Watford Junction Draft Development Brief

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Object

Watford Junction Draft Development Brief 2016

Representation ID: 838

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

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.

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: 839

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

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.

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: 840

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

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.

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: 841

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

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.

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: 842

Received: 28/09/2016

Respondent: London Concrete Ltd

Agent: Firstplan Ltd

Representation Summary:

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

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: 850

Received: 03/10/2016

Respondent: Hertfordshire County Council SLU

Representation Summary:

The retention of the rail aggregates depot is expected unless a comparable facility is provided.

Full text:

Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
With regard to Policy SPMX1: Special Policy Areas, the council is pleased to see the insertion of reference to the county council's documents. The text should however refer to the' Waste Local Plan' which includes both the Waste Core Strategy and Development Management Policies document and the Waste Site Allocations document.
With regard to Special Policy Area 2: Watford Junction, the council is pleased to see that there is reference to the need to safeguard the rail aggregates depot at Orphanage Road.
Further information on SPA2 is contained in Appendix I: Site Schedules of the Local Plan Part 2. The council is pleased that the rail aggregates depot is included as a
Spatial Planning and the Economy
Environment Department
Hertfordshire County Council
County Hall
Hertford
Hertfordshire
SG13 8DN
paul.donovan@hertfordshire.gov.uk
01992 556289
Planning Policy Team,
Room 65,
Watford Borough Council,
Town Hall,
Watford,
Herts,
WD17 3EX.
development consideration where it states 'This will need to be retained, or a new comparable facility provided within the local area'. However it should be noted that the text should refer to the 'rail aggregates depot' as opposed to the 'waste aggregates depot'.
However, in practice, taken together with the masterplan and accompanying viability report, there appears to be a strong likelihood that the rail aggregates depot is not to be retained on site and the collective impact of the Local Plan is not to safeguard the rail aggregates depot. Given this, the Inspector may well wish to see what evidence exists with regard to securing a replacement facility and currently no such evidence accompanies the Local Plan. As a consequence, there is considerable uncertainty in relation to whether the Local Plan satisfies potentially all soundness tests.
With regard to SPA6 Western Gateway, this includes ELAS221 and it is also worth pointing out that the areas designated as PS2 and PS3 potential in the Croxley View/Ascot Road Masterplanning Study are also located in ELAS221.
It is agreed that it is useful to insert text in relation to the circular economy as part of the waste section under paragraph 3.30, supporting text to Policy SD10: Waste. The second bullet point should state 'drive greater resource productivity.'
The relevant policy basis has been applied in the waste section and the Watford Local Plan with regard to responsibility for waste management. Whilst there appears to no longer be specific reference to Waste Policy 12, there is text to cover the use of this policy along with others within the Waste Core Strategy and Development Management Polices document. One comment to make is that in the wider context of the Watford Local Plan with there also being reference to ELAS221, the text in paragraph 3.30 should refer to the Waste Local Plan, which covers policies within the Waste Core Strategy and Development Management Policies document, adopted November 2012 and the Waste Site Allocations document, adopted July 2014.
Watford Junction Development Brief
As previously stated, most recently in respect of the Infrastructure Delivery Plan, the key matter of concern to the Minerals and Waste Planning Authority is the impact that any proposed development may have upon the safeguarded rail aggregate depot located at Orphanage Road, Watford which is a current operational facility.
The planning policy status, as detailed within the introduction of the brief, refers to consideration being had to national planning policy and the Watford Borough Council Local Plan. To ensure that the Development Plan has been considered as a whole the brief needs to also refer to the Minerals Local Plan and the Waste Local Plan. In terms of national policy, there is the need to ensure that the NPPF is considered in respect of para 143 which states that Mineral Planning Authorities should safeguard existing, planned and potential rail heads, so as to prevent their redevelopment for other uses and loss of the mineral infrastructure. This safeguarding is also applicable to storage, handling and processing facilities associated with them.
It is considered that due to the location of the rail aggregate depot within the development brief area that the county council's Minerals Local Plan 2002-2016, adopted March 2007 is also considered with specific regard to minerals policy 10: Railheads and Wharves. The Minerals Local Plan is being reviewed at present. It is envisaged, due to the requirement of the NPPF, that there will be a policy on Rail heads and Wharves in the Draft Minerals Local Plan.
The siting of the rail aggregate depot is shown within the county council's Mineral Consultation Area Supplementary Planning Document, adopted November 2007. The consultation area covers the majority of the Special Policy Area 2 Watford Junction. In accordance with the NPPF and Minerals Local Plan, in respect of minerals policy 10 the county council seeks to safeguard the rail aggregate depot which continues to serve as a sustainable mode of transporting minerals over long distances and the concrete batching facility which this site also supports. Given that the site is viable for use as a rail aggregate depot, its retention is expected unless the facility can be satisfactorily relocated within the development proposals in terms of operational requirements and environmental criteria or it has been or will be replaced in an alternative location.
The development brief identifies the rail aggregate depot as being a 'weakness' for the redevelopment of Watford junction in the SWOT analysis in paragraph 2.1. Minerals are important to the economy. Aggregate is needed to facilitate development and volumes of construction material being transported by rail in increasing. In light of this it could be considered that a rail aggregate depot in close proximity to the construction project could be considered to be a strength.
The issue of addressing such a 'weakness' is not however further expanded upon. It is clear from the illustrative masterplan that the retention of the rail aggregate depot is not part of the scheme. Whilst it is intended to be flexible enough to accommodate alternative layouts so long as it achieves the guiding principles and core ambitions of the masterplan, there does not appear to be sufficient scope to accommodate the existing or a relocated rail aggregate depot within the redevelopment area. As such this leaves the only option of relocating the rail aggregate depot offsite at another location along the railway line.
There is the need to establish an alternative well positioned strategic location for the rail aggregate depot to ensure its continued operation for imports and exports of minerals and secondary and recycled aggregates. The SWOT analysis in the development brief states that there is a 'weakness' in terms of a lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling. The Borough Council is referred back to paragraph 143 of the NPPF, the adopted Minerals Local Plan and specifically minerals policy 10 and the adopted Minerals Consultation Area SPD as detailed above in terms of the clarity for the safeguarding of the rail aggregates depot at Orphanage Road.
The brief states under the land use and quantum section of Station Quarter East within paragraph 3.4 that the development will be required to relocate the Rail Aggregates Depot within the local area, in consultation with Hertfordshire County Council and the operator of the site. The County Council will continue to work with the Borough Council in respect of this matter. The land use and quantum section in
paragraph 3.4 should also refer to the need to work with Network Rail with regard to the relocation of the Rail Aggregates Depot. The County Council understands that Network Rail Freight Management has been consulted and will provide comments to this consultation. There is however no further detail with regard a precise location having been secured.
To this end the relocation of the rail aggregate depot is fundamental to the delivery of the masterplan. A statement should be made in the delivery section of the brief at paragraph 4.1 specifically in relation to the requirement to ensure that the relocation of the rail aggregates depot forms part of the Watford Junction Delivery Plan.
Croxley View/Ascot Road Masterplanning Study
The Croxley View/Ascot Road Masterplanning Study has been considered by the county council as Waste Planning Authority due to the proximity of redevelopment to the Employment Land Area of Search (ELAS) 221 Watford Business Park.
The masterplan aims to build on the policy foundations of the district Local Plan Core Strategy Policy SPA6 to facilitate redevelopment. The location of potential residential development is shown within the Masterplanning Study to be directly adjacent to ELAS221 as designated within the county council's Waste Site Allocations document 2011-2026, adopted July 2014.
It is considered that ELAS that are predominantly used for general industry (B2) and storage and distribution (B8) are compatible with waste management uses. ELAS221 contains B1 and B2 uses and as such is acceptable in principle for a range of potential waste uses listed in the general waste brief during the 15 year plan period 2011-2026. Further planning guidance into the suitability of waste related development on the identified ELAS is within the ELAS Supplementary Planning Document, adopted November 2015. For this area, the Supplementary Planning Document states 'only enclosed waste transfer stations and materials recovery facilities that handle dry recyclables would be acceptable, along with enclosed inert waste recycling facilities. No other potential uses that may generate a leachate or liquor, which poses a risk to groundwater resources would be appropriate'.
The council does not wish to see the loss of identified ELAS for non-waste uses in order to safeguard it for future potential waste uses that may be sited in this location. Whilst the residential development would not directly encroach onto the ELAS, the council is mindful that the residential development is identified along the eastern boundary of the designated site and as a result there could be the potential for indirect impact upon the siting of waste uses within the ELAS.
The Waste Local Plan does not rely on the need for all land within ELAS across the county for the delivery of waste uses. However the cumulative loss of ELAS to non-waste uses is monitored and the safeguarding of remaining ELAS land is important to ensure there is a sufficient amount of land that could come forward for waste management facilities in the future, particularly with additional growth resulting in an increase in waste produced which needs to be managed.
There are currently no extant planning permissions on land directly adjacent to the masterplanned residential development to be aware of. The nearest waste site is the Household Waste Recycling Centre at Caxton Way in ELAS221. There is sufficient land remaining in ELAS221 to be brought forward for waste management uses.
The County Council does not wish to object to the masterplanning for potential residential development at this stage but reserves its right to object to future planning applications adjacent to the ELAS should a waste site be development in advance of residential. The reason for this would be to safeguard any waste use(s) under waste policy 5: Safeguarding of Sites within the Waste Core Strategy and Development Management Policies document 2011-2026, adopted November 2012. Further discussions would need to take place in the event that negative effects are identified that would restrict the waste operation to continue. A buffer between two land uses or mitigation measures in some cases may be appropriate to allow opposing land uses to exist in harmony adjacent to each other.
The County Council's adopted Waste Core Strategy and Development Management Policies document, does not stipulate a distance whereby other development in close proximity to a safeguarded waste site should be discouraged, the 2004 ODPM document: Planning for Waste Management Facilities: A Research Study states that for waste transfer stations: "sites closer than 250m from residential, commercial or recreational areas should be avoided." This guidance was used in the production of the Waste Site Allocations document. Depending upon the location of any potential future waste management facility within the ELAS, there is the potential that facilities may well be sited closer than the suggested 250m to any future housing.
Transport
Overarching/ general comments
Watford and the surrounding transport network face growing challenges as a result of the desired housing and economic growth in the area and increasing demand for travel. The County Council is developing a countywide transport model that will help all local authorities in the county to plan positively for growth and infrastructure investment in a way that safeguards the health and wellbeing of our communities and the environment. Already the model has identified notably worsening congestion issues in the Watford area as a result of planned growth. The next outputs of the enhanced Watford area version of the model will be available by the end of October 2016. The existing model is already available to Watford Borough Council to test development scenarios and proposals from the Local Plan.
In parallel with this, the County Council is developing a Growth & Transport Plan for South West Hertfordshire, which includes Watford and the surrounding towns and transport networks that make up a coherent area of travel demand. The Growth & Transport Plan will put forward packages of transport interventions to respond to strategic transport challenges and objectives for the area, derived through robust evidence analysis and engagement with stakeholders. Watford Borough Council officers and members have been involved from the early stages in GTP workshops
at key stages. The GTP is about identifying needs, planning for and enabling investment and delivery of a transport network and public realm that will support a healthy economy, environment and communities.
As a result of the current ongoing work being incomplete, at this stage there is insufficient evidence available to assess the implications of Local Plan Part 2 on the transportation network. As a consequence, there is uncertainty in relation to the mitigations that will be required to support the proposals and we remain in doubt that it potentially satisfies all soundness tests.
Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
Contents
'Appendix I - Site Allocations' is referred to later as 'Site Schedule'
'Appendix L' and 'Appendix M' missing from content list
Policy SD10
Refuse collection vehicles must be able to stop within the 'maximum refuse carry distance' specified by the Local Planning Authority or within 25m of any bin storage area, whichever is the lesser distance. Residents should not have to carry their rubbish more than 30m to a storage point. (Sources BS5906:2005 and Schedule 1 Part H Building Regulations)
Policy TLC14
On-street parking continues to need to be managed to manage congestion and avoid hazards, particularly at junctions.
Policy HS7
The subjective "undue pressure" on on-street parking should not lead to increased congestion and / or hazards on the highway network, particularly at junctions.
The siting of bin stores should not adversely impact on the operation of the highway network.
Policy HS8
The Highway Authority recommends that consideration of deliveries is made explicit in this policy.
6.9 and Policy EMP5
The County Council supports urban realm enhancement of Clarendon Road to encourage walking and cycling and improve the key pedestrian route between the town centre and Watford Junction.
Consideration should be given to amending the policy wording to explicitly include an expectation for development along Clarendon Road to contribute towards urban realm enhancements directly through works delivered or through developer contributions to fund such works.
Policy T6
The County Council is supportive of the zonal approach to car parking guidance to encourage lower car ownership and usage in more accessible zones. The principle of 'Car Lite' development in the most accessible areas, within 5 or so minutes' walk of a major transport hub, is also supported as long as the needs of disabled drivers and visitors are considered.
Lower car parking provision must be accompanied by appropriate restrictions in surrounding residential streets and any public car parks to prevent spill-over parking. In order for this approach to lowering car usage to be successful, there needs to be parallel investment in infrastructure (eg significantly better cycle and bus routes) and urban realm improvements to support and actively encourage alternative modes of travel.
The County Council welcomes the requirements for car club spaces in the SPAs and where parking does not meet the guidance.
Policy T8 and Appendix H
The policy on cycle parking provision and the stipulations relating to quality contained in the policy is welcomed. Adequate cycle storage must also be provided for existing and high predicted future levels.
A small change is recommended to allow for cycle parking provision for dwelling houses to be in a private garage as well as within the private garden area - subject to the dimensions of the garage being adequate to accommodate cycles as well as any vehicle.
However, the policy only specifies one long-term space per unit (regardless of size or location) where there is no garage or shed. In some instances such as within SPA2 and SPA6 where housing will be in the form of apartments and where there will be reduced car parking, it may be necessary for additional capacity for cycle storage beyond one space per unit, especially for larger flats or any flats without car parking provided.
Policy UD3
Structures abutting and overhanging the public highway will need the approval of the Highway Authority (HCC) as will illumination visible from the highway.
Policy TB1
From a transport network and user perspective, locations near to major passenger transport hubs, offering good interchange between different services and modes, are the most appropriate for denser development (i.e. taller buildings). However, development proposals should all be subject to Core Strategy policies T2-T5 to ensure that their impacts are understood and mitigated.
In order for such development to be acceptable, there must be adequate and appropriate improvements to transport infrastructure and urban realm within the site and in the wider area, to ensure no significant adverse impact on the highway and passenger transport networks, as a direct, indirect or cumulative result of development at the site and in the Borough as a whole.
Policy TB2
Suggest change to text at 8. Transport, parking and infrastructure:
'The design should detail a transport strategy for the proposed development to include how cycle parking, car parking, cycle permeability and pedestrian permeability have been integrated into the overall design. This should be based on a Transport Assessment and should avoid negative impacts on the public realm. The scheme will also need to demonstrate that the required infrastructure and utility capacity has been fully appraised.'
