Watford Junction Draft Development Brief

Showing comments and forms 31 to 60 of 171

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 521

Received: 29/09/2016

Respondent: Mr Thomas Parsons

Representation Summary:

Plan needed to consider St. Albans Road (including Colonial Way and Station Road)

Full text:


I have read the above document with great interest and the plan for Watford Junction and the surrounding area looks great.
The huge and very obvious (at least to us local residents) obstacle is St. Albans Road though.
What is the plan for that?
The plan says that the new development will be accessed from St. Albans Road and also Colonial Way and Station Road which both lead onto St. Albans Road.
I live in Regent Street and at the moment it is not unusual at certain times of the day to take 20 minutes to get there from Balmoral Road or to take 25 minutes to get to the Asda supermarket or Croxley Green.
The addition of 1500 dwellings, 2 schools and however many businesses and commercial enterprises would surely bring the area to a complete standstill.
The volume of traffic added to the ever worsening parking problem makes life difficult enough as it is.
Who would want to live in North Watford if it also took hours to get in and out of the place?

Support

Watford Junction Draft Development Brief 2016

Representation ID: 523

Received: 30/09/2016

Respondent: Warner Bros.

Agent: Terence O'Rourke

Representation Summary:

Supports the Masterplan for Watford Junction, particularly the improvements for the Railway Station and any enhancements to the station's quality and legibility and sense of arrival would be welcomed and strongly supported.

Full text:

Thank you for the opportunity to respond to the Watford Junction Draft Development
Brief public consultation process. I am writing on behalf of our client, Warner Bros.
Studios Leavesden (WBSL).
Having reviewed the draft development brief, WBSL is pleased to support the master
plan for Watford Junction, particularly the planned improvements to the railway station.
WBSL acknowledges that the redevelopment of this area has the potential to drive the
economic development of Watford, create employment opportunities and enhance the
offer of services and facilities, which again is supported in the context of the wider area.
Watford Junction plays a key role in the arrival experience for visitors to the area.
Specifically, the station is a gateway for both UK and overseas visitors both to Warner
Bros. Studios Leavesden (WBSL) and the world-class visitor attraction 'Warner Bros.
Studio Tour London - The Making of Harry Potter TM'. Any enhancements to the station's
quality, legibility and sense of arrival would be welcomed and strongly supported.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 532

Received: 01/10/2016

Respondent: Mr David Horton

Representation Summary:

Support the development brief providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station, including connections with London bound services.

Full text:

I support this providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created. Ability to run through-trains from the Abbey Line to the main line in the London-bound direction should be retained. Much wider thoroughfares to relieve congestion are also required as well the ability to buy tickets on the new eastern-accessible side of the station.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 533

Received: 01/10/2016

Respondent: Julie Logan

Representation Summary:

Support the development brief providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station, including connections with London bound services.

Full text:

I support this providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created. Ability to run through-trains from the Abbey Line to the main line in the London-bound direction should be retained. Much wider thoroughfares to relieve congestion are also required as well as the ability to buy tickets on the new eastern-accessible side of the station.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 534

Received: 01/10/2016

Respondent: Elliot Arazi

Representation Summary:

Support the development brief providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station, including connections with London bound services.

Full text:

I support this providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created. Ability to run through-trains from the Abbey Line to the main line in the London-bound direction should be retained. Much wider thoroughfares to relieve congestion are also required as well as Oyster terminals on the new eastern-accessible side of the station.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 535

Received: 01/10/2016

Respondent: Terrence Webb

Representation Summary:

Support the development brief providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station, including connections with London bound services.

Full text:

I support this providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created. Ability to run through-trains from the Abbey Line to the main line in the London-bound direction should be retained. Much wider thoroughfares to relieve congestion are also required as well as the ability to buy tickets on the new eastern-accessible side of the station.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 536

Received: 01/10/2016

Respondent: Ms Victoria Willis

Representation Summary:

Lack of efforts to improve sustainability e.g. measures to reduce carbon emissions

Full text:

I object to this proposal on environmental grounds; I don't see evidence of realistic efforts to meet your sustainability targets e.g. Reduce C02 emissions.
1) Where is the cycle parking provision? Badly thought out cycle parking has been proved time again to fail to encourage use. See WestTrans Report on cycle parking.
2) Where are the segregated cycle lanes on surrounding roads? Without them, research has shown it is unlikely journeys by bike will displace car journeys. Disincentivising driving by reducing car parking also works. See 'Urban Transport without the hot air' by Steve Melia.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 537

Received: 01/10/2016

Respondent: Mr Stephen Davies

Representation Summary:

This is an opportunity for the Abbey Line platform is brought much closer to, and accessible from, the rest of the station, including connections with London bound services.

Full text:

The plans to redevelop the station and local environs provides an excellent opportunity to improve the St Albans Abbey branch line connectivity and commercial viability; preferably by bringing services and track configuration closer to (or actually in to) existing platform 10 to provide cross-platform interchange with London-bound platform 9 with additional automated ticketing infrastrucure and gates as necessary. This would also enable the running of some through services from St Albans in to London Euston via Watford Junction.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 538

Received: 01/10/2016

Respondent: Mr Cameron Lavin

Representation Summary:

Support the development brief providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station, including connections with London bound services.

Full text:

I support this providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created. Ability to run through-trains from the Abbey Line to the main line in the London-bound direction should be retained. Much wider thoroughfares to relieve congestion are also required as well as the ability to buy tickets on the new eastern-accessible side of the station.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 539

Received: 01/10/2016

Respondent: Mrs Jacqueline Taylor

Representation Summary:

Support the development brief providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station, including connections with London bound services.

Full text:

I support this providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created. Ability to run through-trains from the Abbey Line to the main line in the London-bound direction should be retained. Much wider thoroughfares to relieve congestion are also required as well as the ability to buy tickets on the new eastern-accessible side of the station.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 540

Received: 01/10/2016

Respondent: Convatec

Representation Summary:

Support the development brief providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station, including connections with London bound services.

Full text:

I support this providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created. Ability to run through-trains from the Abbey Line to the main line in the London-bound direction should be retained. Much wider thoroughfares to relieve congestion are also required as well as the ability to buy tickets on the new eastern-accessible side of the station. Rodney Allen

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 542

Received: 01/10/2016

Respondent: Ms Sarah Burgess

Representation Summary:

Support the development brief providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station, including connections with London bound services.

Full text:

I support this providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created. Ability to run through-trains from the Abbey Line to the main line in the London-bound direction should be retained. Much wider thoroughfares to relieve congestion are also required as well as the ability to buy tickets on the new eastern-accessible side of the station.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 543

Received: 01/10/2016

Respondent: Dr Francesco Anselmo

Representation Summary:

Supports the plans for redevelopment, which is considered excellent.

Full text:

Developing the area between Watford Junction and North Watford with a mix of residential, commercial, education buildings and parks that connect North Watford to the station is excellent, however I am concerned about the following points: the proposal includes high rise buildings that would cause overshadowing and wind problems to the surrounding areas, the distances between buildings are too small (you should include results of simulations in the consultation document); you should include cycling paths; you should include a pedestrian link between colonial way and Brixton Rd; you should include cultural and community buildings (museum, cinema, theatre) and parks.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 544

Received: 02/10/2016

Respondent: Ms Julie Spicer

Representation Summary:

No to the replacement of the existing service with a Bus Rapid Transit (BRT)!

Full text:

Abbey Line:
Support the development brief providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created.

The ability to run through-trains from the Abbey Line to the main line in the London-bound direction must be retained.

Passing loop to increase frequency of trains.
Ticket machines on all Abbey Line stations.
No to the replacement of the existing service with a Bus Rapid Transit (BRT)!

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 548

Received: 02/10/2016

Respondent: Mrs Sophie summerhayes

Representation Summary:

Concerns regarding the amount of parking being proposed which will cause more traffic to an already congested area

Full text:

I am writing on behalf of the Watford area green party who have a few concerns regarding the development. We understand the need for housing and building up, but we have issues with the amount of parking being proposed which will cause more traffic to an already congested area. There also seem to be no mention of public transport or cycle routes. We are also hoping that the buildings will be sustainable and there will be a large number of affordable housing as young people are increasingly being priced out of the market, especially in Watford. Many thanks Sophie Summerhayes.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 549

Received: 02/10/2016

Respondent: Mr Kevin O'Connor

Representation Summary:

Support provided that the Abbey Line platform is brought much closer to, and is accessible from, the rest of the station. It could be re routed to join up with the mainline London bound services.

