Watford Junction Draft Development Brief

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Comment

Watford Junction Draft Development Brief 2016

Representation ID: 693

Received: 03/10/2016

Respondent: Thames Water Utilities Ltd

Representation Summary:

On 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 may be required to ensure sufficient capacity is brought forward ahead of the development.

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: 694

Received: 10/10/2016

Respondent: Historic England

Representation Summary:

Baseline Assessment required 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. It 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. All these features should be mapped.

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.

Object

Watford Junction Draft Development Brief 2016

Representation ID: 695

Received: 03/10/2016

Respondent: Mrs Hazel Harkin

Representation Summary:

Need for a doctors surgery in the area

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.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 696

Received: 03/10/2016

Respondent: Mrs Hazel Harkin

Representation Summary:

Supports primary school.

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: 697

Received: 03/10/2016

Respondent: Mrs Hazel Harkin

Representation Summary:

Negative landscape impacts as a result of buildings over 4 stories.

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: 698

Received: 03/10/2016

Respondent: Mrs Hazel Harkin

Representation Summary:

Insufficient parking for residential units.

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.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 699

Received: 03/10/2016

Respondent: Mrs Hazel Harkin

Representation Summary:

Questions where the bus capacity will be able to cope?

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: 700

Received: 03/10/2016

Respondent: Mrs Hazel Harkin

Representation Summary:

Number of homes should be reduced

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: 701

Received: 03/10/2016

Respondent: Mrs Hazel Harkin

Representation Summary:

Small individual properties should be proposed with gardens rather than flats. This is more in keeping with the local area

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: 702

Received: 03/10/2016

Respondent: Mrs Hazel Harkin

Representation Summary:

The proposed shops/cafes should be monitored as there too many food outlets already

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.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 703

Received: 16/09/2016

Respondent: N/A

Representation Summary:

The plan should show where the main pedestrian area will be.

Full text:

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

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

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

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 704

Received: 22/09/2016

Respondent: N/A

Representation Summary:

Housing will lead to greater impacts on train services

Full text:

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

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

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

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

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

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 705

Received: 22/09/2016

Respondent: N/A

Representation Summary:

There is no need more shops or restaurants in this area.

Full text:

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

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

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

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

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

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 706

Received: 22/09/2016

Respondent: N/A

Representation Summary:

Need for garages to cater for cars

Full text:

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

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

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

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 707

Received: 29/09/2016

Respondent: Mr Thomas Parsons

Representation Summary:

Concern regarding the volume of traffic added to the ever worsening parking problem

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?

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 708

Received: 02/10/2016

Respondent: Central Town Residents' Association

Representation Summary:

Attempts to limit the unsightly effects of massing tall buildings and setting some of then back from the building lines will be insufficient to avoid "manhattenising" parts of the development area.

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: 709

Received: 02/10/2016

Respondent: Central Town Residents' Association

Representation Summary:

Amenity areas could be improved, perhaps to one or two medium-sized plots which would be better.

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: 710

Received: 02/10/2016

Respondent: Central Town Residents' Association

Representation Summary:

Consultation for a Delivery Plan should be undertaken as the further stages are developed.

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: 711

Received: 28/10/2016

Respondent: Mary Forsyth

Representation Summary:

Agrees with Point 12 - but is it possible to provide suitable transport arrangements e.g. parking, buses, taxis, drop off points

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 713

Received: 03/10/2016

Respondent: TJX Europe

Agent: Savills

Representation Summary:

States that improving accessibility to the area by sustainable modes of transport will have positive impacts for the town as a whole.

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: 714

Received: 03/10/2016

Respondent: TJX Europe

Agent: Savills

Representation Summary:

Objective to make Watford Junction a landmark gateway is strongly supported.

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: 715

Received: 03/10/2016

Respondent: TJX Europe

Agent: Savills

Representation Summary:

The principles that see the highest buildings close to the train station is good design and is strongly supported

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: 716

Received: 03/10/2016

Respondent: TJX Europe

Agent: Savills

Representation Summary:

Agree that the masterplan should incorporate a significant proportion of employment floorspace to help meet the wider Watford requirement.

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.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 717

Received: 03/10/2016

Respondent: Thames Water Utilities Ltd

Representation Summary:

Wording has been provided regarding wastewater and sewerage infrastructure. Thames Water would like for this to be included in the development brief.

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.

Support

Watford Junction Draft Development Brief 2016

Representation ID: 718

Received: 10/10/2016

Respondent: Historic England

Representation Summary:

Encourage the sensitive regeneration of this part of Watford and welcome a masterplan document offering guidance to future developers.

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: 719

Received: 10/10/2016

Respondent: Historic England

Representation Summary:

Recommend that an additional objective be added to the vision and objectives page to draw on the opportunities of the historic environment to produce a locally distinctive place.

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: 720

Received: 10/10/2016

Respondent: Historic England

Representation Summary:

A development approach to the Nascot Conservation Area in the area identified as Area 21 should be addressed within any revised document and this should use HE guidance as a resource.

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: 721

Received: 28/09/2016

Respondent: Hille Holdings

Agent: Planning Potential

Representation Summary:

Supports in principle the inclusion of the site(s) (Site numbers: 23, 24, 25, 26 and 27) for residential development within the overall masterplan.

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 722

Received: 28/09/2016

Respondent: Hille Holdings

Agent: Planning Potential

Representation Summary:

The site must be deliverable and there must be clear steps in place to enable the delivery of infrastructure.

Full text:

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 723

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

Fails to make reference to requirements in the Minerals Local Plan forming part of the Development Plan in the introduction

Full text:


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

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

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

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

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

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