Appendix G
Parking bay dimensions only seem to consider residential element, parking bay at 2.4 x 4.8m is fine for standard bay but dimensions of other bays should be provided e.g. parallel arrangement. The garage dimensions provided are 3m x 5.5m whereas the industry standards are 3m x 6m (MfS para 8.3.41). Should minimum circulatory space for car parks be covered here (i.e. 6m) or will it be covered elsewhere?
SPA1
The ring road constrains pedestrian and cycle accessibility to the heart of the town centre. nb includes EMP5, R1, R2, R3, R4, R5. See Highway Authority comments in regard to each of these.
SPA2
Any development within the Watford Junction SPA should ensure that connectivity for pedestrians and cyclists is improved across the site, between the site and the town centre and on other key routes to Watford Junction Station.
Development of the station building, forecourt and car parks must address current limitations including capacity, access and circulation issues, for pedestrians, cyclists, buses, bus users, taxis, as well as users of the car parks. Opportunities to make Watford Junction an attractive and functional transport interchange that can accommodate future growth should be maximised.
See Highway Authority comments on Draft Development Brief (below).
SPA3
Good quality cycle and pedestrian links through the site and between the site and surrounding area and key destinations (town centre, Vicarage Road MLX station, local schools etc.) must be provided, or contributions to support infrastructure improvements in the wider area made through developer contributions.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
SPA4
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
Support improvements to green infrastructure and public realm as a complement to improvements to pedestrian and cycle links.
Flooding is a known issue affecting this area. Any development in this area should be designed to avoid and mitigate flood risk. Sustainable drainage approaches and green infrastructure should be used where appropriate to reduce and manage flood risk.
SPA5
Development at this location will need to consider transport impacts on the highway network, including operation of the Dome roundabout and St Albans Road notably at peak times. Also junctions including M25/A405/M1, and M1/A41.
There is a need to improve cycle, pedestrian and passenger transport connectivity to the site, and between the site and the town centre and Watford Junction.
It is recognised that the Abbey Line (North Watford) station is closer to the site, but there are limitations to this service at present which will reduce its attractiveness as an alternative to the car for journeys to Watford Junction or St Albans Abbey stations.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
There is a typo on second bullet point - should read 'improve air quality'.
SPA6
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Cycle improvements on Rickmansworth Road may be required as this is a key corridor between Rickmansworth and Watford.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
Secure, high quality cycle parking is needed at the proposed Cassiobridge station, as well as within the employment premises.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
See Highway Authority comments on Masterplanning Study (below)
MXD3
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
R1
It is agreed that robust pedestrian links with the town centre should form part of the new development at this location.
Good cycle access and high quality cycle parking also needs to be provided, for customers as well as employees.
R2
Agree that clear pedestrian connections between the site and the High Street are needed.
Good cycle access and cycle parking must also be provided.
There is a need to consider access needs to the site by different modes. A planned highway improvement scheme will make Clarendon Road one-way (NE-SW only) from Beechen Grove to High Street, with a contraflow cycle lane. Access to the street will be restricted by a Traffic Regulation Order to buses, taxis, cycles, 'blue badge' vehicles, and other vehicles 'for access only' to premises. All accessing vehicles will need to leave either via High Street or Watford House Lane (private road) for those accessing that area.
Development of this site should complement public realm enhancements proposed or already delivered on Clarendon Road and the High Street.
R3
Good cycle access and storage facilities must be provided, as well as good pedestrian links.
Developments at this location must take into account severance issues caused by the ring road for pedestrians and cyclists. Improvements required such as crossing improvements, new accesses into/through the site, should be delivered as part of the development or through developer contributions.
R4
Strong pedestrian and cycle links between this site and the town centre must be provided.
The quality of cycle routes and access to/from the west needs to be improved - eg. Market Street west of ring road and the Hornets Gyratory.
H1
This site is in close proximity to Bushey Station and includes its car park.
Opportunities to upgrade access to the station by non-car modes should be pursued.
Need to consider quantity and quality of cycle parking and cycle access to station from surrounding area.
Cycle access and cycle parking provision at Bushey station should be improved as part of any car parking replacement/improvement scheme.
Bushey Arches is a known congestion hotspot. Impacts of development on Bushey Arches must be considered and mitigation provided. This should include contributions to needed improvements to key walking and cycling routes and passenger transport infrastructure in the area.
H2
The ring road causes significant severance to people travelling by foot and cycle. Particular issues have been reported for people with visual impairments.
Improved cycle and pedestrian links to town centre and to Watford High Street and Watford Junction stations are needed from the site.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
H3
This site is about half mile from both the proposed Vicarage Road Met Line station and Watford High Street station, which is 10 to 12 minutes walking time.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
Vicarage Road is a busy road without dedicated cycle facilities. As such improvements to this route for cyclists should be considered. Developer contributions to improving cycle routes may be appropriate.
H5
The traffic impact on west Watford's road network needs to be considered and mitigated.
Cycle and pedestrian links into the site from different directions are required.
Adequate cycle storage must also be provided for existing and high predicted future levels.
Cycle infrastructure and the pedestrian environment of the surrounding area needs consideration.
H9
The impact of development at this site on the road network must be considered and mitigated if needed, including Rickmansworth Road and West Watford.
Good cycle links are needed including between the site, the town centre, and Ascot Road.
Bus services and infrastructure, including linking to new Cassiobridge Met Line station.
Bus services in this area may well be subject to change following the loss of the underground station. Development of this site and any forthcoming S106 contributions would provide the opportunity for an assessment to be made of potential improvements to bus services so this site remains connected to key destinations.
E1
High quality, secure cycle provision is needed at business premises.
Although the Ebury Way provides a good cycle route to the site, this will not be suitable for use all year round, at any time of day. As such improvements to the A412 corridor cycle infrastructure should be explored and provided. Developer contributions may be appropriate.
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
E2
Cycle and pedestrian routes through the site need improvement;
Via Watford Junction SPA site, there is a need to reduce severance and improve pedestrian and cycle connectivity to Watford Junction station and Clarendon Road.
WBC also needs to consider the implications of the Colonial Way Link road on development at site E2.
There is a need to consider potential transport implications of this site and the Watford Junction masterplan as a whole, including traffic accessing any new station multi-storey car parks, and the impact on the road network (eg. Colonial Way, Stephenson's Way, Radlett Road, Link Road, A41/M1 junction...).
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions.
E4
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions and on footways.
E5
Needs to link with SPA2 Watford Junction.
Development will need to assess impacts on road network and car parking demand in surrounding area.
Quality of pedestrian and cycle environment and urban realm on Clarendon Road should be considered and opportunities to enhance in consistent, coherent way should be explored to promote sustainable travel and improve route between town and Watford Junction.
Buildings will need to provide adequate, high quality secure cycle parking. If low car parking, may need to increase requirements or leave space to expand provision as required.
G6
Any change in land use/ status/ access provision to the south of Caxton Way and the south and east of Greenhill Crescent should not be permitted until its ability to provide the link for sustainable modes between Tolpits Lane and Caxton Way required by paragraph 10.6.9 of the WBC Core Strategy has been fully explored and ruled out.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF
1.1
The traffic and transport impacts of the masterplan scheme have not been modelled and thereby understood. The Highway Authority is, therefore, unable to fully support the plan until those impacts are assessed and deliverable mitigation measures agreed. HCC is developing traffic and transport models of Watford as part of its work to create a Growth & Transport Plan for the area. These will be used to test the impacts of the Watford Junction and other development proposals on transport infrastructure and services individually and cumulatively.
As part of earlier work on this site the County Council had required the construction of a road and bridge linking Colonial Way and St Albans Road via Penn Road. The scheme to build it received outline DfT funding and included a passenger transport (coach) interchange on the northeast side of the station. If the link road and bridge are no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
1.2
Correct reference to 'Abbey Link' in map to 'Abbey Line'.
2.1
The Barriers plan acknowledges the severance created by the presence of the Abbey Line. As part of earlier work on this site the County Council had required the construction of a road over the Abbey Line linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.2
Policy T1 in the borough council's Core Strategy supports conversion of the Abbey Line from heavy to light rail operation.
Correct reference to 'Abbey Flyover' in Objectives to 'Abbey Line'.
2.3
Correct reference to 'Abbey train line' under Transport and Parking to 'Abbey Line'.
As part of earlier work on this site the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.4
Gross External Areas values are different to those in 5.1 Area Schedules.
3D views might benefit from road names for orientation.
2.7
As part of earlier work on this site, the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
It is recommended that all roads are usable by cycles to aid permeability.
The road hierarchy titles have different meanings in the Highway Authority's own existing hierarchy. As the design is refined it is recommended that confusion is avoided by using different names.
2.8
The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.
3.3
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
3.4
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
4.1
The County Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order that they can be considered in the emerging Watford Growth & Transport Plan. Joint working with the County Council will remain key in order to maximise access to appropriate funding streams and delivery programmes.
Special Policy Area 2 is zero-CIL-rated so that all planning obligations will be derived via Section 106 agreements with service providers.
4.2
An overall Travel Plan for the site will be required and one for each subsequent development area should be provided and agreed.
5.1
Total car parking number differs from that given in 2.4 and Station Quarter East breakdown (p 46).
Gross External Areas values are different to those in 2.4.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF VIABILITY APPRAISAL
4.2
The County Council is concerned about the unrealistically low estimates given in figure 4.1 for the costings of infrastructure required to mitigate the impact of the masterplan.
CROXLEY VIEW/ ASCOT ROAD STUDY
Introduction
Mention must be made of the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The need for a link both for Watford and Three Rivers grows as pressure to develop either side of the Ebury Way increases and its delivery should be seen as key to both authorities' Duty to Cooperate.
Plans
All plans refer to Watford County Council.
All plans show Croxley Green Business Park to the southwest of the masterplan area. This is correctly the Wolsey Business Park.
Most plans show the Grand Union Canal badged as the River Gade which runs to the south and east of it.
Some plans do not show the correct alignment of the Watford/ Three Rivers boundary.
Some plans erroneously label the NE corner of Croxley Common as Cassiobury Park Nature Reserve.
Masterplanning Strategy plan - asterisks and other labelling are not described and inconsistently applied.
Potential Development Sites plan
This omits to include the Tech Site (around Woodshots Meadow). This is subject to preapplication discussions now and should be considered with the adjacent sites as it is in Employment Policy Area E1 (Local Plan Part 2 appendix 1).
Proposed Vehicle and Pedestrian Movement plan
This omits the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The route currently being explored follows the cycle track between the Watford Enterprise Centre and number 27 Greenhill Crescent.
Historic environment, landscape and ecology
The County Council supports the overall policy intentions of the Local Plan covering landscape, ecology and the historic and built environment and provides the following comments to help strengthen these policies and their supplementary text.
Historic Environment
Development Management Policies
The County Council welcomes the Borough's consideration of the Historic Environment in Part 9 Urban Design and the Historic Environment. However, the historic environment should be referenced in line with the NPPF definition of heritage assets. In addition to historic buildings (both designated and undesignated), the historic environment of Watford includes archaeological remains, historic landscapes and historic parks. Therefore policies are needed to conserve the historic environment as whole, not just designated buildings, registered gardens and conservation areas as is currently stated.
Under Policy UD4, Archaeology, there appears to be repetition of the NPPF, the policy is unclear and should be re-written.
There is also reference to the conservation of heritage assets being secured by an archaeological Written Scheme of Investigation (WSI). Whilst the County Council welcomes the requirement for these documents and for them to include provision for publication and public dissemination of results where appropriate (NPPF 141), it is not clear if the WSI on its own is considered to be robust enough to secure appropriate conservation of the historic environment. Therefore it is unclear if this part too, is effective.
Watford Junction Draft Development Brief 2016
Paragraph 4.2 notes that a Heritage Statement and Desktop Archaeological Study may need to be submitted with any planning applications. However, it is unclear what is meant by a Heritage Statement. Also archaeological assessment may not be limited to a desktop study.
Site Allocations
An appraisal of the archaeological implications of development for the new areas identified in the Second Consultation document (2016) is summarised below.
1. Archaeology as a Development Constraint
N/A
2. Requirement for Pre-allocation Archaeological Assessment
The sites below have known archaeological remains within them or have significant archaeological potential by reason of their size and situation, such that there is a risk that archaeology could be a constraint on any development. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that archaeological assessments should be included within all development briefs and other proposals for the sites, before they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the sites, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent of archaeological remains that might be a constraint upon the principle of development of these sites.
Allocation numbers: SPA1, SPA4 and H9.
3. Requirement for Pre-application or Pre-determination Archaeological Assessment
The sites below have known archaeological remains within them or have archaeological potential. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that that pre-application or pre-determination archaeological assessments should be included within all development briefs and other proposals for the sites, if they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the proposals, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent
of archaeological remains worthy of preservation in situ, to enable the LPA to determine any specific application for development.
Allocation numbers: SPA 2, SPA3, SPA5, SPA6, MXD1, MXD3, R1, R2, R3, R4, H2, H3, H4, H 10, E1, E2, E3, E4, E5, E6.
4. Mitigation of archaeological impact by condition
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, any archaeological issues can probably be dealt with by condition, should planning permission be granted.
Allocation numbers: R5, CF1, H1, H5, H6, GT1.
5. No archaeological requirements
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, there are unlikely to be any archaeological implications. However this will depend on the details of any proposals and any new archaeological information.
Allocation numbers: MXD2, MXD4, H7, H8, H11.
Ecology
Development Management Policies
Policy SD15, External lighting, the County Council support the provisions set out in this policy and advise that there should be reference to the guidance provided by the Institute of Lighting Engineers which has been instrumental in seeking to reduce the impacts of artificial lighting within the environment.
Green Infrastructure, Biodiversity and Recreation, the County Council supports the reference to Green Infrastructure (GI).In defining GI there should also be reference to the provision of local food production as a key ecosystem service.
Policy G15, Trees, Woodlands and Hedgerows, this policy is supported in respect of highlighting ecological and cultural value of trees, woodlands and hedgerows. However, under paragraph 10.3, the reference to valuable habitats should be extended to include reference to ecological networks and corridors. Under paragraph 10.6 it should be clarified that replacing trees lost to development cannot compensate for the loss of biodiversity or amenity value in the short term.
Policy GI6, Protecting and Enhancing the Grand Union Canal, this policy is supported including the reference to enhancing biodiversity under paragraph 10.11. It is advised that the policy is extended to include a clause that seeks to improve the biodiversity of the canal corridor where possible. Development that would have an
adverse impact on the biodiversity of the canal would not be supported unless it can demonstrate provision of suitable mitigation or compensation.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, this policy is supported however recommend the following clarifications and amendments.
It is advised to make reference to the 'amenity value' of the river, specifically encouraging 'recreation' may increase disturbance to sensitive wildlife within river corridors. The term 'amenity' embraces visual and recreational importance without being too prescriptive or disruptive if more sensitive habitats or locations are affected an important consideration within this largely urban area.
