakeholders, and for a buy-in by all parties to realise the illustrative proposals.
This matter of deliverability within the WJDDB is of vital importance to my client because the site is currently occupied by
multiple tenants and any uncertainty in respect of redevelopment will hinder my client's ability to re-let the buildings on site in
the short to medium term.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 519

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan

Representation:

The development brief does not accord with the requirements of Policy SPA2 in the Core Strategy. With the Core Strategy and HCC Minerals Local Plan these are the development plan documents for the site and the development brief should account for them. Accordingly London Concrete and AI will resist an attempt to relocate.

Full text:


LOCAL PLAN PART 2 - SITE ALLOCATIONS AND DEVELOPMENT MANAGEMENT POLICIES PUBLICATION 2016
The following objection is made on behalf of London Concrete Ltd and Aggregate Industries Ltd (AI) the operators of the safeguarded rail aggregates depot and associated facilities at Orphanage Road. The objection should be read in conjunction with representations made on the draft Watford Junction Development Brief currently also subject to consultation.
For the avoidance of doubt it is confirmed that London Concrete and AI continue to rely fully on the objections made on their behalf in respect of the First Consultation - Watford Local Plan DPD, Part 2 - Site Allocations Consultation (as submitted December 2013), Development Management Policies - First Consultation (as submitted December 2013) and the Local Plan Part 2 - Second Consultation (as submitted February 2015). The objections made to those documents have not been reflected in either the latest Local Plan consultation stage nor in the draft Watford Junction Development Brief consultation document.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road). (Policy Boundary)
In the context of Local Plan Part 2 - SPA2 Watford Junction, whilst it is acknowledged that references are now included to the effect that any proposals should take account of the safeguarded facilities, the SPA2 Watford Junction plan showing the proposed extent of the SPA2 area still fails to identify the extent of the rail aggregates depot and associated facilities.
Our previous representations have consistently underscored the fact that the safeguarded area needs to be specifically detailed. The National Planning Policy Framework (NPPF) expressly requires local planning authorities in preparing Local Plans to safeguard existing rail heads and associated storage and handling facilities for the bulk transport by rail of mineral and to safeguard existing concrete batching facilities [Pg33, Para 143, bullet point 4]. Without specifically identifying the extent of the safeguarded area the safeguarding is undermined and does not provide a clear policy based framework for considering development proposals coming forward in the surrounding area. In response to earlier submissions made in this context - the Summary of Comments Received and Initial Officer Response indicated that
"WBC - we agree it would be useful to show the safeguarded concrete batching area and will consider the best way of showing this (and other safeguarded sites in the borough) as we further develop maps for the plan, and appreciate the provision of a detailed plan showing this area and the shared access to the site. We consider that the inclusion of the Option B site should help to provide additional masterplan/design flexibility in the vicinity of the concrete batching plant given the development constraints the plant imposes on the area".

The safeguarded area should be identified now in the Special Policy Area boundary - to appropriately reflect the requirements of the Core Strategy, Minerals Plan and to ensure conformity with requirements in the NPPF, and not least of all so the document can be found 'sound'. The specific identification of the safeguarded site is justified on the basis that the safeguarded area is an existing operational site as opposed to the future development of the wider SPA2 area - where appropriate uses and broad scale of development are being identified to guide future development in the Policy Area Boundary. The proper identification of the safeguarded site will be critical in informing how that development is taken forward in the surrounding area.
The SPA2 area has been expanded to include additional land to the east of the rail aggregates depot site. As per our previous consultation responses we continue to object to this on the grounds that the Inclusion of additional land into the SPA2 Policy area, which is currently subject to an employment designation, and is located adjacent to the safeguarded site is not appropriate and could undermine the safeguarding of the area. As detailed in objection to the draft Development Brief - this issue could be overcome if the Development Brief ensures that noise-sensitive uses cannot be introduced with this area which could prejudice the future operation of the safeguarded area.
Alterations required
* Full extent of rail aggregates depot and associated facilities (including access road) to be marked on to the SPA2 Watford Junction Boundary Plan.