Full text:

I support this providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created. Ability to run through-trains from the Abbey Line to the main line in the London-bound direction should be retained. Much wider thoroughfares to relieve congestion are also required as well as the ability to buy tickets on the new eastern-accessible side of the station.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 550

Received: 02/10/2016

Respondent: Mr Martin Winstone

Representation Summary:

Current arrangements for taxis and car park inadequate particularly with narrow pathway through tunnel.

Full text:

Watford Junction is currently chaotic in terms of access to the car park both in the car and on foot. The rearrangement of the taxis has meant on a number of occasions the queues to get out can be substantial and sometimes there are too many taxis in pick up partly blocking the roadway.

I also support this providing that the Abbey Line platform is brought much closer to, and accessible from, the rest of the station. Ideally if the branch was re-routed to join up with the present platform 10 'bay' (dead end), a cross-platform interchange with mainline London-bound services could be created. Ability to run through-trains from the Abbey Line to the main line in the London-bound direction should be retained. I would have a preference for using the Abbey Line if trains were running more often rather than driving to the Junction.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 553

Received: 02/10/2016

Respondent: Nascot Residents Association

Representation Summary:

Supports measures which encourages redevelopment of the station to ensure it is safe and fit for purpose.

Full text:

The Nascot Residents Association thank the Council for being consulted on the changes to the Watford Local Plan and also on the brief for the Junction station regeneration. In particular, we very much appreciated the attendance of Catriona Ramsay at our recent meeting to inform us of key details contained within these documents.
The Nascot Residents Association fully support to desire of the Council & other agencies to encourage development which expedites the urgent need to redevelopment the station to ensure it is safe and fit for purpose to cope with the increasing number of users.
We are encouraged to see that appropriate community facilities (e.g. schools, open space) to support the large amount of housing is recognised and included.

Our main concern is that the brief says very little about how the station itself should be improved. The Council, as planning authority, needs to set out minimum standards for any new station buildings, including:
* Additional access to the station such as from the St Albans Road/Penn Road side for those approaching form the north.
* Adequate cover on all the platforms to ensure passengers are not exposed to the elements as well as all the dangers from wet surfaces that currently characterise the station platforms.
* Expanded means of entry and exit from the platforms in place of the current dangerously overcrowded tunnel.
* Improved access between the "main-line" platforms, and the currently distant Abbey Line Platform 11.
* Improved access between the "main-line" platforms and platforms 1-4, which will soon see massively expanded use when the Met Line is diverted to the Junction station.
* Increased and better provision for cycle parking to encourage more "active travelling" by bike & foot to the station and to reduce the problems arising from people driving along congested roads to the station
* Increased and better provision for cycle parking to encourage more "active travelling" by bike & foot to the station and to reduce the problems arising from people driving along congested roads to the station

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 554

Received: 03/10/2016

Respondent: Mr John Burke

Representation Summary:

I would like to see the St Albans Abbey railway line brought back on to its original alignment into platform 10 from the Watford North direction. A road bridge could be built over the line from the Penn Road direction to link into Colonial Way. Passenger entrances need to be built on the north east side of the station so that they do not need to walk over the railway line and to the front of the station to gain access. Extra Lifts and stairs should be provided at the north end of the platforms 6-9. Reinstate platform 5.

Full text:

I would like to see the St Albans Abbey railway line brought back on to its original alignment into platform 10 from the Watford North direction. A road bridge could be built over the line from the Penn Road direction to link into Colonial Way. Passenger entrances need to be built on the north east side of the station so that they do not need to walk over the railway line and to the front of the station to gain access. Extra Lifts and stairs should be provided at the north end of the platforms 6-9. Reinstate platform 5.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 556

Received: 03/10/2016

Respondent: Ms Susan Jermyn

Representation Summary:

Watford Junction Station cannot accommodate extra passenger demand from this size of development

Full text:

1. Watford is already supporting far more persons than its infrastructure was designed for so 2777 spaces in ugly highrise will increase anto-social behaviour. Creaking sewer system?

The platforms at Watford Junction can only take trains of a certain length. Where are the extra passengers going to be accommodated?

2. The centralised nature of Watford Junction means that cars destined for the car park have to crawl along already overcrowded roads to even get in the car park when they could assemble at any number of the station car parks along the line. It is already impossible to pick up from there without nearly backing into another vehicle and then sitting in traffic for extended time periods so that we drop at the Reeds Complex and walk the rest of the way at the moment or miss our train! What about the disabled what do they do?

The pick-up system @ WJ actually worked better before the last re-vamp. You are just shifting the traffic around the existing road system which already is crumbling with the current stress!

Watford continues to suffer constant disruption from current "projects" and roads are ruined by overweighted vehicles. We are tired of it!

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 563

Received: 02/10/2016

Respondent: Central Town Residents' Association

Representation Summary:

In Section 2.2 Interchange, reference should be made to the Passenger Interchange Publication by the Institute of Civil Engineers.

Full text:

Thank you for the opportunity to comment on this document. I use your clause numbers in my comments.

2.2 Interchange

The existing facilities have long been "unfit for purpose". The outline proposals are a reasonable start towards redevelopment.
I recommend that in developing the brief and the delivery plan, reference is made to the publication Passenger Interchange published by the Institution of Civil Engineers in 2000, and to the more detailed practice guides mentioned therein.

2.3, 2.4, and 2.5 Built Environment

The proposal to attempt to limit the unsightly effects of massing tall buildings and setting some of them back from the (apparently undefined) "building lines" will, I fear, be insufficient to avoid an appearance of "Manhattanising" parts of the development area. The 3D Massing Model is not encouraging in this respect.
The small "amenity" (?) spaces between many of the buildings will be, I suggest, unlikely to be comfortably usable even at moderately windy times.
Would it be preferable to plan for just one or two medium-sized pocket parks? These could be more usable and possibly attractive to wildlife-especially birds, and could go some way towards making the whole area just a little "garden city"- like, providing a welcome benefit for Watford as a whole.
Does this large development area give an opportunity to produce further "Green Zones" which could well be more effective than those introduced some years ago.

Remaining Clauses

One hopes that as further stages are developed, consultation will lead to a Delivery Plan which includes a widely acceptable refinement of the proposals outlined in this Brief.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 565

Received: 30/09/2016

Respondent: TfL Planning

Representation Summary:

Consultation would be required with TFL for any reconfiguration of the station to account for matters including access during construction.

Full text:

* The report mentions the impact MLX will have on rail connectivity. It is forecast that there would be a net increase in Metropolitan Line annual trips of 730,000 following the opening of the extension. However the impact on passenger numbers from MLX are not on their own a driver for the increase in demand.
* Any reconfiguration of station facilities would need to be made in consultation with Transport for London.
* We would expect any interface between construction projects are appropriately managed and take account of respective and applicable governance and standards.
* MLX will be working with Network Rail and the Train Operating Companies to ensure our access requirements (for construction) are managed in a collaborative way (through the Engineering Access Statement process) and will need to ensure that any maintenance access we design in (e.g. gates in the fence line etc.) are considered for any other works. TfL would normally do this via the Network and Station Change processes and through inclusion of appropriate stakeholders at Independent Design Reviews.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 567

Received: 28/10/2016

Respondent: Mary Forsyth

Representation Summary:

There are a number of types and inconsistencies in the report.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 578

Received: 03/10/2016

Respondent: Mrs Hazel Harkin

Representation Summary:

Road structure cannot cope with the increase traffic generated.

Full text:

My name is Hazel Harkin I am a home owner at 61 Cromer Road, Watford, Hertfordshire, WD24 4DY, I am contacting you with regards to the proposed development around Watford Junction. I have a 3 year old and I currently don't wish to move out of the area as I believe where we live suit our family needs.

I have commuted into various parts of London via Watford Junction for over 10 years now and I am fully behind the fact that Watford Junction needs to be developed to allow the station to cope with an increase in commuters traveling through it on a daily basis. I walk from the station home, which I am glad about because I would just hate to sit in the traffic if I was trying to leave via a car from the stations car park.