With regards the provision of 'a corridor for wildlife and biodiversity,' the reference to biodiversity should be deleted as wildlife is biodiversity. With regards replacement structures and fish passage, liaison with the Environment Agency is essential if any such works are proposed. With regards access it should be designed in a way that also enables some undisturbed areas to be retained.
Policy GI9, Provision of Open Space and Play Space in Residential Development, aspects of this policy relevant to biodiversity are supported. The reference to green space typologies should be expanded to include allotments and community orchards, in order to reflect the types of functional sites which support both community and biodiversity benefits.
Biodiversity, it is not clear why this section is formatted differently to the preceding and subsequent sections. In particular it does not describe 'Why is this policy needed?' and 'what is it intended to do?' In setting out the need for the policy, it should reference the legislative requirements of statutorily protected sites and species which are a material consideration in planning, as well as the Duty placed on Local Authorities to have regard to conserving biodiversity in all of their functions as set out in the Natural Environment and rural Communities Act 2006. In setting out the intention of the policy there should also be reference to seeking to deliver the aims of the Local Nature Partnership - for which securing ecological resources, functions and services are a consideration when determining planning applications.
Under paragraph 10.37 the reference to the 'Biodiversity Plan' should be amended to reference to the 'Biodiversity Action Plan principles' (BAP). The BAP, nationally and locally, has ceased to be actively supported by National and Local Government, and has essentially been replaced by the Local Nature Partnership. However the principles underpinning it remain valid as statements and the intentions of the various habitat and species action plans are sound in themselves and could be followed if resources or interest permitted.
It is suggested that the statement under paragraph 10.39 should be amended as follows:
'This policy expects that where appropriate, development proposals will demonstrate the relative ecological value of a site before and after development. Proposals should follow the mitigation hierarchy and provide clear evidence of impacts and enhancements where appropriate, consistent with the aims of NPPF, BS42020
"Biodiversity - Code of Practice for Planning and Development'' and guidance provided by CIEEM. This will require sufficient detail and clarity to enable net losses and gains to be identified and monitored, consistent with the Code. Where unavoidable, Biodiversity Offsetting should be considered as a means to ensure there is no net loss of biodiversity resulting from development'.
Highlighting the specific use of Biodiversity Calculators such as the one mentioned in paragraph 10.39 can be a little misleading. BS42020 does not mention the use of biodiversity calculators, and taken out of context the results of such calculations can sometimes show net gains where there should be none (removal of ancient woodland for example cannot reasonably be compensated in the real world). Other wider landscape issues are also not always considered by these calculators; if the land is part of a wider corridor, or a biodiversity network for example. It has taken several years for Warwickshire County Council to incorporate their use in to the planning system and there is still not universal agreement on them.
The County Council would therefore advise caution on their avocation, but rather emphasise the need to prove that biodiversity has not been lost and in the most part enhanced through "appropriate methods in-line with BS42020".
Policy GI10 Managing Biodiversity in new Developments. The County Council supports Watford Borough Council's commitment to increasing biodiversity within the district. The Policy is consistent with other Hertfordshire Local Authorities, and in-line with the National Planning Policy Framework.
The following amendments are advised. There should be reference to avoiding negative impacts upon ' local ecological networks...,'as each site sits within a local environmental and should retain or enhance any existing ecological resources or corridors to and from adjacent sites.
'Compensation will only be considered as a last resort. Development proposals will be expected to evaluate the impact on local biodiversity where appropriate and propose measures to maintain and enhance biodiversity. This approach should follow the principles outlined within BS42020 "Biodiversity - Code of Practice for Planning and Development" or other measures of best practice, including Biodiversity Offsetting where necessary'.
The above wording embraces the mitigation hierarchy as well as defining means to achieve no net loss as sought by NPPF, without being too prescriptive.
It is considered that paragraph 10.40 regarding the biodiversity calculator is not needed if references requiring its specific use are otherwise removed. The County Council remain concerned that some caution needs to be taken regarding the generation of positive scores which indicate a net gain despite losses that may otherwise be considered unacceptable.
Site Allocations
Please refer to Appendix 1.
Landscape
Green Infrastructure, Biodiversity and Recreation, the policy framework for green infrastructure (GI) was significantly strengthened in Feb 2016 with the introduction of detailed Planning Policy Guidance. The guidance states that GI is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water and should be a key consideration in both local plans and planning decisions.
The Herts Landscape and Green Infrastructure Group is currently looking at GI delivery and practice across Hertfordshire with a view to presenting a project proposal to Herts Infrastructure Planning Partnership (HIPP) in November. The key aim of the project is to mainstream the delivery of GI through the local plan and development management processes. The outputs and deliverables of the project are currently being shaped and should help provide local planning authorities with a good practice approach to GI delivery, supported by robust evidence and case studies.
The Landscape Institute Position Statement for Green Infrastructure provides a widely supported definition of GI (assets and functions) and a comprehensive overview of the key benefits it can deliver, supported by case studies http://www.landscapeinstitute.org/policy/GreenInfrastructure.php
There is no reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans. (The strategies provide an opportunity to address cross boundary issues and meet the Duty to Cooperate. (Hertfordshire and GreenArc Area Strategic Highlights Plan (SHiP) and the All London Green Grid.)
There should be greater emphasis on GI in place-making and conserving and enhancing local distinctiveness. There should be reference to any local character assessments and the guidelines for managing change that should help shape proposals, and conserve and enhance local character.
At a national level there is also the National Character Areas produced by Natural England https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making, and at a regional level there is the East of England Landscape Framework http://landscape-east.org.uk/.
Where proposals are likely to result in landscape and visual effects a landscape and visual impact assessment, in line with industry good practice guidance (Landscape and Visual Impact Assessment third edition Landscape Institute and Institute for Environmental Management and Assessment) may be required as part of an application. The mitigation hierarchy should be referenced to ensure that proposals seek to avoid and minimise any negative effects.
The reference to Green Infrastructure under paragraph 10.1, is fully supported, however it is suggested to expand the definition to include reference to blue assets
such as the Grand Union Canal. Also suggest amend reference to 'mitigating climate change' to 'mitigating the effects of climate change.'
Under paragraph 10.3, it should be clear that biodiversity is not the only driver for Green Infrastructure; other key drivers include a single or multiple land-use functions and include waste/water management, recreation, food production, local distinctiveness etc.
Policy GI5, Trees, Woodlands and Hedgerows, the reference to the protection of trees in line with current British Standard Institute code of practice is fully supported, however the full title of the standard does not appear to be referenced and should be 'Trees in relation to design, demolition and construction' (BS5837:2012). In addition it is advised that where required by the planning authority, tree surveys, arboricultural impact assessments and method statements should all be carried out in compliance with this standard.
The policy should be expanded to include reference to the current hedgerow regulations, the provision of a landscape strategy, planting plans and specifications, and the provision of aftercare (long term management plans) and replacement of failures.
Policy GI6, Protecting and Enhancing the Grand Union Canal, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Yours sincerely,
Paul Donovan
Environment Department
Hertfordshire County Council
APPENDIX 1
Please find below a brief ecological assessment of the site allocations. A 'standard' template for each Site has been provided.
Ecosites do not have any form of status of importance, but are merely sites that we have some ecological information on - thus they do support some wildlife interest, at least at a local level. Whilst these sites are often a valuable starting point in identifying the county's wildlife resource, they do not meet the rigorous and quantifiable assessment criteria needed to identify them as non-statutory Local (County) Wildlife Sites.
SPA1 Town Centre
Recognised sites adjacent / close to Site: close to eastern end of Cassiobury Park Local Wildlife Site.
Other features: Little semi natural habitat present, possibly some mature trees.
Protected species: Probably bats, badger records to the west.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road)
Protected species: Unknown - no records
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA3 Health Campus (includes a Borough Council Depot and Waste Transfer Station at Wiggenhall Road)
Recognised nature sites within Site: The Lairage Land Local Wildlife Site (LWS) and Local Nature Reserve (LNR), Croxley Green Junction Sidings LWS, Oxhey Park River & Margins LWS; Riverside Road Waste Ground ecosite (local database site), The Island, off Cardiff Road ecosite, Oxhey Park ecosite
Recognised sites adjacent / close to Site: Horwoods Avenue Playground ecosite, Moor View ecosite, Cardiff Road Embankment ecosite.
Other features: includes village green - "Green situated between Riverside Road & the River Colne"
Protected species: Birds and Water voles.
Opportunities: High. Habitat management to maintain and enhance biodiversity interest, green infrastructure / corridors.
Ecological sensitivity: Medium to high depending on location.
Fundamental ecological constraint: Presumption to avoid development on Local Wildlife Sites, fragmentation of green corridor,
Loss of Farm Terrace allotment site - should be offset elsewhere as open space / community food growing / ecological resource.
SPA4 Lower High Street
Recognised sites adjacent / close to Site: Bushey Hall Farm ecosite, Oxhey Park ecosite.
Other features: "Recreation Allotments" village green.
Protected species: Unknown - no records. Birds in trees.
Opportunities: Limited as previously developed site. Potential green corridors along railways lines.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA5 Dome Roundabout (includes a Waste Transfer Station at Colne Way)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA6 Western Gateway (includes area of search ELAS221 in the Hertfordshire Waste Site Allocations Document)
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite, Ascot Road ecosite.
Recognised sites adjacent / close to Site: close to eastern end of Croxley Common Moor Site of Specific Scienttific Interest (SSSI) and LNR.
Other features: Grassland strip along eastern boundary with bordering trees.
Protected species: Unknown - no records.
Opportunities: Enhance green infrastructure corridor along eastern boundary.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds in trees.
The ecosites have largely been destroyed by development.
MXD1 North Watford library, Lemarie Centre for Charities, and health facilities (within SPA5)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
MXD2 The Brow
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
MXD3 Gas holder site (within SPA4)
Other features: River Colne borders the eastern boundary.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site. Potential to enhance the river margins as a green corridor.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in the trees.
Largely developed but riverside trees most important and scrub on site.
MXD4 Ascot Road
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite.
Other features: As well as the rough ground and bordering trees of the area to the west, the Site includes part of the school playing fields to the east, which is short mown amenity grassland. There are also some mature trees.
Protected species: Unknown - no records.
Opportunities: Potential enhancement of the areas of semi-natural habitat to improve green corridor connectivity.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds. Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R1 Sainsbury's and adjoining land
Other features: The north-eastern part of the Site includes an area of grassland and mature trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R2 Former TJ Hughes and adjoining land
Other features: Small area of amenity grassland on the north-eastern side.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R3 BT Telephone Exchange and adjoining Wellstones
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R4 Church Street Car Park and land fronting Market Street/Market Place
Other features: area of amenity grassland and scattered trees on the southern side.
Protected species: Unknown - no records.
Opportunities: Limited as predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R5 Charter Place centre and adjoining land onto the High Street
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
CF1 Community Facility Tolpits Lane.
Other features: Site appears to be rough grassland with scattered scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to enhance the habitats on site. The northern boundary is a wooded bank bordering the railway line. Maintain / enhance green corridor along railway.
Ecological sensitivity: Low - medium as semi-natural habitats on site.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H1 Land at Pinner Road
Other features: There are small areas of rough (possibly amenity) grassland with scrub and scattered trees.
Protected species: Unknown - no records.
Opportunities: Limited as a predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H2 Skatepark, Lower Derby Road
Other features: There is an area of grassland with trees in the north-west corner.
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a predominantly a previously developed site. Potential to maintain / enhance the semi-natural habitats on site for green corridor links to nearby habitats, river corridor and wooded railway banks.
Ecological sensitivity:
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H3 Vicarage Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H4 Telephone Exchange - First Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H5 Builder's Yard, Queens Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H6 Bill Everett Community Centre
Recognised sites adjacent / close to Site: adjacent to Long Spring and Harebreaks Wood (Watford) Local Wildlife Site and Local Nature Reserve.
Other features: some areas of grassland (probably amenity?) and occasional scattered trees.
Protected species: Bat roost in building nearby.
Opportunities: Potential to link woodland to the south to area to the north - depending on what the latter is like, as it appears to be bare ground on our aerial photographs.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H7 Rickmansworth Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H8 Garages- The Gossamers
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H9 Watford Station, Cassiobury Park Avenue
Recognised nature sites within Site: Cassiobury Park Avenue allotments ecosite.
Recognised sites adjacent / close to Site: close to "Gade Avenue" Local Wildlife Site.
Other features: Includes an area of allotment gardens and mature trees.
Protected species: Unknown - no records. Potential for bats and reptiles.
Opportunities: Maintain and enhance the green corridor link along the railway line.
Ecological sensitivity: Low - medium?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H10 Croxley View
Other features: Area of semi-natural grassland with scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to manage the existing habitats to maintain / improve biodiversity. Maintain as a green infrastructure link from open grasslands to the south towards the River Gade corridor and semi-natural habitats to the north
Ecological sensitivity: Low.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H11 Garages, Bowmans Green
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
GT1 Lands at Tolpits Lane
Other features: Area of rough grassland with bordering trees.
Protected species: Unknown - no records.
Opportunities: Limited, but part of semi-natural grassland complex in the area so potential for linking hedgerows. Any loss of grassland could be compensated for by enhancement elsewhere and landscaping may provide additional buffering habitats locally if this site were to be developed as such.
Ecological sensitivity: Low?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
E1 Watford Business
Recognised sites adjacent / close to Site: adjacent to Croxley Common Moor Site of Special Scientific Interest (SSSI and Local Nature Reserve (LNR) and Commonland; adjacent to Ascot Road Car Park and Waste ecosite, adjacent to Ascot Road ecosite; close to Ascot Road Scrub Local Wildlife Site.
Other features: Some areas with trees.
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
Part of the edge of this currently provides a valuable buffer and boundary edge to Croxley Common Moor SSSI and LNR. We would object to any development which further degraded this boundary habitat, although much of the former area has already been lost to hard surfacing.
E2 Imperial Way / Colonial
Protected species: Limited as a previously developed site.
Opportunities: Low.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E3 Fishers
Recognised nature sites within Site: Cardiff Road Embankment ecosite.
Recognised sites adjacent / close to Site: adjacent to Croxley Green Junction Sidings Local Wildlife Site.
Other features: Disused railway line to the west is bordered by woody vegetation.
Protected species: Unknown - no records.
Opportunities: Potential green corridors east / west across the site and along the western boundary. Maintain a buffer against LWS to the south.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
E4 Greycaine Road / Odhams / Sandown Road
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E5 Clarendon Road / Station Road / Bridle Path Office Area
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E6 Leavesden Studios - the Island site
Recognised nature sites within Site: part of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Recognised sites adjacent / close to Site: adjacent to the rest of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Other features: Semi-improved grassland habitat, part of a much larger complex.
Protected species: Badger setts on site and nearby.
Opportunities: Linking habitats to similar adjacent grasslands.
Ecological sensitivity: Low - medium.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species, with particular attention to badgers