* The SPA2 Boundary Map reference which currently reads : "SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road") should be amended as follows to ensure it accords with the provisions of adopted Policy SPA2 (Core Strategy)

"SPA2 Watford Junction (includes a safeguarded rail aggregates depot and associated facilities at Orphanage Road)."

Appendix I - Site Schedules
SPA2 - Watford Junction.
The following objection should be read in conjunction to the objections made to Policy SPA2 (boundary plan) at Chapter 2 of the draft Local Plan and to the draft Watford Junction Development Brief. As detailed in those responses the full extent of the safeguarded area should be expressly detailed both within Local Plan Part 2 and within the Development Brief.
The Development Considerations listed at Appendix 1 with regard to SPA2 - Watford Junction are objected to as not being in conformity with Adopted Core Strategy Policy SPA 2, nor with provisions in the Minerals Plan and the NPPF. The following amendments are required to ensure the draft Plan is sound.
"Development Considerations
Development proposals will need to be in line with the emerging Watford Junction Masterplan Development Brief and the SPA Objectives and requirements of Policy SPA2 in the Core Strategy.
The waste Orphanage Road rail and aggregates depot and associated facilities (concrete batching plant) within the SPA is safeguarded as identified in Core Strategy Policy SPA2 and Hertfordshire County Council's Minerals Plan. This will need to be retained, or a comparable facility provided on site, which will also be subject to safeguarding, or a new comparable facility provided in the local area.
If the rail aggregate depot and associated facilities are retained in their current location, or relocated within the SPA2 area, the development proposals should not allow for the introduction of noise sensitive uses in proximity to the safeguarded area. Any new development in the vicinity of the safeguarded area should be planned, laid out and designed with appropriate mitigation to ensure they do not prejudice the existing or future use of the safeguarded site and operations.
Greater pedestrian connectivity between the SPA area and the town centre is required as well as .....
Design and development along boundaries.....
Dependent on proposals, an archaeological....
An investigation into waste water....."