However I am contacting you as the I feel very strongly about the fact about the proposed development of the local area that will accompany the improvements at Watford Junction.
* The road structure around north Watford I believe could not cope with the increase in traffic. As soon as there is an incident on the ring road in Watford the traffic backs up along St Albans road and other roads feeding into the centre.
* Another doctors surgery is required in this area, not another gym. Our doctors surgeries are already working to full capacity and trying to get an appointment is very difficult.
* I believe Watford General Hospital is already over burdened. More development and facilities should be given to other local hospitals ie St Albans and Hemel Hempsted.
* Introducing a new primary school is good, however what proposals are there to introduce new secondary schools to the Watford area? I don't believe the current proposed building around Watford has allowed or given thought for children's future schooling needs.
* I believe having the amount of buildings over 4 stories is too many, it will greatly change the landscape of this part of town and not for the good.
* I don't believe that there is sufficient parking being provided for residents. Now a days every house hold does have 1-2 cars.
* Will the residential roads be wide enough? As all new developments seem to have narrow roads, which can become difficult when trying to pass moving cars along side parked cars.
* I don't believe the current bus services could cope with the potential increase in usage. Speaking from experience when I was on maternity leave, trying to move across Watford and out of Watford via the use of buses could still be difficult especially when using a pram for a very young baby. One morning I was not able to access 3 consecutive buses due to how busy they were. My pram wouldn't have fitted on and this was after 9am in the morning. Bus routes out of Watford also need to be improved.
* If there isn't adequate parking for residents and businesses proposed within this development it will then impact the already over parked local streets.
In summary I just feel that the number of proposed homes should be greatly reduced. Even more small individual properties should be proposed with gardens rather than flats. This is more in keeping with the local area. The proposed shops/cafes should be monitored as there too many food outlets already. What North Watford needs is it's community back and a thriving high street, I don't believe this large development will support this.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 579

Received: 03/10/2016

Respondent: HSBC Bank Pension Trust (UK) (HSBCP) Limited

Agent: PowerHaus Consultancy

Representation Summary:

After the consultations, few of the comments exchanged have been reflected in the brief and therefore a more reflective brief is required that supports the early stages of the development and recognises that these will not happen if there is overly burdensome upfront expenditure. The brief needs to respond to the commercial realities of bringing forward regeneration and a more realistic position needs to be adopted.

Full text:

We write on behalf of HSBC Pension Trust (UK) (now referred to as HSBCP) Limited, the freeholders of St Albans Road Retail Park, St Albans Road. It is a site located within the Policy SPA2 Watford Junction regeneration area and is a successful retail park occupied by TK Maxx, Staples and The Range. The HSBCP site has a high existing use value and trades well. It has permission for up to 11,855 sq. m of retail floorspace of which 2,316 sq. m is yet to be constructed. There are further asset management initiatives that could be pursued, to enhance the existing use value as an alternative to redevelopment.
As Watford Borough Council, (now referred to as the Council), will know, the area has been considered for comprehensive redevelopment over many years and two masterplan initiatives worked up with other main landowners and in close consultation with the Council have proved not to be viable. We recognise that the Council need to mitigate the impact of the development. However, unless the scheme is viable and commercially appropriate then the HSBCP site will definitely not come forward for development.
HSBCP has strict responsibilities to its Pension Trustees and shareholders. There is a duty to both safeguard and, where appropriate and achievable at minimum risk, enhance the value of the asset for the pensioners. One alternative to asset management and redevelopment of the existing retail uses would be to pursue a residential-led option. It is important to note, however, that residential development on the scale proposed is high-risk and hence any prospective returns would need to be significantly in excess of the present value, which is already substantial, in order for HSCBP to justify pursuing such an option.
HSBCP is working with Be:here Ltd and Prime Place Developments Ltd as their preferred delivery partner to explore the potential for residential led redevelopment. By way of introduction, Be:here and Prime Place are subsidiaries of Willmott Residential, which has a long track-record for transforming large areas through residential-led regeneration. Prime Place deliver homes for sale and Be:here develop and undertake the long term stewardship of homes for the rental market. This unique combination significantly accelerates delivery, creates an environment where people want to live and provides a balance of tenures with a range of homes that cater for different levels of affordability.
Please note, however, the decision on whether to pursue a redevelopment or retain the site as a retail park has not been determined and is dependent upon whether it is commercially appropriate to do so. It is absolutely critical that the Council recognise that there will need to be a strong commercial justification for HSBCP and other landowners to redevelop their sites; otherwise the masterplan will not be delivered.
A number of meetings have been held with the Council to discuss the potential development of the site, as a catalytic first phase of the wider Watford Junction Major Development Area. In addition, HSBCP has been represented at four further stakeholder meetings with the Council over the last year to engage in the process of the emergence of the Watford Junction Brief, however, few of the comments and information exchanged has been reflected in the draft documents. The Council is therefore urged to re-consider this position, and prepare a more supportive and deliverable Development Framework that particularly supports the early,
catalytic phases of development and recognises that these will not occur if they are overly burdened by upfront expenditure.
Overall, HSBCP and their delivery partners are supportive of the production of a Watford Junction Development Brief and the Council's vision and desire to transform the SPA2 regeneration area. However, it is felt that many of the assumptions within the PBA Viability Appraisal, which supports the BDP masterplan, are fundamentally flawed and the conclusions are grossly misleading. The degree to which the Viability Assessment is out of touch with the current commercial market is a major concern and raises serious questions about whether agreement between the Council and the individual landowners will be possible.
The Development Brief has to respond to the commercial realities of bringing forward such a significant regeneration in order for it to be effective, and fundamentally it has to support delivery, particularly in the early stages, by setting achievable principles, and minimising commercial delivery risk. Unless a more realistic position is adopted then it is questionable whether the regeneration of the SPA2 area will actually come to fruition. Further more specific comments are outlined below.
Comments
Phased Development
The introduction of the Draft Development Brief refers to previous redevelopment plans for Watford Junction since the 1970's, which pivoted on delivery and viability challenges. This remains a key consideration for this version of the Development Brief and it is critical that it acknowledges the need for phased delivery and that the HSBCP site could be the first catalytic phase. A comprehensive approach remains undeliverable without the significant input of public monies to assist in the provision of critical infrastructure. The Development Brief should be amended throughout to reflect phased delivery of each potential development site.
Development Assumptions
In accordance with the requirements of the NPPF (paragraphs 173 and 174) the risk, cost and resource commitment associated with any development opportunity needs to be worthwhile to the landowner, otherwise the incentive to bring forward development would not outweigh the existing use value and retention of the site in its current form. The NPPF particularly states:
'Plans should be deliverable. Therefore, the sites and the scale of development
identified in the plan should not be subject to such a scale of obligations and policy
burdens that their ability to be developed viably is threatened. To ensure viability, the costs of any requirements likely to be applied to development such as requirements for affordable housing, standards, infrastructure contributions or other requirements should when taking account of normal cost of development mitigation provide competitive returns to a willing landowner and willing developer to enable the development to be deliverable.'
Paragraph 174 of the Framework continues:
'...In order to be appropriate, the cumulative impact of these standards and policies
should not put implementation of the plan at serious risk and should facilitate
development throughout the economic cycle....'
As advised above, the HSBCP site has a high existing use value and benefits from planning permission for further extensions to the retail park. The Viability Appraisal prepared by PBA on behalf of the Council, to support the Draft Development Brief, notes in section 3.3.1 that, "a reasonable benchmark land value could be considered in the region of £3m per net hectare across the whole masterplan area". This significantly underestimates the existing use value of the HSBCP site, let alone the potential value at which HSBCP would consider a sale of its asset. It is expected that other landowners will have a similar opinion. By way of illustration, the current estimate of the existing HSBCP use value is close to five times the value that PBA
have adopted. This message was reported to the Council and PBA on a number of occasions prior to the Viability Appraisal being issued.
The Viability Appraisal by PBA also sets out various other assumptions in section 3 (Viability Assumptions) that are considered to be inappropriate. As an illustration, in section 3.2.1 PBA stipulates that residential build costs for flats (6 stories and above) are £1,700 per sq. m.
Evidence supplied by Be:here and Prime Place, suggests that the PBA estimates are a significant underestimate of the true delivery costs, especially if the Council has aspirations for a high quality of design, with extensive public realm and landscaping. Recent tender information for similar developments suggests that the actual cost for buildings over six storeys would be in the region of £2,300 per sq. m GIA, excluding fees and abnormal costs.
Whilst it is appreciated that the Viability Appraisal covers a large area in multiple ownerships, the allowance for abnormal costs is unlikely to be sufficient, given the character of the area.
Certainly, the assumption of £500,000 per net hectare in Table 3.7 would not be sufficient to cover remediation and other abnormal costs on the HSBCP site. This has also been communicated to PBA in consultation at their offices in Bristol.
Table 3.8 includes a list of infrastructure items and estimated costs that have not been calculated by PBA and have been taken from third parties, although the sources are omitted.
Further information should have been provided to determine whether these costs are
appropriate, such as whether the cost of the two schools include the cost of the land as well as construction costs, as well as a more detailed assessment of cost of facilities at and around the station which seem low.
The Viability Appraisal concludes:
"The viability position identifies that a surplus of some £31m is available from the
scheme, which could be used in contributing towards associated infrastructure items
which have not been included in costing the scheme.
The Council have identified five large infrastructure items which potentially need to be provided within the Watford Junction development area, and the approximate estimated £56m total cost for these items has been compared to the overall residual value of the scheme. This appraisal concludes that the headroom falls only marginally short of being able to fund all of the infrastructure item costs, and should the proportion of policy compliant affordable housing reduce from 35% to being closer to 20%, then the scheme would have more chance of meeting the costs in full.
But should it be in the Council's interest to ensure that the scheme is policy compliant and that it does deliver the required 35% affordable housing, then external funding is likely to be needed to plug the gap in funding the big ticket infrastructure items."
As noted, it is felt that many of the assumptions adopted by PBA do not reflect current market prices and, therefore, the conclusion of the PBA report is misleading.
The Viability Assessment should reflect a more accurate position, to enable the Council to have a realistic expectation of the amount landowners can actually provide in terms of affordable housing and infrastructure contributions and plan accordingly. A more realistic base case would then provide developers with confidence that the vision is deliverable and enable the masterplan to be realised. If schemes exceed expectations then the Council could share in this surplus via a clawback mechanism in the Section 106 Agreement, without inhibiting development in the first place. Otherwise, it is likely that sites will be not taken forward and the masterplan will not be implemented.
Movement Hierarchy
Please note that Penn Road is within the ownership title of HSBCP (HD152573) for the exclusive use of the retail park. The Draft Development Brief suggests that this access road would be extended to open up other land ownerships, in particular the adjacent land to the east owned by Network Rail (Station Quarter West) and potentially land on the other side of the railway lines.
Whilst HSBCP are willing to contemplate the grant of this access to adjoining owners if development of their own land is feasible and takes place in a substantial form, it is inappropriate to presume that consent will be forthcoming. An understanding of the capacity will be required to determine whether the junction can sustain the level of use being proposed and the impact on the HSBCP ownership. However, it is fair to assume that this access would have significant implications on the continuation of the site as a retail park and result in a
significant diminution of value. Even if HSBCP were to allow access to other sites, to enable the wider masterplan to be realised, it must not create any capacity issues that could subsequently prevent HSBCP from fully utilising their site and the access must be recognised in any planning obligations discussions and viability assessment.
Land Uses
Section 3.2 of the Draft Development Brief states, "a primary school will be provided (on the HSBCP site) to support the residents of the area, comprising one form entry per 500 new residential units". The lawful planning principles of making contributions to meet the needs of a development and mitigate impacts arising from a development scheme is that the obligations may only constitute a reason for granting planning permission if they meet the tests that they are necessary to make the development acceptable in planning terms, directly related to the development, and fairly and reasonably related in scale and kind. These tests are set out as statutory tests in the Community Infrastructure Levy Regulations 2010 and as
policy tests in the National Planning Policy Framework. It is not known at this stage whether every 500 residential units would all require school places related to the tenure proposed and this requirement could fail these tests.
In addition, page 11 of the Draft Development Brief shows a location to the west of St Albans Road on Bedford Street as a 'Potential School Location' although this is identified for residential development in other parts of the document and is not included in the Individual Development Sites. Another school is shown on the other side of the railway tracks on page 18 (Land Uses). Greater clarity should be provided on the location and criteria of the school and consideration should be given to appropriateness of individual sites for school use.
The HSBCP site is situated in a central urban area, in close proximity to Watford Junction Station and the core commercial area. It is likely that the number of families with children living in the development would be limited, especially as a large quantum of the accommodation is intended to be delivered for the private rented sector, which studies show, tend to appeal to young professionals rather than families.
Whilst it is understood that there is a need to provide new on-site education provision within the wider scope of the Draft Development Brief, it is not considered that the delivery of a new primary school on the HSBCP site is appropriate. It is likely to be one of the earlier phases, at which point there is unlikely to be sufficient demand from the regeneration of the SPA2 area and planning obligations cannot lawfully be used to meet the existing school demands and under provision of school places in the area.
The Development Brief should provide guidance on a contribution formula for meeting the identified school places needs of the proposed housing to provide certainty for development schemes. This would increase the chance of the earlier phases of development to actually be delivered, particularly given the overall expected infrastructure requirements.
Maximising Efficiency of Land
Section 3.2 of the Draft Development Brief states, "development should not exceed a maximum plot ratio of 2.5 (GEA/Site Area), including all undercroft and above ground parking".
This is an antiquated means of assessing or guiding the acceptable scale and form of
development. It is rarely applied in an environment where highly sustainable previously developed sites are required to optimise the development potential to maximise the efficient use of a finite resource.
The HSBCP site extends to approximately 2.52 hectares, which would equate to a maximum development of 63,000 sq. m based on this plot ratio. Page 42 of the Draft Development Brief
then states that the density of the HSBCP Site would be 246 dwellings per hectare with 622 units and 61,060 sq. m on a site area of 2.52 hectares.
The Council's 'SKYLINE Approach to Taller Buildings SPD (2016)', highlights that Watford Junction is one of the areas where taller building may be suitable. This document notes, "If sited and designed appropriately, taller buildings can bring benefits in terms of a more compact urban form based on good public transport accessibility and quality place-making".
The HSBCP site has a high existing PTAL rating as it is in very close proximity to Watford Junction station further improved linkages proposed as part of the masterplan. The actual density calculation of an acceptable development (in terms of units or habitable rooms per hectare) is a product of all the relevant design and management factors. With good quality design that broadly accords with the heights outlined on page 19 within the Draft Development Brief, we would expect a density range of 400-450 dwellings per hectare to be more
appropriate. The Council should take a design-led approach to density or adopt guidance more akin to the Greater London Authority The London Plan (March 2016 - policy 3.4 and Table 3.2) setting guidance based on the PTAL rating of the site.
Retail Provision
Page 44 of the Draft Development Brief identifies 1,694 sq m (GEA) of active ground floor uses. Whilst we generally support the need to provide ground floor activity in certain locations, the precise level of ground floor commercial uses needs to be considered in the context of market demand and on the basis that the Station Quarter West area is proposed as the 'commercial centre' of the masterplan.
The dispersal of commercial floorspace throughout each quarter of the masterplan may not necessarily be the most appropriate approach and flexibility around market demand for commercial space outside of the commercial centre needs to be applied.
Car Parking
Page 42 of the Draft Development Brief states that car parking provision should range between 0.40 - 0.58 spaces per dwelling.
In such a highly sustainable public transport location as Watford Junction with its high PTAL rating the provision of car parking at a ratio of 0.40 - 0.58 is considered to be high and does not seek to promote sustainable modes of travel or reflect the likely levels of car ownership in such a development proposal. Car-free development and reduced parking ratios should be positively encouraged to limit highway impacts.
We look forward to formal acknowledgement of these representations and request that we are kept informed about further developments of the Development Brief and planning policy.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 587

Received: 03/10/2016

Respondent: TJX Europe

Agent: Savills

Representation Summary:

Supportive of the principles of the WJDDB and its objective to deliver a mixed use neighbourhood

Full text:

We write on behalf of our client, TJX Europe Limited, to provide formal representations to the Watford Junction Draft Development Brief ('WJDDB').
These representations are submitted in accordance with the prescribed timetable for consultation which expires on Monday 03 October 2016.
As officers of the Local Planning Authority ('LPA') are aware, TJX Europe Limited is currently engaged in formal pre-application discussions in respect of significant development on land to the south of the Masterplan area.
The proposed development at the northern end of Clarendon Road includes the creation of approximately 25,000 sq. m of new office floorspace (Class B1) and a series of associated physical works to link two existing buildings. The intention is to create a new office campus facility that will become the company's European head quarters and meet its requirements now and in the future.
TJX Europe Limited is proposing to make a significant investment into Watford, in terms of both capital expenditure and its staff, and is keen to engage proactively with the formulation and delivery of local planning policy.
In summary, the Company is supportive of the principles of the WJDDB and its objective to deliver a mixed use neighbourhood. Watford has significant aspirations and requirements to grow over the period of the Core Strategy and the area around Watford Junction station is considered to be one of the main opportunities to accommodate a range of uses.
Below we provide some more detailed comments on The Masterplan and its vision, objectives and site principles.
The Masterplan
Chapter Two of the WJDDB sets out the overall masterplan for the area, including the area-wide vision and principles, land uses, building heights, and car parking.
We comment on each of these main issues below.
Vision and Objectives
The WJDDB sets out six overarching objectives for the area.
Objective 1 states:
Create a new and improved major transport interchange, which encourages the use of multi-modal public transport and provides adequate station car parking.
The creation of an improved transport interchange will not only have positive impacts on the defined Masterplan area, but also the town as a whole. It will help to deliver wider economic growth and serve the anticipated growth in population.
Improving accessibility to the area by sustainable modes of transport will have positive impacts upon local traffic flows, air quality, and will increase the desirability of the area for businesses looking to locate there.
Objective 6 states:
Improve the built and environmental quality of Watford Junction as a place to live and as a landmark gateway to the town centre and Watford as a whole.
Watford Junction station is one of the principal gateways to the town and the objective to make this a 'landmark gateway' is strongly supported.
Improving the quality of the built form will assist in attracting further investment and businesses to Watford as well as having social and other benefits for residents and visitors.
Site Wide Principles
In respect of scale and massing, the document acknowledges that there will need to be a change in the scale of the built form in Watford in order to accommodate the growth in population and the required increase in commercial and employment floorspace.
The Masterplan states that the highest buildings should be located close to the train station, and then step down away from that area to blend in with the surrounding area. This accords with the principles of good design and is strongly supported.
Grouping the tallest buildings around the commercial hub of the station will lessen the visual impact of new development and protect the established key views and vistas. Furthermore, the train station is one of the most accessible locations and therefore dense development in this location accords with the overarching objectives to deliver sustainable forms of development.
The Core Strategy also identifies a requirement for the creation of approximately 80,000 sq. m of additional Class B floorspace by 2030. The local policy framework also identifies Clarendon Road as the preferred location for office floorspace within the town. It is anticipated that to meet the requirements in terms of new employment positions1 there is going to be significant development along Clarendon Road over the plan period. The established built form, including building heights, is anticipated to evolve and this can align with the principles set out in the Masterplan with height focussed around the station.
Illustrative Masterplan
The Illustrative Masterplan sets out the following approximate floor areas for acceptable land uses:
1 Between 3,500 - 4,200 are expected to be provided within the town centre area by 2030.
 Residential - 2,777 units
 Employment - 73,920 sq. m
 Retail - 6,135 sq. m
 Gym - 789 sq. m
 School - 2 x 3,000 sq. m
 Community - 1,883 sq. m
 Car Parking - 3,771 sq. m
In respect of the employment floor space, the masterplan envisages 73,920 sq. m can be accommodated on the site2.
It is a policy objective of the LPA within Policy EMP1 of the Watford Core Strategy to provide at least 7,000 additional jobs up to 2031. We therefore agree that the masterplan should incorporate a significant proportion of employment floorspace to help meet the wider Watford requirement.
Similarly to the objective for buildings heights above, the promotion of employment uses will have knock-on positive consequences for the wider area, especially Clarendon Road, as it will confirm the status of that corridor as an office location.
Summary and Conclusion
In summary, we support the main objectives and principles for development within the WJDDB area.
In particular, we support the principle of promoting a mix of commercial and residential uses. This will help to create a vibrant and successful area that meets the requirements of both businesses and residents.
We also strongly support the principle of making Watford Junction train station a landmark gateway, which will help to regenerate the wider area outside of the Masterplan area. Focussing taller buildings around the train station is also a principle we support, especially given it is the most accessible location and it will help to protect established views.
We trust these comments will be taken into consideration in the production of the WJDDB. We also request that we are kept informed about progress of the document, and notified when the next stage of consultation will take place. I look forward to receiving confirmation to this effect.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 590

Received: 03/10/2016

Respondent: LaSalle Investment Managmenet (LaSalle)

Agent: GERALD EVE LLP

Representation Summary:

Supports the comprehensive plans for the redevelopment

Full text:

please see attachment

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 598

Received: 10/10/2016

Respondent: Historic England

Representation Summary:

Concerned that there is no mention of the positive contribution that the conservation of heritage assets can make to sustainable communities, including their economic vitality and local character and distinctiveness and would be keen to see a positive strategy for the conservation of the historic environment incorporated into a vision for the area.

Full text:

Consultation Responses

a) Watford Local Plan - Part 2: Site Allocations and Development Management Policies - Publication Version July 2016 and accompanying Watford Local Plan Part 2 Publication Stage Environmental Report August 2016.

b) Draft Watford Junction Development Brief

c) Croxley View/Ascot Road Study

WATFORD LOCAL PLAN - PART 2: SITE ALLOCATIONS AND DEVELOPMENT MANAGEMENT POLICIES - PUBLICATION VERSION JULY 2016 AND ACCOMPANYING WATFORD LOCAL PLAN PART 2 PUBLICATION STAGE ENVIRONMENTAL REPORT AUGUST 2016.

Thank you for consulting Historic England on the submission draft of the Local Plan Site Allocations and Development Management Policies Document.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment.

We very much welcome the references to the historic environment made throughout the draft development framework document and appreciate the effort made to acknowledge the positive contribution to character and placemaking that the historic environment can bring. The document has been set out clearly and is commendably accessible in format. The following amendments are therefore suggested to ensure that the draft SPD fully reflects the statutory requirement to take into account opportunities to draw on the contribution made by all elements of the historic environment.

You will note that we have previously responded to earlier drafts of this document in February 2015 and to an addendum incorporating a Taller Buildings policy in February 2016. Whilst we commended the Borough's comprehensive evidence base incorporating Conservation Area Appraisals and a managed local list of locally important structures, we also requested that some changes be made to the document; particularly consistency of approach to the conservation and enhancement of the historic environment.

Whilst we would not normally expect to offer substantive comment at submission stage, we note that few of the changes requested at earlier stages have been incorporated into the final submission document and this response therefore reiterates our preferred changes to ensure that the plan adequately sets out a positive strategy for the historic environment as required by the NPPF and fulfils the Sustainable Community Objective to be a town that protects its environment and heritage set out within Watford Borough Council's adopted Core Strategy (2013).
We encourage ongoing dialogue and request to be notified of the date of the Examination in Public by the Secretary of State as we may wish to make representations.

Heritage Policies

Policy UD4 - The Historic Environment

We are pleased to see a specific policy addressing the conservation of the historic environment . However we have the following comments to make regarding necessary changes for a sound Local Plan.

Listed Buildings and their setting

The NPPF requires that when considering the impact of a proposed development on the significance of a designated asset, great weight should be given to the asset's conservation. Significance can be harmed by development within the setting of the listed building and substantial harm (including to the setting of a listed building) should be wholly exceptional.

By separating the 'setting of a listed building' from the section on 'listed buildings', the plan implies that a lesser degree of significance is accorded to the setting of a listed building than to a listed building itself.

As submitted, references to the need for wholly exceptional circumstances refer only to the demolition of listed buildings. This does not reflect the NPPF which sets out that substantial harm or loss of highly significant listed buildings (Grade II* or I), which can include harm to the setting of such a building, should be wholly exceptional.

We are also concerned that in consideration of setting, the current policy states that in the event of harm to or loss of significance, this should be weighed against public benefit. This is the role of the planning system but we feel that a more robust strategy for the conservation of the historic environment should set out that harm or loss of significance of the setting of a listed building will not be acceptable.
We strongly encourage the Borough to combine listed buildings and their setting for a robust and NPPF compliant policy that sets out a positive strategy for the conservation and enjoyment of historic environment.

Development in the vicinity of a listed building

We request the following amendment to ensure that the Council's policy for the conservation of the historic environment is appropriate to ensure that listed buildings are given due consideration in the determination of planning applications for development. Without this alteration, the policy relates solely to development of the listed building itself with no other policy for the protection of the significance of listed buildings when development is beyond the listed building.

The Council will preserve the character and setting of the borough's listed buildings and will support applications where:

* The extension/alteration of a listed building development would not adversely affect its character as a building of special architectural or historic interest; both internally and externally, or adversely affect its wider setting.

Conservation Areas

We request the following minor amendments;

Within conservation areas, development will be supported where it:

* Uses materials, finishes, including those for features such as walls, railings, gates and hard surfacing, that are appropriate to local context preserve or enhance the character of the Conservation Area.
* Results, where relevant, in the removal of unsympathetic features and the restoration or reinstatement of missing features.

All other bullet points are supported as consulted.

Demolition in Conservation Areas

We encourage robust policy protection for Conservation Areas and we are pleased to see this addressed within the local plan. We caution however, that the local plan should not be more stringent than the requirements within the NPPF as this may weaken the application of the policy. As such, the first and third bullet points are very welcome. The intent of the second bullet point is understood. This may be a hard policy test in practice however, as, theoretically, all buildings are capable of repair and some beneficial use, even if not suitable or viable. We caution that the use of a difficult test may lead to the entire policy (and decisions based on it) which seek to appropriately conserve the historic environment being challenged at appeal. We suggest that this bullet point is omitted to strengthen the policy.