Object

Watford Junction Draft Development Brief 2016

Representation ID: 851

Received: 03/10/2016

Respondent: Hertfordshire County Council SLU

Representation Summary:

In the context of the aggregates depot being identified as a weakness in the masterplan, minerals are important to the economy and it is not clear from the masterplan if the retention of the rails aggregate depot is not part of the scheme. There does not appear to be sufficient scope to accommodate the existing or relocated rail aggregates depot and this leaves the only option being an off site relocation.

Full text:

Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
With regard to Policy SPMX1: Special Policy Areas, the council is pleased to see the insertion of reference to the county council's documents. The text should however refer to the' Waste Local Plan' which includes both the Waste Core Strategy and Development Management Policies document and the Waste Site Allocations document.
With regard to Special Policy Area 2: Watford Junction, the council is pleased to see that there is reference to the need to safeguard the rail aggregates depot at Orphanage Road.
Further information on SPA2 is contained in Appendix I: Site Schedules of the Local Plan Part 2. The council is pleased that the rail aggregates depot is included as a
Spatial Planning and the Economy
Environment Department
Hertfordshire County Council
County Hall
Hertford
Hertfordshire
SG13 8DN
paul.donovan@hertfordshire.gov.uk
01992 556289
Planning Policy Team,
Room 65,
Watford Borough Council,
Town Hall,
Watford,
Herts,
WD17 3EX.
development consideration where it states 'This will need to be retained, or a new comparable facility provided within the local area'. However it should be noted that the text should refer to the 'rail aggregates depot' as opposed to the 'waste aggregates depot'.
However, in practice, taken together with the masterplan and accompanying viability report, there appears to be a strong likelihood that the rail aggregates depot is not to be retained on site and the collective impact of the Local Plan is not to safeguard the rail aggregates depot. Given this, the Inspector may well wish to see what evidence exists with regard to securing a replacement facility and currently no such evidence accompanies the Local Plan. As a consequence, there is considerable uncertainty in relation to whether the Local Plan satisfies potentially all soundness tests.
With regard to SPA6 Western Gateway, this includes ELAS221 and it is also worth pointing out that the areas designated as PS2 and PS3 potential in the Croxley View/Ascot Road Masterplanning Study are also located in ELAS221.
It is agreed that it is useful to insert text in relation to the circular economy as part of the waste section under paragraph 3.30, supporting text to Policy SD10: Waste. The second bullet point should state 'drive greater resource productivity.'
The relevant policy basis has been applied in the waste section and the Watford Local Plan with regard to responsibility for waste management. Whilst there appears to no longer be specific reference to Waste Policy 12, there is text to cover the use of this policy along with others within the Waste Core Strategy and Development Management Polices document. One comment to make is that in the wider context of the Watford Local Plan with there also being reference to ELAS221, the text in paragraph 3.30 should refer to the Waste Local Plan, which covers policies within the Waste Core Strategy and Development Management Policies document, adopted November 2012 and the Waste Site Allocations document, adopted July 2014.
Watford Junction Development Brief
As previously stated, most recently in respect of the Infrastructure Delivery Plan, the key matter of concern to the Minerals and Waste Planning Authority is the impact that any proposed development may have upon the safeguarded rail aggregate depot located at Orphanage Road, Watford which is a current operational facility.
The planning policy status, as detailed within the introduction of the brief, refers to consideration being had to national planning policy and the Watford Borough Council Local Plan. To ensure that the Development Plan has been considered as a whole the brief needs to also refer to the Minerals Local Plan and the Waste Local Plan. In terms of national policy, there is the need to ensure that the NPPF is considered in respect of para 143 which states that Mineral Planning Authorities should safeguard existing, planned and potential rail heads, so as to prevent their redevelopment for other uses and loss of the mineral infrastructure. This safeguarding is also applicable to storage, handling and processing facilities associated with them.
It is considered that due to the location of the rail aggregate depot within the development brief area that the county council's Minerals Local Plan 2002-2016, adopted March 2007 is also considered with specific regard to minerals policy 10: Railheads and Wharves. The Minerals Local Plan is being reviewed at present. It is envisaged, due to the requirement of the NPPF, that there will be a policy on Rail heads and Wharves in the Draft Minerals Local Plan.
The siting of the rail aggregate depot is shown within the county council's Mineral Consultation Area Supplementary Planning Document, adopted November 2007. The consultation area covers the majority of the Special Policy Area 2 Watford Junction. In accordance with the NPPF and Minerals Local Plan, in respect of minerals policy 10 the county council seeks to safeguard the rail aggregate depot which continues to serve as a sustainable mode of transporting minerals over long distances and the concrete batching facility which this site also supports. Given that the site is viable for use as a rail aggregate depot, its retention is expected unless the facility can be satisfactorily relocated within the development proposals in terms of operational requirements and environmental criteria or it has been or will be replaced in an alternative location.
The development brief identifies the rail aggregate depot as being a 'weakness' for the redevelopment of Watford junction in the SWOT analysis in paragraph 2.1. Minerals are important to the economy. Aggregate is needed to facilitate development and volumes of construction material being transported by rail in increasing. In light of this it could be considered that a rail aggregate depot in close proximity to the construction project could be considered to be a strength.
The issue of addressing such a 'weakness' is not however further expanded upon. It is clear from the illustrative masterplan that the retention of the rail aggregate depot is not part of the scheme. Whilst it is intended to be flexible enough to accommodate alternative layouts so long as it achieves the guiding principles and core ambitions of the masterplan, there does not appear to be sufficient scope to accommodate the existing or a relocated rail aggregate depot within the redevelopment area. As such this leaves the only option of relocating the rail aggregate depot offsite at another location along the railway line.
There is the need to establish an alternative well positioned strategic location for the rail aggregate depot to ensure its continued operation for imports and exports of minerals and secondary and recycled aggregates. The SWOT analysis in the development brief states that there is a 'weakness' in terms of a lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling. The Borough Council is referred back to paragraph 143 of the NPPF, the adopted Minerals Local Plan and specifically minerals policy 10 and the adopted Minerals Consultation Area SPD as detailed above in terms of the clarity for the safeguarding of the rail aggregates depot at Orphanage Road.
The brief states under the land use and quantum section of Station Quarter East within paragraph 3.4 that the development will be required to relocate the Rail Aggregates Depot within the local area, in consultation with Hertfordshire County Council and the operator of the site. The County Council will continue to work with the Borough Council in respect of this matter. The land use and quantum section in
paragraph 3.4 should also refer to the need to work with Network Rail with regard to the relocation of the Rail Aggregates Depot. The County Council understands that Network Rail Freight Management has been consulted and will provide comments to this consultation. There is however no further detail with regard a precise location having been secured.
To this end the relocation of the rail aggregate depot is fundamental to the delivery of the masterplan. A statement should be made in the delivery section of the brief at paragraph 4.1 specifically in relation to the requirement to ensure that the relocation of the rail aggregates depot forms part of the Watford Junction Delivery Plan.
Croxley View/Ascot Road Masterplanning Study
The Croxley View/Ascot Road Masterplanning Study has been considered by the county council as Waste Planning Authority due to the proximity of redevelopment to the Employment Land Area of Search (ELAS) 221 Watford Business Park.
The masterplan aims to build on the policy foundations of the district Local Plan Core Strategy Policy SPA6 to facilitate redevelopment. The location of potential residential development is shown within the Masterplanning Study to be directly adjacent to ELAS221 as designated within the county council's Waste Site Allocations document 2011-2026, adopted July 2014.
It is considered that ELAS that are predominantly used for general industry (B2) and storage and distribution (B8) are compatible with waste management uses. ELAS221 contains B1 and B2 uses and as such is acceptable in principle for a range of potential waste uses listed in the general waste brief during the 15 year plan period 2011-2026. Further planning guidance into the suitability of waste related development on the identified ELAS is within the ELAS Supplementary Planning Document, adopted November 2015. For this area, the Supplementary Planning Document states 'only enclosed waste transfer stations and materials recovery facilities that handle dry recyclables would be acceptable, along with enclosed inert waste recycling facilities. No other potential uses that may generate a leachate or liquor, which poses a risk to groundwater resources would be appropriate'.
The council does not wish to see the loss of identified ELAS for non-waste uses in order to safeguard it for future potential waste uses that may be sited in this location. Whilst the residential development would not directly encroach onto the ELAS, the council is mindful that the residential development is identified along the eastern boundary of the designated site and as a result there could be the potential for indirect impact upon the siting of waste uses within the ELAS.
The Waste Local Plan does not rely on the need for all land within ELAS across the county for the delivery of waste uses. However the cumulative loss of ELAS to non-waste uses is monitored and the safeguarding of remaining ELAS land is important to ensure there is a sufficient amount of land that could come forward for waste management facilities in the future, particularly with additional growth resulting in an increase in waste produced which needs to be managed.
There are currently no extant planning permissions on land directly adjacent to the masterplanned residential development to be aware of. The nearest waste site is the Household Waste Recycling Centre at Caxton Way in ELAS221. There is sufficient land remaining in ELAS221 to be brought forward for waste management uses.
The County Council does not wish to object to the masterplanning for potential residential development at this stage but reserves its right to object to future planning applications adjacent to the ELAS should a waste site be development in advance of residential. The reason for this would be to safeguard any waste use(s) under waste policy 5: Safeguarding of Sites within the Waste Core Strategy and Development Management Policies document 2011-2026, adopted November 2012. Further discussions would need to take place in the event that negative effects are identified that would restrict the waste operation to continue. A buffer between two land uses or mitigation measures in some cases may be appropriate to allow opposing land uses to exist in harmony adjacent to each other.
The County Council's adopted Waste Core Strategy and Development Management Policies document, does not stipulate a distance whereby other development in close proximity to a safeguarded waste site should be discouraged, the 2004 ODPM document: Planning for Waste Management Facilities: A Research Study states that for waste transfer stations: "sites closer than 250m from residential, commercial or recreational areas should be avoided." This guidance was used in the production of the Waste Site Allocations document. Depending upon the location of any potential future waste management facility within the ELAS, there is the potential that facilities may well be sited closer than the suggested 250m to any future housing.
Transport
Overarching/ general comments
Watford and the surrounding transport network face growing challenges as a result of the desired housing and economic growth in the area and increasing demand for travel. The County Council is developing a countywide transport model that will help all local authorities in the county to plan positively for growth and infrastructure investment in a way that safeguards the health and wellbeing of our communities and the environment. Already the model has identified notably worsening congestion issues in the Watford area as a result of planned growth. The next outputs of the enhanced Watford area version of the model will be available by the end of October 2016. The existing model is already available to Watford Borough Council to test development scenarios and proposals from the Local Plan.
In parallel with this, the County Council is developing a Growth & Transport Plan for South West Hertfordshire, which includes Watford and the surrounding towns and transport networks that make up a coherent area of travel demand. The Growth & Transport Plan will put forward packages of transport interventions to respond to strategic transport challenges and objectives for the area, derived through robust evidence analysis and engagement with stakeholders. Watford Borough Council officers and members have been involved from the early stages in GTP workshops
at key stages. The GTP is about identifying needs, planning for and enabling investment and delivery of a transport network and public realm that will support a healthy economy, environment and communities.
As a result of the current ongoing work being incomplete, at this stage there is insufficient evidence available to assess the implications of Local Plan Part 2 on the transportation network. As a consequence, there is uncertainty in relation to the mitigations that will be required to support the proposals and we remain in doubt that it potentially satisfies all soundness tests.
Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
Contents
'Appendix I - Site Allocations' is referred to later as 'Site Schedule'
'Appendix L' and 'Appendix M' missing from content list
Policy SD10
Refuse collection vehicles must be able to stop within the 'maximum refuse carry distance' specified by the Local Planning Authority or within 25m of any bin storage area, whichever is the lesser distance. Residents should not have to carry their rubbish more than 30m to a storage point. (Sources BS5906:2005 and Schedule 1 Part H Building Regulations)
Policy TLC14
On-street parking continues to need to be managed to manage congestion and avoid hazards, particularly at junctions.
Policy HS7
The subjective "undue pressure" on on-street parking should not lead to increased congestion and / or hazards on the highway network, particularly at junctions.
The siting of bin stores should not adversely impact on the operation of the highway network.
Policy HS8
The Highway Authority recommends that consideration of deliveries is made explicit in this policy.
6.9 and Policy EMP5
The County Council supports urban realm enhancement of Clarendon Road to encourage walking and cycling and improve the key pedestrian route between the town centre and Watford Junction.
Consideration should be given to amending the policy wording to explicitly include an expectation for development along Clarendon Road to contribute towards urban realm enhancements directly through works delivered or through developer contributions to fund such works.
Policy T6
The County Council is supportive of the zonal approach to car parking guidance to encourage lower car ownership and usage in more accessible zones. The principle of 'Car Lite' development in the most accessible areas, within 5 or so minutes' walk of a major transport hub, is also supported as long as the needs of disabled drivers and visitors are considered.
Lower car parking provision must be accompanied by appropriate restrictions in surrounding residential streets and any public car parks to prevent spill-over parking. In order for this approach to lowering car usage to be successful, there needs to be parallel investment in infrastructure (eg significantly better cycle and bus routes) and urban realm improvements to support and actively encourage alternative modes of travel.
The County Council welcomes the requirements for car club spaces in the SPAs and where parking does not meet the guidance.
Policy T8 and Appendix H
The policy on cycle parking provision and the stipulations relating to quality contained in the policy is welcomed. Adequate cycle storage must also be provided for existing and high predicted future levels.
A small change is recommended to allow for cycle parking provision for dwelling houses to be in a private garage as well as within the private garden area - subject to the dimensions of the garage being adequate to accommodate cycles as well as any vehicle.
However, the policy only specifies one long-term space per unit (regardless of size or location) where there is no garage or shed. In some instances such as within SPA2 and SPA6 where housing will be in the form of apartments and where there will be reduced car parking, it may be necessary for additional capacity for cycle storage beyond one space per unit, especially for larger flats or any flats without car parking provided.
Policy UD3
Structures abutting and overhanging the public highway will need the approval of the Highway Authority (HCC) as will illumination visible from the highway.
Policy TB1
From a transport network and user perspective, locations near to major passenger transport hubs, offering good interchange between different services and modes, are the most appropriate for denser development (i.e. taller buildings). However, development proposals should all be subject to Core Strategy policies T2-T5 to ensure that their impacts are understood and mitigated.
In order for such development to be acceptable, there must be adequate and appropriate improvements to transport infrastructure and urban realm within the site and in the wider area, to ensure no significant adverse impact on the highway and passenger transport networks, as a direct, indirect or cumulative result of development at the site and in the Borough as a whole.
Policy TB2
Suggest change to text at 8. Transport, parking and infrastructure:
'The design should detail a transport strategy for the proposed development to include how cycle parking, car parking, cycle permeability and pedestrian permeability have been integrated into the overall design. This should be based on a Transport Assessment and should avoid negative impacts on the public realm. The scheme will also need to demonstrate that the required infrastructure and utility capacity has been fully appraised.'
Appendix G
Parking bay dimensions only seem to consider residential element, parking bay at 2.4 x 4.8m is fine for standard bay but dimensions of other bays should be provided e.g. parallel arrangement. The garage dimensions provided are 3m x 5.5m whereas the industry standards are 3m x 6m (MfS para 8.3.41). Should minimum circulatory space for car parks be covered here (i.e. 6m) or will it be covered elsewhere?