WATFORD JUNCTION - DRAFT DEVELOPMENT BRIEF
This objection should be read in conjunction with the objections made to the Watford Local Plan Part 2 on behalf the London Concrete and Aggregate Industries the operators of the rail aggregates depot at Orphanage Road.
The Watford Junction Draft Development Brief is objected to on the basis that it does not accord with the requirements of Adopted Policy SPA2, Watford Junction, in the Watford Borough Local Plan (Core Strategy) Adopted 2013. Policy SPA2 expressly requires that:
"The development scheme will be required to safeguard the existing Orphanage Way rail and aggregates depot and associated facilities, or re-provide a comparable facility on site which will also be subject to safeguarding, or ensure re-provision of a comparable facility within the local area, via liaison with Hertfordshire County Council and the operator. The redevelopment scheme shall be required to be sensitive to and respond to the operating parameters of the facility."
The requirement to safeguard the rail aggregates depot and associated facilities, and this specific policy wording, was secured at EIP as result of objections raised at that time by the operator of the rail and aggregates depot site (namely London Concrete and Aggregate Industries). The safeguarding secured applies to the rail head and aggregates depot and associated facilities, by which is meant the on-site concrete batching plant (CBP). The safeguarding secured within Adopted Policy SPA2 was justified at the time, and continues to be justified and underpinned, by the requirements to safeguard such sites and facilities in the National Planning Policy Framework (NPPF). Specifically, the NPPF requires local planning authorities in preparing Local Plans to safeguard existing rail heads and associated storage and handling facilities for the bulk transport by rail of mineral and to safeguard existing concrete batching facilities [Pg33, Para 143, bullet point 4].
The safeguarding of the Orphanage Road rail and aggregates site, as required by national policy, has been identified within the Hertfordshire Minerals Policy 10: Railheads and Wharves in the County Councils Minerals Local Plan (2002-2016) Adopted 2007. It is highlighted that Hertfordshire County Council made representations including most recently to the Watford Local Plan Part 2 - Second Consultation (representations letter dated 3 February 2016) which highlight the protection which should be afforded to the current facilities at Orphanage Road.
The Minerals Plan together with the Adopted Core Strategy currently comprise the key development plan documents relevant to the consideration of this site. They form the policy context within which the Development Brief must be drafted.
In the context of the safeguarding policies which apply (Adopted Core Strategy Policy SPA2 and Minerals Policy 10) it is reiterated that the operator of the site was very clear when the Core Strategy was under consideration at the EIP that due to the scarcity of rail served sites such as that at Orphanage Road that they did not consider there would be any reasonable possibility that an alternative site could be found that would be suitable to accommodate them. This remains the case. Moreover to date there has been no indication from the LPA or prospective developer as to where the existing facilities could be relocated to or by what mechanism that might be achieved, nor the practicalities or costs of achieving such a relocation. Notwithstanding this, Policy SPA2 is clear that the development proposals for SPA2 need to as a starting point safeguard the existing Orphanage Road rail and aggregates depot and associated facilities, or re-provide a comparable facility on-site also subject to safeguarding, or ensure re-provision within the local area via liaison with Hertfordshire County Council and the operator. The draft Development Brief fails to replicate this policy approach. Its starting point, at Page 34, Section 3.4 Development Sites - Station Quarter East, Land Use and Quantum, bullet point 2, in fact fails to make any reference to the first two parts of Adopted Policy SPA2 in this context, and makes reference only to relocation within the local area.
London Concrete and Aggregate Industries are clear that they will resist any attempt to relocate their facility - due to the impact in would have on their operation and business and the fact that they are clear that there is no suitable site in the "local" area which could provide the same rail and road access that currently supports their operations.
The approach of the draft Development Brief, with regard to Station Quarter East development site (within which the London Concrete/AI facility is located) is flawed, not consistent with Adopted Policy in the Core Strategy, not consistent with Policy in the Minerals Plan and not consistent with NPPF requirements.
On this basis the draft Development Brief is not 'sound' and is objected to on the following specific points:
Specific objections/comments draft Development Brief -
Page 6, 1.1 Introduction, Planning Policy and Status - Fails to make reference to requirements in the Minerals Local Plan forming part of the Development Plan. Draft development brief - must include reference to this.