We request the following omission from the text;
Permission will not be granted for development outside of but near to a conservation area which adversely affects the setting, character, appearance of or views into and out of that conservation area.

This allows for consideration of any affects to a Conservation Area without having to define the difficult question of what is 'near' to the site or not.

Future Designations

Watford Borough Council has a commendable history of local listing, conservation area appraisal and review of its surviving historic environment. It would be a positive strategy to embed this positive approach to heritage conservation within the draft local plan with a policy supporting future designations of locally listed buildings, registered parks and gardens and other heritage assets,

General Comments

Glossary

Listed Buildings and Locally Listed Buildings appear twice. In each case, the first definition is the most appropriate.

Policy SPMX1 - Special Policy Areas

This omits the wording suggested in our previous letter dated 04/02/15 which requested that the sentence Development proposals should accord with the related Core Strategy Policy be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that the principle of development does not override the need to comply with other adopted policies including those that seek to enhance and protect the historic environment.

Policy SPMX2 - Mixed Use Allocations Policy

As this policy states that development will be appropriate on these sites, it is important to ensure that the historic environment is appropriately considered. The mechanism for this is through robust development considerations as set out in Appendix I.

These are acceptable in many places but references to the historic environment are not consistently presented and in some cases there are gaps, as set out in our previous advice of February 2015. In some of these sites, heritage assets in the locality are named and even graded where in others they are partially identified or omitted altogether, even where they are within the allocated site. For this reason I have reviewed the wording of each site within Appendix I - Site Schedules in the table attached to these comments and request that any suggested changes be incorporated to ensure that the protection and enhancement of the historic environment is a consideration for future developers and not contrary to the presumption in favour of development.

See attached table for detailed comment on Appendix I.

Policy TLC9 - Character Areas

This policy refers to the character areas within Watford Town Centre. We would welcome the following minor amendments to the wording;

* Recognition that Character Area ii - the Cultural Area includes the named Civic Core Conservation Area and many listed and locally listed buildings. Additional clarity is considered particularly necessary given that the Environmental Report accompanying the policy document determines that the impact of the character area designation on 'heritage' is neutral (See Page 41 of the Environmental Report accompanying the submission)..
* Recognition that the Palace Theatre and Colosseum are Grade II listed buildings.
* The text relating to Character Area vii - Heritage Area St Mary's and High Street/King Street Conservation Areas does not reflect the amendment requested in our letter of February 2016 which requested the following addition;
The primary concern in these areas is the impact of any proposed development on the designated heritage assets. The Council will expect proposals for development in these areas to actively seek to enhance the identified character and appearance of the conservation areas and the settings of the listed buildings and other heritage assets within and adjoining them.

We are supportive of the Council's encouragement of the redevelopment of the Church Car Park as this is an opportunity to better respond to the Grade I St Mary's Church and the thirteen Grade II structures in its immediate locality, including Watford's remaining Tudor houses the Grade II listed Bedford Alms Houses. The setting of the church is an important part of its significance and developers should be asked to give this careful consideration to this building of exceptional national significance. As such, we again request the above addition to the policy wording.
Policy EMP4 - Change of Use from B Class Outside of Designated Employment Areas

We request that the sentence The proposal must also be compatible with surrounding uses be continued with the words and guidance on environmental considerations contained in this plan. This would demonstrate that compatibility with surrounding uses does not overcome the need to consider the historic environment and relevant policies within the Local Plan.

Policy EMP5 - Clarendon Road, Station Road and Bridle Path Office Area

This area contains a number of locally listed buildings the retention of which would be beneficial to refer to within this policy to offer them a degree of protection. Retention of these locally listed buildings could enhance the townscape and character of the future office quarter and we encourage reference to them within this policy.

Policy SD6 - Renewable Energy Technology , Policy SD15 - External Lighting Policy & Policy INF2 - Mobile Communications

We are pleased to see the incorporation of the historic environment within the text of these policies. We recommend that the last bullet point in Policy SD15 - External Lighting Policy be altered from heritage assets to historic environment for consistency and to allow greater flexibility in protecting the historic environment beyond designated assets.

Policy TB1 - Location of taller buildings

We are disappointed to note that our detailed advice of February 2016 has not translated into amendments to the wording of the draft policies.

We again submit the following suggested amendments, in the awareness that the proposed locations are in close proximity to the historic core of Watford, several listed and locally listed buildings and Conservation Areas.

The majority of Watford is characterised by low level residential and other forms of development where taller buildings would generally be considered inappropriate. All development needs to be designed in order to respect, reinforce and enhance the local character, including historic character, of the area in which it is located and to contribute to Watford's distinctive sense of place and identity as referred to in Policy UD1 of the Core Strategy....

... (Watford Junction SPA2): The Watford Junction Masterplan should be referred to for further detail on how the pinnacles should be incorporated into the wider townscape and to achieve a positive strategy for the conservation and enjoyment of the historic environment.

The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage (See page 62 of the Environmental Report).

Policy TB2 - Design of Taller Buildings

Please alter 'heritage assets' to 'the historic environment' throughout the document to ensure the widest possible application of the policy to historic places and non-designated heritage assets.

We recommend the inclusion of 'high' in front of quality within the discussion of public realm (point 8).

We note that Criterion 10 - Heritage has been removed. As a result it is particularly important to ensure that the remaining criteria adequately allow for protection of the historic environment.

We note that the accompanying Environmental Report finds that the impact of Policy TB2 is positive or 'sustainable' with regard to Watford's Historic Environment (see page 62 of the accompanying Heritage Report). The change of terminology from within the policy text from heritage assets to historic environment may assist in mitigating harm from taller buildings to ensure that the policy can be considered sustainable.

Appendix I - Site Schedules

We reiterate our comment that we would not normally expect to offer substantive changes to the Local Plan at submission stage. However, as previous suggestions have not been incorporated with regard to the historic environment and clarity of presentation of heritage considerations, we request the following revisions to the text.

These changes will be necessary to ensure that the plan adequately takes into account the desirability of sustaining and enhancing the significance of heritage asserts and identifies opportunities to draw on the contribution made by the historic environment to the character of Watford.