SPA1
The ring road constrains pedestrian and cycle accessibility to the heart of the town centre. nb includes EMP5, R1, R2, R3, R4, R5. See Highway Authority comments in regard to each of these.
SPA2
Any development within the Watford Junction SPA should ensure that connectivity for pedestrians and cyclists is improved across the site, between the site and the town centre and on other key routes to Watford Junction Station.
Development of the station building, forecourt and car parks must address current limitations including capacity, access and circulation issues, for pedestrians, cyclists, buses, bus users, taxis, as well as users of the car parks. Opportunities to make Watford Junction an attractive and functional transport interchange that can accommodate future growth should be maximised.
See Highway Authority comments on Draft Development Brief (below).
SPA3
Good quality cycle and pedestrian links through the site and between the site and surrounding area and key destinations (town centre, Vicarage Road MLX station, local schools etc.) must be provided, or contributions to support infrastructure improvements in the wider area made through developer contributions.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
SPA4
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
Support improvements to green infrastructure and public realm as a complement to improvements to pedestrian and cycle links.
Flooding is a known issue affecting this area. Any development in this area should be designed to avoid and mitigate flood risk. Sustainable drainage approaches and green infrastructure should be used where appropriate to reduce and manage flood risk.
SPA5
Development at this location will need to consider transport impacts on the highway network, including operation of the Dome roundabout and St Albans Road notably at peak times. Also junctions including M25/A405/M1, and M1/A41.
There is a need to improve cycle, pedestrian and passenger transport connectivity to the site, and between the site and the town centre and Watford Junction.
It is recognised that the Abbey Line (North Watford) station is closer to the site, but there are limitations to this service at present which will reduce its attractiveness as an alternative to the car for journeys to Watford Junction or St Albans Abbey stations.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
There is a typo on second bullet point - should read 'improve air quality'.
SPA6
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Cycle improvements on Rickmansworth Road may be required as this is a key corridor between Rickmansworth and Watford.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
Secure, high quality cycle parking is needed at the proposed Cassiobridge station, as well as within the employment premises.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
See Highway Authority comments on Masterplanning Study (below)
MXD3
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
R1
It is agreed that robust pedestrian links with the town centre should form part of the new development at this location.
Good cycle access and high quality cycle parking also needs to be provided, for customers as well as employees.
R2
Agree that clear pedestrian connections between the site and the High Street are needed.
Good cycle access and cycle parking must also be provided.
There is a need to consider access needs to the site by different modes. A planned highway improvement scheme will make Clarendon Road one-way (NE-SW only) from Beechen Grove to High Street, with a contraflow cycle lane. Access to the street will be restricted by a Traffic Regulation Order to buses, taxis, cycles, 'blue badge' vehicles, and other vehicles 'for access only' to premises. All accessing vehicles will need to leave either via High Street or Watford House Lane (private road) for those accessing that area.
Development of this site should complement public realm enhancements proposed or already delivered on Clarendon Road and the High Street.
R3
Good cycle access and storage facilities must be provided, as well as good pedestrian links.
Developments at this location must take into account severance issues caused by the ring road for pedestrians and cyclists. Improvements required such as crossing improvements, new accesses into/through the site, should be delivered as part of the development or through developer contributions.
R4
Strong pedestrian and cycle links between this site and the town centre must be provided.
The quality of cycle routes and access to/from the west needs to be improved - eg. Market Street west of ring road and the Hornets Gyratory.
H1
This site is in close proximity to Bushey Station and includes its car park.
Opportunities to upgrade access to the station by non-car modes should be pursued.
Need to consider quantity and quality of cycle parking and cycle access to station from surrounding area.
Cycle access and cycle parking provision at Bushey station should be improved as part of any car parking replacement/improvement scheme.
Bushey Arches is a known congestion hotspot. Impacts of development on Bushey Arches must be considered and mitigation provided. This should include contributions to needed improvements to key walking and cycling routes and passenger transport infrastructure in the area.
H2
The ring road causes significant severance to people travelling by foot and cycle. Particular issues have been reported for people with visual impairments.
Improved cycle and pedestrian links to town centre and to Watford High Street and Watford Junction stations are needed from the site.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
H3
This site is about half mile from both the proposed Vicarage Road Met Line station and Watford High Street station, which is 10 to 12 minutes walking time.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
Vicarage Road is a busy road without dedicated cycle facilities. As such improvements to this route for cyclists should be considered. Developer contributions to improving cycle routes may be appropriate.
H5
The traffic impact on west Watford's road network needs to be considered and mitigated.
Cycle and pedestrian links into the site from different directions are required.
Adequate cycle storage must also be provided for existing and high predicted future levels.
Cycle infrastructure and the pedestrian environment of the surrounding area needs consideration.
H9
The impact of development at this site on the road network must be considered and mitigated if needed, including Rickmansworth Road and West Watford.
Good cycle links are needed including between the site, the town centre, and Ascot Road.
Bus services and infrastructure, including linking to new Cassiobridge Met Line station.
Bus services in this area may well be subject to change following the loss of the underground station. Development of this site and any forthcoming S106 contributions would provide the opportunity for an assessment to be made of potential improvements to bus services so this site remains connected to key destinations.
E1
High quality, secure cycle provision is needed at business premises.
Although the Ebury Way provides a good cycle route to the site, this will not be suitable for use all year round, at any time of day. As such improvements to the A412 corridor cycle infrastructure should be explored and provided. Developer contributions may be appropriate.
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
E2
Cycle and pedestrian routes through the site need improvement;
Via Watford Junction SPA site, there is a need to reduce severance and improve pedestrian and cycle connectivity to Watford Junction station and Clarendon Road.
WBC also needs to consider the implications of the Colonial Way Link road on development at site E2.
There is a need to consider potential transport implications of this site and the Watford Junction masterplan as a whole, including traffic accessing any new station multi-storey car parks, and the impact on the road network (eg. Colonial Way, Stephenson's Way, Radlett Road, Link Road, A41/M1 junction...).
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions.
E4
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions and on footways.
E5
Needs to link with SPA2 Watford Junction.
Development will need to assess impacts on road network and car parking demand in surrounding area.
Quality of pedestrian and cycle environment and urban realm on Clarendon Road should be considered and opportunities to enhance in consistent, coherent way should be explored to promote sustainable travel and improve route between town and Watford Junction.
Buildings will need to provide adequate, high quality secure cycle parking. If low car parking, may need to increase requirements or leave space to expand provision as required.
G6
Any change in land use/ status/ access provision to the south of Caxton Way and the south and east of Greenhill Crescent should not be permitted until its ability to provide the link for sustainable modes between Tolpits Lane and Caxton Way required by paragraph 10.6.9 of the WBC Core Strategy has been fully explored and ruled out.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF
1.1
The traffic and transport impacts of the masterplan scheme have not been modelled and thereby understood. The Highway Authority is, therefore, unable to fully support the plan until those impacts are assessed and deliverable mitigation measures agreed. HCC is developing traffic and transport models of Watford as part of its work to create a Growth & Transport Plan for the area. These will be used to test the impacts of the Watford Junction and other development proposals on transport infrastructure and services individually and cumulatively.
As part of earlier work on this site the County Council had required the construction of a road and bridge linking Colonial Way and St Albans Road via Penn Road. The scheme to build it received outline DfT funding and included a passenger transport (coach) interchange on the northeast side of the station. If the link road and bridge are no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
1.2
Correct reference to 'Abbey Link' in map to 'Abbey Line'.
2.1
The Barriers plan acknowledges the severance created by the presence of the Abbey Line. As part of earlier work on this site the County Council had required the construction of a road over the Abbey Line linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.2
Policy T1 in the borough council's Core Strategy supports conversion of the Abbey Line from heavy to light rail operation.
Correct reference to 'Abbey Flyover' in Objectives to 'Abbey Line'.
2.3
Correct reference to 'Abbey train line' under Transport and Parking to 'Abbey Line'.
As part of earlier work on this site the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.4
Gross External Areas values are different to those in 5.1 Area Schedules.
3D views might benefit from road names for orientation.
2.7
As part of earlier work on this site, the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
It is recommended that all roads are usable by cycles to aid permeability.
The road hierarchy titles have different meanings in the Highway Authority's own existing hierarchy. As the design is refined it is recommended that confusion is avoided by using different names.
2.8
The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.
3.3
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
3.4
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
4.1
The County Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order that they can be considered in the emerging Watford Growth & Transport Plan. Joint working with the County Council will remain key in order to maximise access to appropriate funding streams and delivery programmes.
Special Policy Area 2 is zero-CIL-rated so that all planning obligations will be derived via Section 106 agreements with service providers.
4.2
An overall Travel Plan for the site will be required and one for each subsequent development area should be provided and agreed.
5.1
Total car parking number differs from that given in 2.4 and Station Quarter East breakdown (p 46).
Gross External Areas values are different to those in 2.4.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF VIABILITY APPRAISAL
4.2
The County Council is concerned about the unrealistically low estimates given in figure 4.1 for the costings of infrastructure required to mitigate the impact of the masterplan.
CROXLEY VIEW/ ASCOT ROAD STUDY
Introduction
Mention must be made of the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The need for a link both for Watford and Three Rivers grows as pressure to develop either side of the Ebury Way increases and its delivery should be seen as key to both authorities' Duty to Cooperate.
Plans
All plans refer to Watford County Council.
All plans show Croxley Green Business Park to the southwest of the masterplan area. This is correctly the Wolsey Business Park.
Most plans show the Grand Union Canal badged as the River Gade which runs to the south and east of it.
Some plans do not show the correct alignment of the Watford/ Three Rivers boundary.
Some plans erroneously label the NE corner of Croxley Common as Cassiobury Park Nature Reserve.
Masterplanning Strategy plan - asterisks and other labelling are not described and inconsistently applied.
Potential Development Sites plan
This omits to include the Tech Site (around Woodshots Meadow). This is subject to preapplication discussions now and should be considered with the adjacent sites as it is in Employment Policy Area E1 (Local Plan Part 2 appendix 1).
Proposed Vehicle and Pedestrian Movement plan
This omits the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The route currently being explored follows the cycle track between the Watford Enterprise Centre and number 27 Greenhill Crescent.
Historic environment, landscape and ecology
The County Council supports the overall policy intentions of the Local Plan covering landscape, ecology and the historic and built environment and provides the following comments to help strengthen these policies and their supplementary text.
Historic Environment
Development Management Policies
The County Council welcomes the Borough's consideration of the Historic Environment in Part 9 Urban Design and the Historic Environment. However, the historic environment should be referenced in line with the NPPF definition of heritage assets. In addition to historic buildings (both designated and undesignated), the historic environment of Watford includes archaeological remains, historic landscapes and historic parks. Therefore policies are needed to conserve the historic environment as whole, not just designated buildings, registered gardens and conservation areas as is currently stated.
Under Policy UD4, Archaeology, there appears to be repetition of the NPPF, the policy is unclear and should be re-written.
There is also reference to the conservation of heritage assets being secured by an archaeological Written Scheme of Investigation (WSI). Whilst the County Council welcomes the requirement for these documents and for them to include provision for publication and public dissemination of results where appropriate (NPPF 141), it is not clear if the WSI on its own is considered to be robust enough to secure appropriate conservation of the historic environment. Therefore it is unclear if this part too, is effective.
Watford Junction Draft Development Brief 2016
Paragraph 4.2 notes that a Heritage Statement and Desktop Archaeological Study may need to be submitted with any planning applications. However, it is unclear what is meant by a Heritage Statement. Also archaeological assessment may not be limited to a desktop study.
Site Allocations
An appraisal of the archaeological implications of development for the new areas identified in the Second Consultation document (2016) is summarised below.
1. Archaeology as a Development Constraint
N/A
2. Requirement for Pre-allocation Archaeological Assessment
The sites below have known archaeological remains within them or have significant archaeological potential by reason of their size and situation, such that there is a risk that archaeology could be a constraint on any development. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that archaeological assessments should be included within all development briefs and other proposals for the sites, before they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the sites, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent of archaeological remains that might be a constraint upon the principle of development of these sites.
Allocation numbers: SPA1, SPA4 and H9.
3. Requirement for Pre-application or Pre-determination Archaeological Assessment
The sites below have known archaeological remains within them or have archaeological potential. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that that pre-application or pre-determination archaeological assessments should be included within all development briefs and other proposals for the sites, if they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the proposals, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent
of archaeological remains worthy of preservation in situ, to enable the LPA to determine any specific application for development.
Allocation numbers: SPA 2, SPA3, SPA5, SPA6, MXD1, MXD3, R1, R2, R3, R4, H2, H3, H4, H 10, E1, E2, E3, E4, E5, E6.
4. Mitigation of archaeological impact by condition
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, any archaeological issues can probably be dealt with by condition, should planning permission be granted.
Allocation numbers: R5, CF1, H1, H5, H6, GT1.
5. No archaeological requirements
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, there are unlikely to be any archaeological implications. However this will depend on the details of any proposals and any new archaeological information.
Allocation numbers: MXD2, MXD4, H7, H8, H11.
Ecology
Development Management Policies
Policy SD15, External lighting, the County Council support the provisions set out in this policy and advise that there should be reference to the guidance provided by the Institute of Lighting Engineers which has been instrumental in seeking to reduce the impacts of artificial lighting within the environment.
Green Infrastructure, Biodiversity and Recreation, the County Council supports the reference to Green Infrastructure (GI).In defining GI there should also be reference to the provision of local food production as a key ecosystem service.
Policy G15, Trees, Woodlands and Hedgerows, this policy is supported in respect of highlighting ecological and cultural value of trees, woodlands and hedgerows. However, under paragraph 10.3, the reference to valuable habitats should be extended to include reference to ecological networks and corridors. Under paragraph 10.6 it should be clarified that replacing trees lost to development cannot compensate for the loss of biodiversity or amenity value in the short term.
Policy GI6, Protecting and Enhancing the Grand Union Canal, this policy is supported including the reference to enhancing biodiversity under paragraph 10.11. It is advised that the policy is extended to include a clause that seeks to improve the biodiversity of the canal corridor where possible. Development that would have an
adverse impact on the biodiversity of the canal would not be supported unless it can demonstrate provision of suitable mitigation or compensation.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, this policy is supported however recommend the following clarifications and amendments.
It is advised to make reference to the 'amenity value' of the river, specifically encouraging 'recreation' may increase disturbance to sensitive wildlife within river corridors. The term 'amenity' embraces visual and recreational importance without being too prescriptive or disruptive if more sensitive habitats or locations are affected an important consideration within this largely urban area.