Pg 10, 2.1 Baseline Analysis, under heading of Weaknesses, bullet point 6, makes reference to "Lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling." The policy position is perfectly clear and set out in Adopted Policy SPA2 in terms of first safeguarding of the facility in-situ, re-provision and safeguarding on site, or re-provision in the local area. The site operator has equally been clear in terms of the likelihood of an alternative suitable site being available, which is considered to be extremely limited. It should be very clear that the likelihood is that the facility will remain on site and will need to be fully safeguarded. This will require careful consideration to be given to the uses and design of development in the vicinity of the safeguarded site.
Page 13, 2.13 Site Wide Principles: Built Environment - under the heading Land Use and Activity - draft Development Brief fails to make any reference to likelihood of the retention of the safeguarded rail and aggregates depot or its re-provision on site. Important that it does so at an early stage - to provide a coherent and realistic framework for the wider development.
Pg 15, 2.4 Illustrative Masterplan - the illustrative masterplan has no regard to the requirements of Adopted Policy SPA2 and the requirement to safeguard the existing Orphanage Road facilities or re-provide onsite. Given the fact that the operator has consistently advised that there is extremely limited potential that they could be relocated in the local area -the illustrative masterplan is fundamentally flawed in that it currently shows no provision for the safeguarded uses and operations and fails to appropriately guide development in this part of the SPA2 policy area.
As a starting point the illustrative masterplan must show the retention of the safeguarded uses including access to the highway network - to appropriately guide development in the context of the adopted SPA2 policy.
Pg 18, 2.5 Land Uses - In context of requirements in adopted Policy SPA2 fails to make any reference to the retained and safeguarded rail and aggregates depot and associated facilities - in the list of land uses.
In addition to showing the retained area to accord with the principles of safeguarding - it is not considered appropriate to introduce noise sensitive uses in the adjoining area which could prejudice the future operation of the safeguarded area. Adjoining land uses are currently employment uses - objections have previously been maintained to the inclusion of those employment areas within the SPA2 area for just this reason.
Land use plan should show retained safeguarded area including appropriate access provision and be clear in its guidance in terms of appropriate surrounding land uses.
Pg 32, 3.3 Development Sites: Station Quarter West - in the context of Land Use and Quantum as this area of land is located directly opposite the existing Orphanage Road facility - land uses indicated here consisting primarily of office, retail and leisure are supported. However, any introduction of residential or other noise-sensitive uses would be resisted as they would be located in close proximity to the aggregates unloading area and associated rail sidings and would have the potential to prejudice the safeguarded area.
Pg 34, 3.4 Development Sites: Station Quarter East - as detailed above and in the context of objections to the current Local Plan consultation, bullet point 3 fails entirely to accord with the clear principles of safeguarding established in Adopted Policy SPA2. This forms the main basis for the objection to the draft Development Brief which is fundamentally flawed in failing to allow for any option other than the relocation of the rail and aggregates depot in the local area. The starting point of the Policy requires consideration of retention of the safeguarded area. In not considering that as a development option the Development Brief will fail to provide appropriate guidance in terms of development coming forward in this part of the SPA2 area. The Brief must account for the potential that it is highly unlikely that a suitable alternative location will be found to accommodate the safeguarded operations and that facility will need to be retained and appropriately safeguarded on site. That safeguarding will need to ensure that new land uses introduced around the retained area should not prejudice the existing and future operation of the site including its access to the highway network.
Conclusion
It is noted that the site operator has had significant experience in protecting and safeguarding sites such as this at a number of its location. This has been achieved by a variety of means including: through local plan representations; by objecting to application proposals which could prejudice their operations; by successfully resisting CPO's and by recourse to legal action including judicial review. The operator is clear on the importance of this site as a rail served freight facility safeguarded at every level of policy. A robust case was made at the Core Strategy EIP which secured the basis on which future development documents including the Local Plan Part 2 and the Watford Junction Development Brief should be progressed. The operator has made repeated representations to the Local Plan process and it is extremely disappointing that this is not reflected in the latest round of consultation and the formulation of the draft Development Brief. The Operator was consulted at a very late stage on the draft Development Brief - just a few weeks before formal consultation commenced.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 520