Site Comments Justification
SPA1 - Town Centre Replace 'Heritage assets' with The Historic Environment. Please add the following point: Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Little Cassiobury and Former Stable Blocks (registered on the national Heritage at Risk register) will be given significant weight. The historic environment encompasses more than designated heritage assets. The NPPF requires that a local plan sets out a positive strategy for conservation and enjoyment of the historic environment including heritage assets most at risk through neglect, decay or other threats. As this Grade II* listed building, which is on the Heritage at Risk register is not otherwise mentioned within the Local Plan, it is appropriate to mention a positive strategy for its conservation in Policy SPA1. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA2 - Watford Junction Please replace 4th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the adjacent Nascot Conservation Area, Grade II listed Benskins House (The Flag Public House), Reeds Crescent and other heritage assets within the area. Within the site, the conservation of the Grade II listed Old Station House and its setting should form part of the proposals. For consistency with the remaining policies, we recommend naming and grading the listed heritage assets referred to. For continuity with previous consultations, locally listed Reeds Crescent is retained as a named asset. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different name, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. Grade II Old Station House is within the site and its conservation should therefore be given emphasis. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA3 - Health Campus Please insert the preservation and enhancement of the setting of before 'the Square Conservation Area' at Bullet Point 9. Reuse of Grade I Iisted Shrodells Wing of Watford General Hospital is welcome (We note a typographical error in its name [Grade II listed) ) as is due consideration to the Square Conservation Area.
SPA4 - Lower High Street Please replace 6th Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street and the Grade II listed Bushey Arches. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. This is amended for consistency of approach with regard to heritage assets and to ensure that all of the nine listed buildings/structures and other locally listed buildings within the site are captured, not just the two mentioned. Reference to Grade II* listed Frogmore House is amended for consistency with Little Cassiobury at Policy SPA1. The wording seeks an appropriate scheme of repair and reuse rather than 'restoration' which has a specific meaning in terms of conservation and may not be appropriate. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA5 - Dome Roundabout No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
SPA6 - Western Gateway No comment As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site MXD1 - North Watford Library/ Lemarie Centre No comment No comment
Site MXD2 - The Brow No comment No comment
Site MXD3 - Gas Holder Site Please add: Design and development will need to be sympathetic to the significance and setting of the cluster of Grade II listed buildings and structures and locally listed buildings on Lower High Street. Development which proposes an appropriate scheme of repair and reuse for Grade II* listed Frogmore House (registered on the national Heritage at Risk register) will be given significant weight. We welcome the requirement for archaeological assessment and a heritage statement. We reiterate our comments with regard to Policy SPA4.
Site MXD4 - Ascot Road No comment No comment
Site R1 - Sainsbury's and adjoining land Please replace the 4th Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Monmouth House and Nos. 151-153 High Street. Proposals should preserve and enhance the Civic Core Conservation Area and its setting. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street and a potential Roman Road, and adjacent to the point that they are believed to meet we request archaeological assessment where appropriate.
Site R2 - Former TJ Hughes and adjoining land Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Grade II listed Palace Theatre, Beechen Grove Baptist Church and Nos. 14-16 The Parade as well as locally listed buildings at Nos. 11-33 The Parade. Proposals should preserve and enhance the setting of the adjacent Civic Core Conservation Area. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R3 - BT Telephone Exchange and adjoining warehouses Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 14-16 and No 58 High Street which will be expected to be retained. The significance and setting of the adjacent Grade I listed Holy Rood Church and St. Mary's Church and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is in the vicinity of two Grade I listed buildings. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site R4 - Church Street Car Park and land fronting Market Street Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade I listed building of St Mary's Church and Grade II* listed Elizabeth Fuller Free School and the cluster of Grade II buildings and structures to the south of the site. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan, particularly as the site is within the core of surviving historic buildings and open spaces within Watford, including Grade I St.Mary's church and its open setting. Please note that the Elizabeth Fuller Free School is Grade II* listed, not Grade II listed as noted in the consultation document wording. As an area encompassing known archaeological deposits, we welcome the need for archaeological assessment where appropriate.
Site R5 - Charter Place Please replace the 3rd Bullet Point with: Design and development will need to be sympathetic to the significance and setting of the Grade II listed buildings of Nos. 63-65 High Street which will be expected to be retained. The significance and setting of the adjacent Grade II listed No. 58 High Street, the Beechen Grove Baptist Chapel and the Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the St.Mary's Conservation Area and its setting. Amendments suggested for consistency in approach to heritage assets across the plan. We request the removal of any reference to the frontage of Nos. 63-65 High Street which may encourage façade retention rather than the more appropriate retention of the building as a whole. As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate.
Site CF1 - Tolpits Community Facility No comment No comment
Site H1 - Pinner Road Please replace the 7th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent Oxhey Conservation Area, nearby Grade II listed buildings and other heritage assets within the area, particularly the locally listed Railway Arms Public House. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H2 - Skate Park, Lower Derby Road No comment No comment
Site H3 - Vicarage Road Please replace the 5th bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Red Lion Public House and Watford Printers Buildings and the Square Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H4 - Telephone Exchange, First Avenue No comment No comment
Site H5 - Builders Yard, Queens Avenue No comment No comment
Site H6 - Bill Everett Centre No comment No comment
Site H7 - Rickmansworth Road Please replace the 1st bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of Nos. 195-199 Rickmansworth Road. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site H8 - Garages, Gossamers No comment No comment
Site H9 - Metropolitan Station, Cassiobury Park Avenue Please replace the 3rd bullet point up to 'is required' with Design and development will need to be sympathetic to the significance and setting of the Grade II listed Watford Station. Amendments suggested for consistency in approach to heritage assets across the plan. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is uncertain with regard to heritage.
Site H10 - Croxley View No comment No comment
Site H11 - Garages Bowman's View No comment No comment
Site GT1 - Land at Tolpits Lane No comment No comment
Site E1 - Watford Business Park No comment No comment
Site E2 - Imperial Way/Colonial Way No comment As an area encompassing a potential roman road and later settlement, we welcome the need for archaeological assessment where appropriate. The suggested amendments to text are considered particularly necessary as the Environmental Report submitted with the Local Plan Part 2 notes the impact of this site allocation is neutral with regard to heritage.
Site E3 - Fishers No comment No comment
Site E4 - Greycaine Road Please replace the 3rd bullet point with: Design and development will need to be sympathetic to the significance and setting of the adjacent locally listed buildings of the Paramount Industrial Estate and Former Odhams Press Hall. Please add the following: An archaeological investigation may be required prior to application Amendments suggested for consistency in approach to heritage assets across the plan. As an area encompassing Roman Watling Street we request archaeological assessment where appropriate.
Site E5 - Clarendon Road Please replace 2nd Bullet point with the following: Design and development will need to be sympathetic to the significance and setting of the Grade II listed Benskins House (The Flag Public House) and the Beechen Grove Baptist Chapel and locally listed buildings clustered around Clarendon Road which will be expected to be retained. The significance and setting of the adjacent Grade II listed Palace Theatre and other heritage assets in the locality will also need to be considered as part of any suitable scheme of redevelopment. Proposals should preserve and enhance the setting of the adjacent Estcourt Conservation Area. Amendments suggested for consistency in approach to heritage assets across the plan.. The Grade II listed Benskins House (The Flag Public House) appears within the Local Plan under different names, we recommend the use of one name 'Benskins House (The Flag Public House)' throughout for clarity. As an area encompassing Roman Watling Street and later settlement, we welcome the need for archaeological assessment where appropriate.
Site E6 - Leavesden Studios No comment No comment

DRAFT WATFORD JUNCTION DEVELOPMENT BRIEF

Thank you for consulting Historic England on the submission draft of the Watford Junction: Draft Development Brief (August 2016).

We encourage the sensitive regeneration of this part of Watford and welcome a masterplan document offering guidance to future developers. We are aware of the many social and economic benefits that the development of the Watford Junction area aims to bring about.

Having reviewed the draft development brief we are concerned that there is no mention of the positive contribution that the conservation of heritage assets can make to sustainable communities, including their economic vitality and local character and distinctiveness.

We are particularly keen to see a positive strategy for the conservation of the historic environment incorporated as part of the vision for the area. This would then cascade into the subsequent development briefs for individual sites. The historic environment is greater than a list of designated assets and encompasses locally listed buildings, character areas, the area's historic development, use patterns, street morphology and social history and a successful development brief should seek to draw on the elements of an area's historic character that make it unique and distinctive. Successful developments balance historic character with the other positive aims of placemaking to make locally distinctive places.

The Draft Masterplan is to be adopted as a Local Plan document and should therefore respond to the NPPF's requirement that local planning authorities set out a positive strategy for the conservation and enjoyment of the historic environment.
To appropriately address this requirement, we recommend that the Baseline Assessment acknowledges the designated heritage assets within and directly adjacent to the site and identifies that the masterplan is an opportunity to draw on the contribution that the historic environment makes to local character.

The baseline assessment should clarify that the site contains two designated heritage assets (the Grade II listed Old Station House and the Nascot Conservation Area) as well as being sited in close proximity to areas of the same Conservation Area and other listed and locally listed buildings.

Some, but not all of the listed buildings are marked on the Opportunities Map within the Baseline Assessment (the Former London Orphan Asylum is omitted for instance). If these are to be marked, we request that all of the listed buildings within a defined radius are properly mapped to avoid giving the impression that the setting of some are more acceptable to respond to than others. None of the Locally Listed Buildings nor Conservation Areas are included. We suggest that the draft document reflects the information contained within Watford's Conservation Areas Management Plan (2013).

We strongly encourage the acknowledgement and recognition of the historic environment as an opportunity within the SWOT analysis within the baseline assessment and that the retention and conservation of the Grade II Listed Building be made an explicit aim of the document.

The Vision and Objectives page should reflect the positive conservation of the historic environment and acknowledge this as a critical element of successful placemaking. We recommend that an additional objective be added to draw on the contributions of the historic environment to produce a locally distinctive place.
We note that the subdivision of the development site into four character quarters fails to include the area of the site that is within the Nascot Conservation Area (and contains the Grade II listed building) within any of the proposed quarters. There is development potential within this neutral part of the Conservation Area which would particularly benefit from guidance as how to appropriately respond to the surrounding Nascot Conservation Area and we would welcome a positive approach to development in this location. This area, identified as Area 21 in the General Masterplan maps contained within the Area Schedule is also omitted from a dedicated analysis of a suitable quantum of development, provided for other identified sub-areas within the area schedule.

We recommend that the possible development of this area be addressed within any revised document.

In making any revisions to the document, we recommend that Historic England's guidance note 'The Historic Environment in Local Plans: Good Practice Advice in Planning 1' is considered and its recommendations incorporated into any subsequent draft.