With regards the provision of 'a corridor for wildlife and biodiversity,' the reference to biodiversity should be deleted as wildlife is biodiversity. With regards replacement structures and fish passage, liaison with the Environment Agency is essential if any such works are proposed. With regards access it should be designed in a way that also enables some undisturbed areas to be retained.
Policy GI9, Provision of Open Space and Play Space in Residential Development, aspects of this policy relevant to biodiversity are supported. The reference to green space typologies should be expanded to include allotments and community orchards, in order to reflect the types of functional sites which support both community and biodiversity benefits.
Biodiversity, it is not clear why this section is formatted differently to the preceding and subsequent sections. In particular it does not describe 'Why is this policy needed?' and 'what is it intended to do?' In setting out the need for the policy, it should reference the legislative requirements of statutorily protected sites and species which are a material consideration in planning, as well as the Duty placed on Local Authorities to have regard to conserving biodiversity in all of their functions as set out in the Natural Environment and rural Communities Act 2006. In setting out the intention of the policy there should also be reference to seeking to deliver the aims of the Local Nature Partnership - for which securing ecological resources, functions and services are a consideration when determining planning applications.
Under paragraph 10.37 the reference to the 'Biodiversity Plan' should be amended to reference to the 'Biodiversity Action Plan principles' (BAP). The BAP, nationally and locally, has ceased to be actively supported by National and Local Government, and has essentially been replaced by the Local Nature Partnership. However the principles underpinning it remain valid as statements and the intentions of the various habitat and species action plans are sound in themselves and could be followed if resources or interest permitted.
It is suggested that the statement under paragraph 10.39 should be amended as follows:
'This policy expects that where appropriate, development proposals will demonstrate the relative ecological value of a site before and after development. Proposals should follow the mitigation hierarchy and provide clear evidence of impacts and enhancements where appropriate, consistent with the aims of NPPF, BS42020
"Biodiversity - Code of Practice for Planning and Development'' and guidance provided by CIEEM. This will require sufficient detail and clarity to enable net losses and gains to be identified and monitored, consistent with the Code. Where unavoidable, Biodiversity Offsetting should be considered as a means to ensure there is no net loss of biodiversity resulting from development'.
Highlighting the specific use of Biodiversity Calculators such as the one mentioned in paragraph 10.39 can be a little misleading. BS42020 does not mention the use of biodiversity calculators, and taken out of context the results of such calculations can sometimes show net gains where there should be none (removal of ancient woodland for example cannot reasonably be compensated in the real world). Other wider landscape issues are also not always considered by these calculators; if the land is part of a wider corridor, or a biodiversity network for example. It has taken several years for Warwickshire County Council to incorporate their use in to the planning system and there is still not universal agreement on them.
The County Council would therefore advise caution on their avocation, but rather emphasise the need to prove that biodiversity has not been lost and in the most part enhanced through "appropriate methods in-line with BS42020".
Policy GI10 Managing Biodiversity in new Developments. The County Council supports Watford Borough Council's commitment to increasing biodiversity within the district. The Policy is consistent with other Hertfordshire Local Authorities, and in-line with the National Planning Policy Framework.
The following amendments are advised. There should be reference to avoiding negative impacts upon ' local ecological networks...,'as each site sits within a local environmental and should retain or enhance any existing ecological resources or corridors to and from adjacent sites.
'Compensation will only be considered as a last resort. Development proposals will be expected to evaluate the impact on local biodiversity where appropriate and propose measures to maintain and enhance biodiversity. This approach should follow the principles outlined within BS42020 "Biodiversity - Code of Practice for Planning and Development" or other measures of best practice, including Biodiversity Offsetting where necessary'.
The above wording embraces the mitigation hierarchy as well as defining means to achieve no net loss as sought by NPPF, without being too prescriptive.
It is considered that paragraph 10.40 regarding the biodiversity calculator is not needed if references requiring its specific use are otherwise removed. The County Council remain concerned that some caution needs to be taken regarding the generation of positive scores which indicate a net gain despite losses that may otherwise be considered unacceptable.
Site Allocations
Please refer to Appendix 1.
Landscape
Green Infrastructure, Biodiversity and Recreation, the policy framework for green infrastructure (GI) was significantly strengthened in Feb 2016 with the introduction of detailed Planning Policy Guidance. The guidance states that GI is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water and should be a key consideration in both local plans and planning decisions.
The Herts Landscape and Green Infrastructure Group is currently looking at GI delivery and practice across Hertfordshire with a view to presenting a project proposal to Herts Infrastructure Planning Partnership (HIPP) in November. The key aim of the project is to mainstream the delivery of GI through the local plan and development management processes. The outputs and deliverables of the project are currently being shaped and should help provide local planning authorities with a good practice approach to GI delivery, supported by robust evidence and case studies.
The Landscape Institute Position Statement for Green Infrastructure provides a widely supported definition of GI (assets and functions) and a comprehensive overview of the key benefits it can deliver, supported by case studies http://www.landscapeinstitute.org/policy/GreenInfrastructure.php
There is no reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans. (The strategies provide an opportunity to address cross boundary issues and meet the Duty to Cooperate. (Hertfordshire and GreenArc Area Strategic Highlights Plan (SHiP) and the All London Green Grid.)
There should be greater emphasis on GI in place-making and conserving and enhancing local distinctiveness. There should be reference to any local character assessments and the guidelines for managing change that should help shape proposals, and conserve and enhance local character.
At a national level there is also the National Character Areas produced by Natural England https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making, and at a regional level there is the East of England Landscape Framework http://landscape-east.org.uk/.
Where proposals are likely to result in landscape and visual effects a landscape and visual impact assessment, in line with industry good practice guidance (Landscape and Visual Impact Assessment third edition Landscape Institute and Institute for Environmental Management and Assessment) may be required as part of an application. The mitigation hierarchy should be referenced to ensure that proposals seek to avoid and minimise any negative effects.
The reference to Green Infrastructure under paragraph 10.1, is fully supported, however it is suggested to expand the definition to include reference to blue assets
such as the Grand Union Canal. Also suggest amend reference to 'mitigating climate change' to 'mitigating the effects of climate change.'
Under paragraph 10.3, it should be clear that biodiversity is not the only driver for Green Infrastructure; other key drivers include a single or multiple land-use functions and include waste/water management, recreation, food production, local distinctiveness etc.
Policy GI5, Trees, Woodlands and Hedgerows, the reference to the protection of trees in line with current British Standard Institute code of practice is fully supported, however the full title of the standard does not appear to be referenced and should be 'Trees in relation to design, demolition and construction' (BS5837:2012). In addition it is advised that where required by the planning authority, tree surveys, arboricultural impact assessments and method statements should all be carried out in compliance with this standard.
The policy should be expanded to include reference to the current hedgerow regulations, the provision of a landscape strategy, planting plans and specifications, and the provision of aftercare (long term management plans) and replacement of failures.
Policy GI6, Protecting and Enhancing the Grand Union Canal, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Yours sincerely,
Paul Donovan
Environment Department
Hertfordshire County Council
APPENDIX 1
Please find below a brief ecological assessment of the site allocations. A 'standard' template for each Site has been provided.
Ecosites do not have any form of status of importance, but are merely sites that we have some ecological information on - thus they do support some wildlife interest, at least at a local level. Whilst these sites are often a valuable starting point in identifying the county's wildlife resource, they do not meet the rigorous and quantifiable assessment criteria needed to identify them as non-statutory Local (County) Wildlife Sites.
SPA1 Town Centre
Recognised sites adjacent / close to Site: close to eastern end of Cassiobury Park Local Wildlife Site.
Other features: Little semi natural habitat present, possibly some mature trees.
Protected species: Probably bats, badger records to the west.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road)
Protected species: Unknown - no records
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA3 Health Campus (includes a Borough Council Depot and Waste Transfer Station at Wiggenhall Road)
Recognised nature sites within Site: The Lairage Land Local Wildlife Site (LWS) and Local Nature Reserve (LNR), Croxley Green Junction Sidings LWS, Oxhey Park River & Margins LWS; Riverside Road Waste Ground ecosite (local database site), The Island, off Cardiff Road ecosite, Oxhey Park ecosite
Recognised sites adjacent / close to Site: Horwoods Avenue Playground ecosite, Moor View ecosite, Cardiff Road Embankment ecosite.
Other features: includes village green - "Green situated between Riverside Road & the River Colne"
Protected species: Birds and Water voles.
Opportunities: High. Habitat management to maintain and enhance biodiversity interest, green infrastructure / corridors.
Ecological sensitivity: Medium to high depending on location.
Fundamental ecological constraint: Presumption to avoid development on Local Wildlife Sites, fragmentation of green corridor,
Loss of Farm Terrace allotment site - should be offset elsewhere as open space / community food growing / ecological resource.
SPA4 Lower High Street
Recognised sites adjacent / close to Site: Bushey Hall Farm ecosite, Oxhey Park ecosite.
Other features: "Recreation Allotments" village green.
Protected species: Unknown - no records. Birds in trees.
Opportunities: Limited as previously developed site. Potential green corridors along railways lines.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA5 Dome Roundabout (includes a Waste Transfer Station at Colne Way)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA6 Western Gateway (includes area of search ELAS221 in the Hertfordshire Waste Site Allocations Document)
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite, Ascot Road ecosite.
Recognised sites adjacent / close to Site: close to eastern end of Croxley Common Moor Site of Specific Scienttific Interest (SSSI) and LNR.
Other features: Grassland strip along eastern boundary with bordering trees.
Protected species: Unknown - no records.
Opportunities: Enhance green infrastructure corridor along eastern boundary.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds in trees.
The ecosites have largely been destroyed by development.
MXD1 North Watford library, Lemarie Centre for Charities, and health facilities (within SPA5)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
MXD2 The Brow
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
MXD3 Gas holder site (within SPA4)
Other features: River Colne borders the eastern boundary.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site. Potential to enhance the river margins as a green corridor.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in the trees.
Largely developed but riverside trees most important and scrub on site.
MXD4 Ascot Road
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite.
Other features: As well as the rough ground and bordering trees of the area to the west, the Site includes part of the school playing fields to the east, which is short mown amenity grassland. There are also some mature trees.
Protected species: Unknown - no records.
Opportunities: Potential enhancement of the areas of semi-natural habitat to improve green corridor connectivity.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds. Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R1 Sainsbury's and adjoining land
Other features: The north-eastern part of the Site includes an area of grassland and mature trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R2 Former TJ Hughes and adjoining land
Other features: Small area of amenity grassland on the north-eastern side.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R3 BT Telephone Exchange and adjoining Wellstones
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R4 Church Street Car Park and land fronting Market Street/Market Place
Other features: area of amenity grassland and scattered trees on the southern side.
Protected species: Unknown - no records.
Opportunities: Limited as predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R5 Charter Place centre and adjoining land onto the High Street
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
CF1 Community Facility Tolpits Lane.
Other features: Site appears to be rough grassland with scattered scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to enhance the habitats on site. The northern boundary is a wooded bank bordering the railway line. Maintain / enhance green corridor along railway.
Ecological sensitivity: Low - medium as semi-natural habitats on site.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H1 Land at Pinner Road
Other features: There are small areas of rough (possibly amenity) grassland with scrub and scattered trees.
Protected species: Unknown - no records.
Opportunities: Limited as a predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H2 Skatepark, Lower Derby Road
Other features: There is an area of grassland with trees in the north-west corner.
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a predominantly a previously developed site. Potential to maintain / enhance the semi-natural habitats on site for green corridor links to nearby habitats, river corridor and wooded railway banks.
Ecological sensitivity:
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H3 Vicarage Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H4 Telephone Exchange - First Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H5 Builder's Yard, Queens Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H6 Bill Everett Community Centre
Recognised sites adjacent / close to Site: adjacent to Long Spring and Harebreaks Wood (Watford) Local Wildlife Site and Local Nature Reserve.
Other features: some areas of grassland (probably amenity?) and occasional scattered trees.
Protected species: Bat roost in building nearby.
Opportunities: Potential to link woodland to the south to area to the north - depending on what the latter is like, as it appears to be bare ground on our aerial photographs.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H7 Rickmansworth Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H8 Garages- The Gossamers
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H9 Watford Station, Cassiobury Park Avenue
Recognised nature sites within Site: Cassiobury Park Avenue allotments ecosite.
Recognised sites adjacent / close to Site: close to "Gade Avenue" Local Wildlife Site.
Other features: Includes an area of allotment gardens and mature trees.
Protected species: Unknown - no records. Potential for bats and reptiles.
Opportunities: Maintain and enhance the green corridor link along the railway line.
Ecological sensitivity: Low - medium?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H10 Croxley View
Other features: Area of semi-natural grassland with scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to manage the existing habitats to maintain / improve biodiversity. Maintain as a green infrastructure link from open grasslands to the south towards the River Gade corridor and semi-natural habitats to the north
Ecological sensitivity: Low.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H11 Garages, Bowmans Green
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
GT1 Lands at Tolpits Lane
Other features: Area of rough grassland with bordering trees.
Protected species: Unknown - no records.
Opportunities: Limited, but part of semi-natural grassland complex in the area so potential for linking hedgerows. Any loss of grassland could be compensated for by enhancement elsewhere and landscaping may provide additional buffering habitats locally if this site were to be developed as such.
Ecological sensitivity: Low?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
E1 Watford Business
Recognised sites adjacent / close to Site: adjacent to Croxley Common Moor Site of Special Scientific Interest (SSSI and Local Nature Reserve (LNR) and Commonland; adjacent to Ascot Road Car Park and Waste ecosite, adjacent to Ascot Road ecosite; close to Ascot Road Scrub Local Wildlife Site.
Other features: Some areas with trees.
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
Part of the edge of this currently provides a valuable buffer and boundary edge to Croxley Common Moor SSSI and LNR. We would object to any development which further degraded this boundary habitat, although much of the former area has already been lost to hard surfacing.
E2 Imperial Way / Colonial
Protected species: Limited as a previously developed site.
Opportunities: Low.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E3 Fishers
Recognised nature sites within Site: Cardiff Road Embankment ecosite.
Recognised sites adjacent / close to Site: adjacent to Croxley Green Junction Sidings Local Wildlife Site.
Other features: Disused railway line to the west is bordered by woody vegetation.
Protected species: Unknown - no records.
Opportunities: Potential green corridors east / west across the site and along the western boundary. Maintain a buffer against LWS to the south.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
E4 Greycaine Road / Odhams / Sandown Road
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E5 Clarendon Road / Station Road / Bridle Path Office Area
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E6 Leavesden Studios - the Island site
Recognised nature sites within Site: part of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Recognised sites adjacent / close to Site: adjacent to the rest of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Other features: Semi-improved grassland habitat, part of a much larger complex.
Protected species: Badger setts on site and nearby.
Opportunities: Linking habitats to similar adjacent grasslands.
Ecological sensitivity: Low - medium.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species, with particular attention to badgers