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan

Representation:


Pg 34, 3.4 Development Sites: Station Quarter East - as detailed above and in the context of objections to the current Local Plan consultation, bullet point 3 fails entirely to accord with the clear principles of safeguarding established in Adopted Policy SPA2. This forms the main basis for the objection to the draft Development Brief which is fundamentally flawed in failing to allow for any option other than the relocation of the rail and aggregates depot in the local area. The starting point of the Policy requires consideration of retention of the safeguarded area. In not considering that as a development option the Development Brief will fail to provide appropriate guidance in terms of development coming forward in this part of the SPA2 area. The Brief must account for the potential that it is highly unlikely that a suitable alternative location will be found to accommodate the safeguarded operations and that facility will need to be retained and appropriately safeguarded on site. That safeguarding will need to ensure that new land uses introduced around the retained area should not prejudice the existing and future operation of the site including its access to the highway network.

Full text:


LOCAL PLAN PART 2 - SITE ALLOCATIONS AND DEVELOPMENT MANAGEMENT POLICIES PUBLICATION 2016
The following objection is made on behalf of London Concrete Ltd and Aggregate Industries Ltd (AI) the operators of the safeguarded rail aggregates depot and associated facilities at Orphanage Road. The objection should be read in conjunction with representations made on the draft Watford Junction Development Brief currently also subject to consultation.
For the avoidance of doubt it is confirmed that London Concrete and AI continue to rely fully on the objections made on their behalf in respect of the First Consultation - Watford Local Plan DPD, Part 2 - Site Allocations Consultation (as submitted December 2013), Development Management Policies - First Consultation (as submitted December 2013) and the Local Plan Part 2 - Second Consultation (as submitted February 2015). The objections made to those documents have not been reflected in either the latest Local Plan consultation stage nor in the draft Watford Junction Development Brief consultation document.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road). (Policy Boundary)
In the context of Local Plan Part 2 - SPA2 Watford Junction, whilst it is acknowledged that references are now included to the effect that any proposals should take account of the safeguarded facilities, the SPA2 Watford Junction plan showing the proposed extent of the SPA2 area still fails to identify the extent of the rail aggregates depot and associated facilities.
Our previous representations have consistently underscored the fact that the safeguarded area needs to be specifically detailed. The National Planning Policy Framework (NPPF) expressly requires local planning authorities in preparing Local Plans to safeguard existing rail heads and associated storage and handling facilities for the bulk transport by rail of mineral and to safeguard existing concrete batching facilities [Pg33, Para 143, bullet point 4]. Without specifically identifying the extent of the safeguarded area the safeguarding is undermined and does not provide a clear policy based framework for considering development proposals coming forward in the surrounding area. In response to earlier submissions made in this context - the Summary of Comments Received and Initial Officer Response indicated that
"WBC - we agree it would be useful to show the safeguarded concrete batching area and will consider the best way of showing this (and other safeguarded sites in the borough) as we further develop maps for the plan, and appreciate the provision of a detailed plan showing this area and the shared access to the site. We consider that the inclusion of the Option B site should help to provide additional masterplan/design flexibility in the vicinity of the concrete batching plant given the development constraints the plant imposes on the area".