This document can be found at the following location:
<https://content.historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/gpa1.pdf/>

I would also recommend that you review the following guidance which may be of assistance to you to produce robust policies on tall buildings and placemaking appropriate to the aims of the NPPF in terms of conservation of the historic environment:

<https://content.historicengland.org.uk/images-books/publications/tall-buildings-advice-note-4/heag037-tall-buildings.pdf/>

<https://content.historicengland.org.uk/images-books/publications/streets-for-all-east-of-england/east-eng-streets.pdf/>

Croxley View/ Ascot Road Study

Thank you for consulting Historic England on the draft Croxley View / Ascot Road Study. We note that there are no Historic Assets on site but note the Grade II listed building Cassio Bridge Lodge is sited to the north of the site and we encourage that any development proposals are considered with regard to setting of this building.
We have no comments to make on the developing brief.

Summary

In preparation of all local plan documents, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime, we look forward to continuing to work with you and your colleagues in the preparation of the Local Plan documents.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 601

Received: 03/10/2016

Respondent: Thames Water Utilities Ltd

Representation Summary:

Developers need to demonstrate that adequate capacity exists and that the brief needs to consider the new increase in wastewater and water supply demand to serve proposed developments and on the network.

Full text:

As you will be aware, Thames Water are the statutory sewerage undertaker for the Borough and are hence a "specific consultation body" in accordance with the Town & Country Planning (Local Planning) Regulations 2012. We have the following comments on the consultation document:
Sewerage/Wastewater Infrastructure
Thames Water seeks to work closely with the local authorities to plan for the necessary water and sewerage/wastewater infrastructure to service development in its area in accordance with the National Planning Policy Framework (NPPF) and the National Planning Practice Guidance (NPPG).
New development should be co-ordinated with the infrastructure it demands and to take into account the capacity of existing infrastructure. Paragraph 156 of the NPPF, March 2012, states:"Local planning authorities should set out strategic policies for the area in the Local Plan. This should include strategic policies to deliver:......the provision of infrastructure for water supply and wastewater...."
Paragraph 162 of the NPPF relates to infrastructure and states: "Local planning authorities should work with other authorities to: assess the quality and capacity of infrastructure for water supply and wastewater and its treatment.....take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."
The NPPG includes a section on 'water supply, wastewater and water quality' and sets out that Local Plans should be the focus for ensuring that investment plans of water and sewerage/wastewater companies align with development needs. The introduction to this section also sets out that "Adequate water and wastewater infrastructure is needed to support sustainable development" (Paragraph: 001, Reference ID: 34-001-20140306).
It is important that developers demonstrate that adequate capacity exists both on and off the site to serve the development and that it would not lead to problems for existing users. In some
Sent by email to: strategy@watford.gov.uk
thameswaterplanningpolicy@savills.com
0118 9520 500
3rd October 2016
circumstances this may make it necessary for developers to carry out appropriate studies to ascertain whether the proposed development will lead to overloading of existing water & sewerage infrastructure. Where there is a capacity problem and no improvements are programmed, then the developer needs to contact the water company to agree what improvements are required and how they will be delivered prior to any occupation of the development.
It is therefore important that the Development Brief considers the net increase in wastewater [and water supply] demand to serve proposed developments and also any impact the development may have off site further down the network, if internal/external sewage flooding of property [and no/low water pressure] is to be avoided.
Thames Water therefore recommend that developers engage with them at the earliest opportunity to establish the following:
 The developments demand for wastewater treatment and sewerage network infrastructure both on and off site and can it be met
 The surface water drainage requirements and flood risk of the development both on and off site and can it be met
To accord with the NPPF and the above, text along the lines of the following should be added to the Development Brief:
"Wastewater & Sewerage Infrastructure
Developers will be required to demonstrate that there is adequate waste water capacity and surface water drainage both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing wastewater/sewerage infrastructure.
Drainage on the site must maintain separation of foul and surface flows. It is the responsibility of a developer to make proper provision for surface water drainage to ground, water courses or surface water sewer. It must not be allowed to drain to the foul sewer, as this is the major contributor to sewer flooding
Where there is an infrastructure capacity constraint the Council will require the developer to set out what appropriate improvements are required and how they will be delivered. "
It should be noted that in the event of an upgrade to Thames Water's assets being required, up to three years lead in time will be potentially necessary for the delivery of the infrastructure; alternatively the developer may wish to requisition the infrastructure to deliver it sooner.
Thames Water must also be consulted regarding proposals involving building over or close to a public sewer. If building over or close to a public sewer is agreed by Thames Water it will need to be regulated by an Agreement in order to protect the public sewer and/or apparatus in question. It may be possible for public sewers or water mains to be moved at a developer's request so as to accommodate development.
Comments on the Proposed Sites
The wastewater network capacity in this area may be unable able to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure are may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 692

Received: 03/10/2016

Respondent: Thames Water Utilities Ltd

Representation Summary:

Wording has been recommended for Wastewater and Sewerage Infrastructure regarding capacity and surface water drainage, potential studies to ascertain capacity and to maintain separation of foul and surface flows.

Full text:

As you will be aware, Thames Water are the statutory sewerage undertaker for the Borough and are hence a "specific consultation body" in accordance with the Town & Country Planning (Local Planning) Regulations 2012. We have the following comments on the consultation document:
Sewerage/Wastewater Infrastructure
Thames Water seeks to work closely with the local authorities to plan for the necessary water and sewerage/wastewater infrastructure to service development in its area in accordance with the National Planning Policy Framework (NPPF) and the National Planning Practice Guidance (NPPG).
New development should be co-ordinated with the infrastructure it demands and to take into account the capacity of existing infrastructure. Paragraph 156 of the NPPF, March 2012, states:"Local planning authorities should set out strategic policies for the area in the Local Plan. This should include strategic policies to deliver:......the provision of infrastructure for water supply and wastewater...."
Paragraph 162 of the NPPF relates to infrastructure and states: "Local planning authorities should work with other authorities to: assess the quality and capacity of infrastructure for water supply and wastewater and its treatment.....take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."
The NPPG includes a section on 'water supply, wastewater and water quality' and sets out that Local Plans should be the focus for ensuring that investment plans of water and sewerage/wastewater companies align with development needs. The introduction to this section also sets out that "Adequate water and wastewater infrastructure is needed to support sustainable development" (Paragraph: 001, Reference ID: 34-001-20140306).
It is important that developers demonstrate that adequate capacity exists both on and off the site to serve the development and that it would not lead to problems for existing users. In some
Sent by email to: strategy@watford.gov.uk
thameswaterplanningpolicy@savills.com
0118 9520 500
3rd October 2016
circumstances this may make it necessary for developers to carry out appropriate studies to ascertain whether the proposed development will lead to overloading of existing water & sewerage infrastructure. Where there is a capacity problem and no improvements are programmed, then the developer needs to contact the water company to agree what improvements are required and how they will be delivered prior to any occupation of the development.
It is therefore important that the Development Brief considers the net increase in wastewater [and water supply] demand to serve proposed developments and also any impact the development may have off site further down the network, if internal/external sewage flooding of property [and no/low water pressure] is to be avoided.
Thames Water therefore recommend that developers engage with them at the earliest opportunity to establish the following:
 The developments demand for wastewater treatment and sewerage network infrastructure both on and off site and can it be met
 The surface water drainage requirements and flood risk of the development both on and off site and can it be met
To accord with the NPPF and the above, text along the lines of the following should be added to the Development Brief:
"Wastewater & Sewerage Infrastructure
Developers will be required to demonstrate that there is adequate waste water capacity and surface water drainage both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing wastewater/sewerage infrastructure.
Drainage on the site must maintain separation of foul and surface flows. It is the responsibility of a developer to make proper provision for surface water drainage to ground, water courses or surface water sewer. It must not be allowed to drain to the foul sewer, as this is the major contributor to sewer flooding
Where there is an infrastructure capacity constraint the Council will require the developer to set out what appropriate improvements are required and how they will be delivered. "
It should be noted that in the event of an upgrade to Thames Water's assets being required, up to three years lead in time will be potentially necessary for the delivery of the infrastructure; alternatively the developer may wish to requisition the infrastructure to deliver it sooner.
Thames Water must also be consulted regarding proposals involving building over or close to a public sewer. If building over or close to a public sewer is agreed by Thames Water it will need to be regulated by an Agreement in order to protect the public sewer and/or apparatus in question. It may be possible for public sewers or water mains to be moved at a developer's request so as to accommodate development.
Comments on the Proposed Sites
The wastewater network capacity in this area may be unable able to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure are may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application.