Watford Junction Draft Development Brief

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Object

Watford Junction Draft Development Brief 2016

Representation ID: 724

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

Clarifies that the likelihood is that the facility will remain on site and will need to be fully safeguarded with regard to the current point under the heading of weaknesses in the Baseline Analysis.

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.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 725

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

The draft Development Brief in the site wide principles section 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

Full text:


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

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

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

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

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

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 726

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

Illustrative Masterplan is flawed as it does not show the safeguarded uses.

Full text:


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

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

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

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

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

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 727

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

It is not considered appropriate to introduce noise sensitive uses in the adjoining area which could prejudice the future operation of the safeguarded area. The safeguarded area should be listed in the land uses.

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.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 728

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

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 rail sidings.

Full text:


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

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

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

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

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

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 729

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

In the development site Station Quarter East bullet point three fails to accord with the clear principles in adopted Policy SPA2 and this does not provide appropriate guidance in terms of development.

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.

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 731

Received: 03/10/2016

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

Agent: PowerHaus Consultancy

Representation Summary:

The brief should be amended throughout to reflect phased delivery of each potential development site. A comprehensive approach remains undeliverable without significant input of public monies to assist in the provision of critical infrastructure.

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 732

Received: 03/10/2016

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

Agent: PowerHaus Consultancy

Representation Summary:

Although willing to contemplate the grant of access on Penn Road, it needs to be that development of their own land is feasible and takes place in a substantial form. It id inappropriate to presume that consent will be forthcoming.

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 733

Received: 03/10/2016

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

Agent: PowerHaus Consultancy

Representation Summary:

Regarding land uses, it is not known at this stage whether every 500 residential units would require a school and therefor fails tests in the Community Infrastructure Levy Regulations 2010. Greater clarity should be provided on the location and criteria of the school and consideration should be given to appropriateness of individual sites for school use.

Full text:

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 734

Received: 03/10/2016

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

Agent: PowerHaus Consultancy

Representation Summary:

It is not considered that the delivery of a new primary school on the HSBCP site is appropriate as it is in the early stages and therefore there will be not be significant demand.

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 735

Received: 03/10/2016

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

Agent: PowerHaus Consultancy

Representation Summary:

The brief should provide guidance on a contribution formula for meeting the identified school places

Full text:

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 736

Received: 03/10/2016

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

Agent: PowerHaus Consultancy

Representation Summary:

The plot ration given for the sites is antiquated and to provide more sustainable urban form a greater density range is preferred.

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 737

Received: 03/10/2016

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

Agent: PowerHaus Consultancy

Representation Summary:

Commercial floor space uses needs to be considered in the context of market demand and the dispersal of commercial floorspace throughout each quarter of the masterplan may not be appropriate and flexibility outside of the commercial floor space needs to be applied.

Full text:

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 738

Received: 03/10/2016

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

Agent: PowerHaus Consultancy

Representation Summary:

Parking provision is range is too high given the location and car free developments and reduced parking ratios should be positively encourage to limit highway impacts.

Full text:

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 739

Received: 02/09/2016

Respondent: Network Rail

Representation Summary:

If the council proceeds to use CPO powers to enable the masterplan then, as is normal procedure, Network Rail may object to the CPO seeking a Deed of Undertaking whereby the objection is withdrawn in return for the council's agreement to necessary railway protections.

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 741

Received: 03/10/2016

Respondent: Ms Susan Jermyn

Representation Summary:

Concern over anti social behavior from high rise developments.

Full text:

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

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

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 742

Received: 03/10/2016

Respondent: Ms Susan Jermyn

Representation Summary:

Impacts on the sewerage system

Full text:

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

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

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 743

Received: 03/10/2016

Respondent: Ms Susan Jermyn

Representation Summary:

Traffic and congestion impacts from the development including the pick up point.

Full text:

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

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

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

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

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

Object

Watford Junction Draft Development Brief 2016

Representation ID: 744

Received: 07/09/2016

Respondent: Mr D Holden

Representation Summary:

Flats are totally unnecessary for the area and smaller development in the form of retail car parks and good office space would be better.

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 745

Received: 07/09/2016

Respondent: Miss Angela Simpson

Representation Summary:

Planning for pedestrians is also required.

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 746

Received: 07/09/2016

Respondent: Mr Nigel Kavanagh Brown

Representation Summary:

Ensure that there is adequate car drop-off/pick up

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 747

Received: 07/09/2016

Respondent: Mr Nigel Kavanagh Brown

Representation Summary:

Not convinced about the need for high-rise buildings

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 748

Received: 08/09/2016

Respondent: Hertfordshire Constabulary

Representation Summary:

Car parking including two decked parking areas needs to be secure and safe

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 749

Received: 08/09/2016

Respondent: Mr Ian Curran

Representation Summary:

Car parking infrastructure is covered comprehensively and will increase car use, congestion and poor air qualiy

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 750

Received: 27/09/2016

Respondent: mr chand patel

Representation Summary:

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

Full text:

generally support the proposal but would like to add,

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 751

Received: 27/09/2016

Respondent: mr chand patel

Representation Summary:

additional height and residential unit numbers should be included, especially near the station.

Full text:

generally support the proposal but would like to add,

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 752

Received: 27/09/2016

Respondent: mr chand patel

Representation Summary:

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

Full text:

generally support the proposal but would like to add,

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 753

Received: 02/10/2016

Respondent: Mr Martin Winstone

Representation Summary:

Direct Abbey Line links to London would encourage more regular use of the line.

Full text:

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 755

Received: 02/10/2016

Respondent: Mr Kevin O'Connor

Representation Summary:

wider thoroughfares to relieve congestion are also required

Full text:

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 756

Received: 02/10/2016

Respondent: Nascot Residents Association

Representation Summary:

encouraged to see that appropriate community facilities (e.g. schools, open space) to support the large amount of housing is recognised and included

Full text:

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

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