The safeguarded area should be identified now in the Special Policy Area boundary - to appropriately reflect the requirements of the Core Strategy, Minerals Plan and to ensure conformity with requirements in the NPPF, and not least of all so the document can be found 'sound'. The specific identification of the safeguarded site is justified on the basis that the safeguarded area is an existing operational site as opposed to the future development of the wider SPA2 area - where appropriate uses and broad scale of development are being identified to guide future development in the Policy Area Boundary. The proper identification of the safeguarded site will be critical in informing how that development is taken forward in the surrounding area.
The SPA2 area has been expanded to include additional land to the east of the rail aggregates depot site. As per our previous consultation responses we continue to object to this on the grounds that the Inclusion of additional land into the SPA2 Policy area, which is currently subject to an employment designation, and is located adjacent to the safeguarded site is not appropriate and could undermine the safeguarding of the area. As detailed in objection to the draft Development Brief - this issue could be overcome if the Development Brief ensures that noise-sensitive uses cannot be introduced with this area which could prejudice the future operation of the safeguarded area.
Alterations required
* Full extent of rail aggregates depot and associated facilities (including access road) to be marked on to the SPA2 Watford Junction Boundary Plan.

* The SPA2 Boundary Map reference which currently reads : "SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road") should be amended as follows to ensure it accords with the provisions of adopted Policy SPA2 (Core Strategy)

"SPA2 Watford Junction (includes a safeguarded rail aggregates depot and associated facilities at Orphanage Road)."

Appendix I - Site Schedules
SPA2 - Watford Junction.
The following objection should be read in conjunction to the objections made to Policy SPA2 (boundary plan) at Chapter 2 of the draft Local Plan and to the draft Watford Junction Development Brief. As detailed in those responses the full extent of the safeguarded area should be expressly detailed both within Local Plan Part 2 and within the Development Brief.
The Development Considerations listed at Appendix 1 with regard to SPA2 - Watford Junction are objected to as not being in conformity with Adopted Core Strategy Policy SPA 2, nor with provisions in the Minerals Plan and the NPPF. The following amendments are required to ensure the draft Plan is sound.
"Development Considerations
Development proposals will need to be in line with the emerging Watford Junction Masterplan Development Brief and the SPA Objectives and requirements of Policy SPA2 in the Core Strategy.
The waste Orphanage Road rail and aggregates depot and associated facilities (concrete batching plant) within the SPA is safeguarded as identified in Core Strategy Policy SPA2 and Hertfordshire County Council's Minerals Plan. This will need to be retained, or a comparable facility provided on site, which will also be subject to safeguarding, or a new comparable facility provided in the local area.
If the rail aggregate depot and associated facilities are retained in their current location, or relocated within the SPA2 area, the development proposals should not allow for the introduction of noise sensitive uses in proximity to the safeguarded area. Any new development in the vicinity of the safeguarded area should be planned, laid out and designed with appropriate mitigation to ensure they do not prejudice the existing or future use of the safeguarded site and operations.
Greater pedestrian connectivity between the SPA area and the town centre is required as well as .....
Design and development along boundaries.....
Dependent on proposals, an archaeological....
An investigation into waste water....."