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 852

Received: 03/10/2016

Respondent: Hertfordshire County Council SLU

Representation Summary:

There is need to establish an alternative location and a statement should be made in the delivery section of the brief at paragraph 4.1 in relation to the requirement to ensure that the relocation forts part of the delivery plan. This is identified in the context that the brief states that the quantum required in the Station Quarter would require the relocation of the aggregates depot within the local area.

Full text:

Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
With regard to Policy SPMX1: Special Policy Areas, the council is pleased to see the insertion of reference to the county council's documents. The text should however refer to the' Waste Local Plan' which includes both the Waste Core Strategy and Development Management Policies document and the Waste Site Allocations document.
With regard to Special Policy Area 2: Watford Junction, the council is pleased to see that there is reference to the need to safeguard the rail aggregates depot at Orphanage Road.
Further information on SPA2 is contained in Appendix I: Site Schedules of the Local Plan Part 2. The council is pleased that the rail aggregates depot is included as a
Spatial Planning and the Economy
Environment Department
Hertfordshire County Council
County Hall
Hertford
Hertfordshire
SG13 8DN
paul.donovan@hertfordshire.gov.uk
01992 556289
Planning Policy Team,
Room 65,
Watford Borough Council,
Town Hall,
Watford,
Herts,
WD17 3EX.
development consideration where it states 'This will need to be retained, or a new comparable facility provided within the local area'. However it should be noted that the text should refer to the 'rail aggregates depot' as opposed to the 'waste aggregates depot'.
However, in practice, taken together with the masterplan and accompanying viability report, there appears to be a strong likelihood that the rail aggregates depot is not to be retained on site and the collective impact of the Local Plan is not to safeguard the rail aggregates depot. Given this, the Inspector may well wish to see what evidence exists with regard to securing a replacement facility and currently no such evidence accompanies the Local Plan. As a consequence, there is considerable uncertainty in relation to whether the Local Plan satisfies potentially all soundness tests.
With regard to SPA6 Western Gateway, this includes ELAS221 and it is also worth pointing out that the areas designated as PS2 and PS3 potential in the Croxley View/Ascot Road Masterplanning Study are also located in ELAS221.
It is agreed that it is useful to insert text in relation to the circular economy as part of the waste section under paragraph 3.30, supporting text to Policy SD10: Waste. The second bullet point should state 'drive greater resource productivity.'
The relevant policy basis has been applied in the waste section and the Watford Local Plan with regard to responsibility for waste management. Whilst there appears to no longer be specific reference to Waste Policy 12, there is text to cover the use of this policy along with others within the Waste Core Strategy and Development Management Polices document. One comment to make is that in the wider context of the Watford Local Plan with there also being reference to ELAS221, the text in paragraph 3.30 should refer to the Waste Local Plan, which covers policies within the Waste Core Strategy and Development Management Policies document, adopted November 2012 and the Waste Site Allocations document, adopted July 2014.
Watford Junction Development Brief
As previously stated, most recently in respect of the Infrastructure Delivery Plan, the key matter of concern to the Minerals and Waste Planning Authority is the impact that any proposed development may have upon the safeguarded rail aggregate depot located at Orphanage Road, Watford which is a current operational facility.
The planning policy status, as detailed within the introduction of the brief, refers to consideration being had to national planning policy and the Watford Borough Council Local Plan. To ensure that the Development Plan has been considered as a whole the brief needs to also refer to the Minerals Local Plan and the Waste Local Plan. In terms of national policy, there is the need to ensure that the NPPF is considered in respect of para 143 which states that Mineral Planning Authorities should safeguard existing, planned and potential rail heads, so as to prevent their redevelopment for other uses and loss of the mineral infrastructure. This safeguarding is also applicable to storage, handling and processing facilities associated with them.
It is considered that due to the location of the rail aggregate depot within the development brief area that the county council's Minerals Local Plan 2002-2016, adopted March 2007 is also considered with specific regard to minerals policy 10: Railheads and Wharves. The Minerals Local Plan is being reviewed at present. It is envisaged, due to the requirement of the NPPF, that there will be a policy on Rail heads and Wharves in the Draft Minerals Local Plan.
The siting of the rail aggregate depot is shown within the county council's Mineral Consultation Area Supplementary Planning Document, adopted November 2007. The consultation area covers the majority of the Special Policy Area 2 Watford Junction. In accordance with the NPPF and Minerals Local Plan, in respect of minerals policy 10 the county council seeks to safeguard the rail aggregate depot which continues to serve as a sustainable mode of transporting minerals over long distances and the concrete batching facility which this site also supports. Given that the site is viable for use as a rail aggregate depot, its retention is expected unless the facility can be satisfactorily relocated within the development proposals in terms of operational requirements and environmental criteria or it has been or will be replaced in an alternative location.
The development brief identifies the rail aggregate depot as being a 'weakness' for the redevelopment of Watford junction in the SWOT analysis in paragraph 2.1. Minerals are important to the economy. Aggregate is needed to facilitate development and volumes of construction material being transported by rail in increasing. In light of this it could be considered that a rail aggregate depot in close proximity to the construction project could be considered to be a strength.
The issue of addressing such a 'weakness' is not however further expanded upon. It is clear from the illustrative masterplan that the retention of the rail aggregate depot is not part of the scheme. Whilst it is intended to be flexible enough to accommodate alternative layouts so long as it achieves the guiding principles and core ambitions of the masterplan, there does not appear to be sufficient scope to accommodate the existing or a relocated rail aggregate depot within the redevelopment area. As such this leaves the only option of relocating the rail aggregate depot offsite at another location along the railway line.
There is the need to establish an alternative well positioned strategic location for the rail aggregate depot to ensure its continued operation for imports and exports of minerals and secondary and recycled aggregates. The SWOT analysis in the development brief states that there is a 'weakness' in terms of a lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling. The Borough Council is referred back to paragraph 143 of the NPPF, the adopted Minerals Local Plan and specifically minerals policy 10 and the adopted Minerals Consultation Area SPD as detailed above in terms of the clarity for the safeguarding of the rail aggregates depot at Orphanage Road.
The brief states under the land use and quantum section of Station Quarter East within paragraph 3.4 that the development will be required to relocate the Rail Aggregates Depot within the local area, in consultation with Hertfordshire County Council and the operator of the site. The County Council will continue to work with the Borough Council in respect of this matter. The land use and quantum section in
paragraph 3.4 should also refer to the need to work with Network Rail with regard to the relocation of the Rail Aggregates Depot. The County Council understands that Network Rail Freight Management has been consulted and will provide comments to this consultation. There is however no further detail with regard a precise location having been secured.
To this end the relocation of the rail aggregate depot is fundamental to the delivery of the masterplan. A statement should be made in the delivery section of the brief at paragraph 4.1 specifically in relation to the requirement to ensure that the relocation of the rail aggregates depot forms part of the Watford Junction Delivery Plan.
Croxley View/Ascot Road Masterplanning Study
The Croxley View/Ascot Road Masterplanning Study has been considered by the county council as Waste Planning Authority due to the proximity of redevelopment to the Employment Land Area of Search (ELAS) 221 Watford Business Park.
The masterplan aims to build on the policy foundations of the district Local Plan Core Strategy Policy SPA6 to facilitate redevelopment. The location of potential residential development is shown within the Masterplanning Study to be directly adjacent to ELAS221 as designated within the county council's Waste Site Allocations document 2011-2026, adopted July 2014.
It is considered that ELAS that are predominantly used for general industry (B2) and storage and distribution (B8) are compatible with waste management uses. ELAS221 contains B1 and B2 uses and as such is acceptable in principle for a range of potential waste uses listed in the general waste brief during the 15 year plan period 2011-2026. Further planning guidance into the suitability of waste related development on the identified ELAS is within the ELAS Supplementary Planning Document, adopted November 2015. For this area, the Supplementary Planning Document states 'only enclosed waste transfer stations and materials recovery facilities that handle dry recyclables would be acceptable, along with enclosed inert waste recycling facilities. No other potential uses that may generate a leachate or liquor, which poses a risk to groundwater resources would be appropriate'.
The council does not wish to see the loss of identified ELAS for non-waste uses in order to safeguard it for future potential waste uses that may be sited in this location. Whilst the residential development would not directly encroach onto the ELAS, the council is mindful that the residential development is identified along the eastern boundary of the designated site and as a result there could be the potential for indirect impact upon the siting of waste uses within the ELAS.
The Waste Local Plan does not rely on the need for all land within ELAS across the county for the delivery of waste uses. However the cumulative loss of ELAS to non-waste uses is monitored and the safeguarding of remaining ELAS land is important to ensure there is a sufficient amount of land that could come forward for waste management facilities in the future, particularly with additional growth resulting in an increase in waste produced which needs to be managed.
There are currently no extant planning permissions on land directly adjacent to the masterplanned residential development to be aware of. The nearest waste site is the Household Waste Recycling Centre at Caxton Way in ELAS221. There is sufficient land remaining in ELAS221 to be brought forward for waste management uses.
The County Council does not wish to object to the masterplanning for potential residential development at this stage but reserves its right to object to future planning applications adjacent to the ELAS should a waste site be development in advance of residential. The reason for this would be to safeguard any waste use(s) under waste policy 5: Safeguarding of Sites within the Waste Core Strategy and Development Management Policies document 2011-2026, adopted November 2012. Further discussions would need to take place in the event that negative effects are identified that would restrict the waste operation to continue. A buffer between two land uses or mitigation measures in some cases may be appropriate to allow opposing land uses to exist in harmony adjacent to each other.
The County Council's adopted Waste Core Strategy and Development Management Policies document, does not stipulate a distance whereby other development in close proximity to a safeguarded waste site should be discouraged, the 2004 ODPM document: Planning for Waste Management Facilities: A Research Study states that for waste transfer stations: "sites closer than 250m from residential, commercial or recreational areas should be avoided." This guidance was used in the production of the Waste Site Allocations document. Depending upon the location of any potential future waste management facility within the ELAS, there is the potential that facilities may well be sited closer than the suggested 250m to any future housing.
Transport
Overarching/ general comments
Watford and the surrounding transport network face growing challenges as a result of the desired housing and economic growth in the area and increasing demand for travel. The County Council is developing a countywide transport model that will help all local authorities in the county to plan positively for growth and infrastructure investment in a way that safeguards the health and wellbeing of our communities and the environment. Already the model has identified notably worsening congestion issues in the Watford area as a result of planned growth. The next outputs of the enhanced Watford area version of the model will be available by the end of October 2016. The existing model is already available to Watford Borough Council to test development scenarios and proposals from the Local Plan.