WATFORD JUNCTION - DRAFT DEVELOPMENT BRIEF
This objection should be read in conjunction with the objections made to the Watford Local Plan Part 2 on behalf the London Concrete and Aggregate Industries the operators of the rail aggregates depot at Orphanage Road.
The Watford Junction Draft Development Brief is objected to on the basis that it does not accord with the requirements of Adopted Policy SPA2, Watford Junction, in the Watford Borough Local Plan (Core Strategy) Adopted 2013. Policy SPA2 expressly requires that:
"The development scheme will be required to safeguard the existing Orphanage Way rail and aggregates depot and associated facilities, or re-provide a comparable facility on site which will also be subject to safeguarding, or ensure re-provision of a comparable facility within the local area, via liaison with Hertfordshire County Council and the operator. The redevelopment scheme shall be required to be sensitive to and respond to the operating parameters of the facility."
The requirement to safeguard the rail aggregates depot and associated facilities, and this specific policy wording, was secured at EIP as result of objections raised at that time by the operator of the rail and aggregates depot site (namely London Concrete and Aggregate Industries). The safeguarding secured applies to the rail head and aggregates depot and associated facilities, by which is meant the on-site concrete batching plant (CBP). The safeguarding secured within Adopted Policy SPA2 was justified at the time, and continues to be justified and underpinned, by the requirements to safeguard such sites and facilities in the National Planning Policy Framework (NPPF). Specifically, the NPPF requires local planning authorities in preparing Local Plans to safeguard existing rail heads and associated storage and handling facilities for the bulk transport by rail of mineral and to safeguard existing concrete batching facilities [Pg33, Para 143, bullet point 4].
The safeguarding of the Orphanage Road rail and aggregates site, as required by national policy, has been identified within the Hertfordshire Minerals Policy 10: Railheads and Wharves in the County Councils Minerals Local Plan (2002-2016) Adopted 2007. It is highlighted that Hertfordshire County Council made representations including most recently to the Watford Local Plan Part 2 - Second Consultation (representations letter dated 3 February 2016) which highlight the protection which should be afforded to the current facilities at Orphanage Road.
The Minerals Plan together with the Adopted Core Strategy currently comprise the key development plan documents relevant to the consideration of this site. They form the policy context within which the Development Brief must be drafted.
In the context of the safeguarding policies which apply (Adopted Core Strategy Policy SPA2 and Minerals Policy 10) it is reiterated that the operator of the site was very clear when the Core Strategy was under consideration at the EIP that due to the scarcity of rail served sites such as that at Orphanage Road that they did not consider there would be any reasonable possibility that an alternative site could be found that would be suitable to accommodate them. This remains the case. Moreover to date there has been no indication from the LPA or prospective developer as to where the existing facilities could be relocated to or by what mechanism that might be achieved, nor the practicalities or costs of achieving such a relocation. Notwithstanding this, Policy SPA2 is clear that the development proposals for SPA2 need to as a starting point safeguard the existing Orphanage Road rail and aggregates depot and associated facilities, or re-provide a comparable facility on-site also subject to safeguarding, or ensure re-provision within the local area via liaison with Hertfordshire County Council and the operator. The draft Development Brief fails to replicate this policy approach. Its starting point, at Page 34, Section 3.4 Development Sites - Station Quarter East, Land Use and Quantum, bullet point 2, in fact fails to make any reference to the first two parts of Adopted Policy SPA2 in this context, and makes reference only to relocation within the local area.
London Concrete and Aggregate Industries are clear that they will resist any attempt to relocate their facility - due to the impact in would have on their operation and business and the fact that they are clear that there is no suitable site in the "local" area which could provide the same rail and road access that currently supports their operations.
The approach of the draft Development Brief, with regard to Station Quarter East development site (within which the London Concrete/AI facility is located) is flawed, not consistent with Adopted Policy in the Core Strategy, not consistent with Policy in the Minerals Plan and not consistent with NPPF requirements.
On this basis the draft Development Brief is not 'sound' and is objected to on the following specific points:
Specific objections/comments draft Development Brief -
Page 6, 1.1 Introduction, Planning Policy and Status - Fails to make reference to requirements in the Minerals Local Plan forming part of the Development Plan. Draft development brief - must include reference to this.
Pg 10, 2.1 Baseline Analysis, under heading of Weaknesses, bullet point 6, makes reference to "Lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling." The policy position is perfectly clear and set out in Adopted Policy SPA2 in terms of first safeguarding of the facility in-situ, re-provision and safeguarding on site, or re-provision in the local area. The site operator has equally been clear in terms of the likelihood of an alternative suitable site being available, which is considered to be extremely limited. It should be very clear that the likelihood is that the facility will remain on site and will need to be fully safeguarded. This will require careful consideration to be given to the uses and design of development in the vicinity of the safeguarded site.
Page 13, 2.13 Site Wide Principles: Built Environment - under the heading Land Use and Activity - draft Development Brief fails to make any reference to likelihood of the retention of the safeguarded rail and aggregates depot or its re-provision on site. Important that it does so at an early stage - to provide a coherent and realistic framework for the wider development.
Pg 15, 2.4 Illustrative Masterplan - the illustrative masterplan has no regard to the requirements of Adopted Policy SPA2 and the requirement to safeguard the existing Orphanage Road facilities or re-provide onsite. Given the fact that the operator has consistently advised that there is extremely limited potential that they could be relocated in the local area -the illustrative masterplan is fundamentally flawed in that it currently shows no provision for the safeguarded uses and operations and fails to appropriately guide development in this part of the SPA2 policy area.
As a starting point the illustrative masterplan must show the retention of the safeguarded uses including access to the highway network - to appropriately guide development in the context of the adopted SPA2 policy.
Pg 18, 2.5 Land Uses - In context of requirements in adopted Policy SPA2 fails to make any reference to the retained and safeguarded rail and aggregates depot and associated facilities - in the list of land uses.
In addition to showing the retained area to accord with the principles of safeguarding - it is not considered appropriate to introduce noise sensitive uses in the adjoining area which could prejudice the future operation of the safeguarded area. Adjoining land uses are currently employment uses - objections have previously been maintained to the inclusion of those employment areas within the SPA2 area for just this reason.
Land use plan should show retained safeguarded area including appropriate access provision and be clear in its guidance in terms of appropriate surrounding land uses.
Pg 32, 3.3 Development Sites: Station Quarter West - in the context of Land Use and Quantum as this area of land is located directly opposite the existing Orphanage Road facility - land uses indicated here consisting primarily of office, retail and leisure are supported. However, any introduction of residential or other noise-sensitive uses would be resisted as they would be located in close proximity to the aggregates unloading area and associated rail sidings and would have the potential to prejudice the safeguarded area.
Pg 34, 3.4 Development Sites: Station Quarter East - as detailed above and in the context of objections to the current Local Plan consultation, bullet point 3 fails entirely to accord with the clear principles of safeguarding established in Adopted Policy SPA2. This forms the main basis for the objection to the draft Development Brief which is fundamentally flawed in failing to allow for any option other than the relocation of the rail and aggregates depot in the local area. The starting point of the Policy requires consideration of retention of the safeguarded area. In not considering that as a development option the Development Brief will fail to provide appropriate guidance in terms of development coming forward in this part of the SPA2 area. The Brief must account for the potential that it is highly unlikely that a suitable alternative location will be found to accommodate the safeguarded operations and that facility will need to be retained and appropriately safeguarded on site. That safeguarding will need to ensure that new land uses introduced around the retained area should not prejudice the existing and future operation of the site including its access to the highway network.
Conclusion
It is noted that the site operator has had significant experience in protecting and safeguarding sites such as this at a number of its location. This has been achieved by a variety of means including: through local plan representations; by objecting to application proposals which could prejudice their operations; by successfully resisting CPO's and by recourse to legal action including judicial review. The operator is clear on the importance of this site as a rail served freight facility safeguarded at every level of policy. A robust case was made at the Core Strategy EIP which secured the basis on which future development documents including the Local Plan Part 2 and the Watford Junction Development Brief should be progressed. The operator has made repeated representations to the Local Plan process and it is extremely disappointing that this is not reflected in the latest round of consultation and the formulation of the draft Development Brief. The Operator was consulted at a very late stage on the draft Development Brief - just a few weeks before formal consultation commenced.