In parallel with this, the County Council is developing a Growth & Transport Plan for South West Hertfordshire, which includes Watford and the surrounding towns and transport networks that make up a coherent area of travel demand. The Growth & Transport Plan will put forward packages of transport interventions to respond to strategic transport challenges and objectives for the area, derived through robust evidence analysis and engagement with stakeholders. Watford Borough Council officers and members have been involved from the early stages in GTP workshops
at key stages. The GTP is about identifying needs, planning for and enabling investment and delivery of a transport network and public realm that will support a healthy economy, environment and communities.
As a result of the current ongoing work being incomplete, at this stage there is insufficient evidence available to assess the implications of Local Plan Part 2 on the transportation network. As a consequence, there is uncertainty in relation to the mitigations that will be required to support the proposals and we remain in doubt that it potentially satisfies all soundness tests.
Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
Contents
'Appendix I - Site Allocations' is referred to later as 'Site Schedule'
'Appendix L' and 'Appendix M' missing from content list
Policy SD10
Refuse collection vehicles must be able to stop within the 'maximum refuse carry distance' specified by the Local Planning Authority or within 25m of any bin storage area, whichever is the lesser distance. Residents should not have to carry their rubbish more than 30m to a storage point. (Sources BS5906:2005 and Schedule 1 Part H Building Regulations)
Policy TLC14
On-street parking continues to need to be managed to manage congestion and avoid hazards, particularly at junctions.
Policy HS7
The subjective "undue pressure" on on-street parking should not lead to increased congestion and / or hazards on the highway network, particularly at junctions.
The siting of bin stores should not adversely impact on the operation of the highway network.
Policy HS8
The Highway Authority recommends that consideration of deliveries is made explicit in this policy.
6.9 and Policy EMP5
The County Council supports urban realm enhancement of Clarendon Road to encourage walking and cycling and improve the key pedestrian route between the town centre and Watford Junction.
Consideration should be given to amending the policy wording to explicitly include an expectation for development along Clarendon Road to contribute towards urban realm enhancements directly through works delivered or through developer contributions to fund such works.
Policy T6
The County Council is supportive of the zonal approach to car parking guidance to encourage lower car ownership and usage in more accessible zones. The principle of 'Car Lite' development in the most accessible areas, within 5 or so minutes' walk of a major transport hub, is also supported as long as the needs of disabled drivers and visitors are considered.
Lower car parking provision must be accompanied by appropriate restrictions in surrounding residential streets and any public car parks to prevent spill-over parking. In order for this approach to lowering car usage to be successful, there needs to be parallel investment in infrastructure (eg significantly better cycle and bus routes) and urban realm improvements to support and actively encourage alternative modes of travel.
The County Council welcomes the requirements for car club spaces in the SPAs and where parking does not meet the guidance.
Policy T8 and Appendix H
The policy on cycle parking provision and the stipulations relating to quality contained in the policy is welcomed. Adequate cycle storage must also be provided for existing and high predicted future levels.
A small change is recommended to allow for cycle parking provision for dwelling houses to be in a private garage as well as within the private garden area - subject to the dimensions of the garage being adequate to accommodate cycles as well as any vehicle.
However, the policy only specifies one long-term space per unit (regardless of size or location) where there is no garage or shed. In some instances such as within SPA2 and SPA6 where housing will be in the form of apartments and where there will be reduced car parking, it may be necessary for additional capacity for cycle storage beyond one space per unit, especially for larger flats or any flats without car parking provided.
Policy UD3
Structures abutting and overhanging the public highway will need the approval of the Highway Authority (HCC) as will illumination visible from the highway.
Policy TB1
From a transport network and user perspective, locations near to major passenger transport hubs, offering good interchange between different services and modes, are the most appropriate for denser development (i.e. taller buildings). However, development proposals should all be subject to Core Strategy policies T2-T5 to ensure that their impacts are understood and mitigated.
In order for such development to be acceptable, there must be adequate and appropriate improvements to transport infrastructure and urban realm within the site and in the wider area, to ensure no significant adverse impact on the highway and passenger transport networks, as a direct, indirect or cumulative result of development at the site and in the Borough as a whole.
Policy TB2
Suggest change to text at 8. Transport, parking and infrastructure:
'The design should detail a transport strategy for the proposed development to include how cycle parking, car parking, cycle permeability and pedestrian permeability have been integrated into the overall design. This should be based on a Transport Assessment and should avoid negative impacts on the public realm. The scheme will also need to demonstrate that the required infrastructure and utility capacity has been fully appraised.'
Appendix G
Parking bay dimensions only seem to consider residential element, parking bay at 2.4 x 4.8m is fine for standard bay but dimensions of other bays should be provided e.g. parallel arrangement. The garage dimensions provided are 3m x 5.5m whereas the industry standards are 3m x 6m (MfS para 8.3.41). Should minimum circulatory space for car parks be covered here (i.e. 6m) or will it be covered elsewhere?
SPA1
The ring road constrains pedestrian and cycle accessibility to the heart of the town centre. nb includes EMP5, R1, R2, R3, R4, R5. See Highway Authority comments in regard to each of these.
SPA2
Any development within the Watford Junction SPA should ensure that connectivity for pedestrians and cyclists is improved across the site, between the site and the town centre and on other key routes to Watford Junction Station.
Development of the station building, forecourt and car parks must address current limitations including capacity, access and circulation issues, for pedestrians, cyclists, buses, bus users, taxis, as well as users of the car parks. Opportunities to make Watford Junction an attractive and functional transport interchange that can accommodate future growth should be maximised.
See Highway Authority comments on Draft Development Brief (below).
SPA3
Good quality cycle and pedestrian links through the site and between the site and surrounding area and key destinations (town centre, Vicarage Road MLX station, local schools etc.) must be provided, or contributions to support infrastructure improvements in the wider area made through developer contributions.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
SPA4
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
Support improvements to green infrastructure and public realm as a complement to improvements to pedestrian and cycle links.
Flooding is a known issue affecting this area. Any development in this area should be designed to avoid and mitigate flood risk. Sustainable drainage approaches and green infrastructure should be used where appropriate to reduce and manage flood risk.
SPA5
Development at this location will need to consider transport impacts on the highway network, including operation of the Dome roundabout and St Albans Road notably at peak times. Also junctions including M25/A405/M1, and M1/A41.
There is a need to improve cycle, pedestrian and passenger transport connectivity to the site, and between the site and the town centre and Watford Junction.
It is recognised that the Abbey Line (North Watford) station is closer to the site, but there are limitations to this service at present which will reduce its attractiveness as an alternative to the car for journeys to Watford Junction or St Albans Abbey stations.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
There is a typo on second bullet point - should read 'improve air quality'.
SPA6
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Cycle improvements on Rickmansworth Road may be required as this is a key corridor between Rickmansworth and Watford.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
Secure, high quality cycle parking is needed at the proposed Cassiobridge station, as well as within the employment premises.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
See Highway Authority comments on Masterplanning Study (below)
MXD3
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
R1
It is agreed that robust pedestrian links with the town centre should form part of the new development at this location.
Good cycle access and high quality cycle parking also needs to be provided, for customers as well as employees.
R2
Agree that clear pedestrian connections between the site and the High Street are needed.
Good cycle access and cycle parking must also be provided.
There is a need to consider access needs to the site by different modes. A planned highway improvement scheme will make Clarendon Road one-way (NE-SW only) from Beechen Grove to High Street, with a contraflow cycle lane. Access to the street will be restricted by a Traffic Regulation Order to buses, taxis, cycles, 'blue badge' vehicles, and other vehicles 'for access only' to premises. All accessing vehicles will need to leave either via High Street or Watford House Lane (private road) for those accessing that area.
Development of this site should complement public realm enhancements proposed or already delivered on Clarendon Road and the High Street.
R3
Good cycle access and storage facilities must be provided, as well as good pedestrian links.
Developments at this location must take into account severance issues caused by the ring road for pedestrians and cyclists. Improvements required such as crossing improvements, new accesses into/through the site, should be delivered as part of the development or through developer contributions.
R4
Strong pedestrian and cycle links between this site and the town centre must be provided.
The quality of cycle routes and access to/from the west needs to be improved - eg. Market Street west of ring road and the Hornets Gyratory.
H1
This site is in close proximity to Bushey Station and includes its car park.
Opportunities to upgrade access to the station by non-car modes should be pursued.
Need to consider quantity and quality of cycle parking and cycle access to station from surrounding area.
Cycle access and cycle parking provision at Bushey station should be improved as part of any car parking replacement/improvement scheme.
Bushey Arches is a known congestion hotspot. Impacts of development on Bushey Arches must be considered and mitigation provided. This should include contributions to needed improvements to key walking and cycling routes and passenger transport infrastructure in the area.
H2
The ring road causes significant severance to people travelling by foot and cycle. Particular issues have been reported for people with visual impairments.
Improved cycle and pedestrian links to town centre and to Watford High Street and Watford Junction stations are needed from the site.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
H3
This site is about half mile from both the proposed Vicarage Road Met Line station and Watford High Street station, which is 10 to 12 minutes walking time.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
Vicarage Road is a busy road without dedicated cycle facilities. As such improvements to this route for cyclists should be considered. Developer contributions to improving cycle routes may be appropriate.
H5
The traffic impact on west Watford's road network needs to be considered and mitigated.
Cycle and pedestrian links into the site from different directions are required.
Adequate cycle storage must also be provided for existing and high predicted future levels.
Cycle infrastructure and the pedestrian environment of the surrounding area needs consideration.
H9
The impact of development at this site on the road network must be considered and mitigated if needed, including Rickmansworth Road and West Watford.
Good cycle links are needed including between the site, the town centre, and Ascot Road.
Bus services and infrastructure, including linking to new Cassiobridge Met Line station.
Bus services in this area may well be subject to change following the loss of the underground station. Development of this site and any forthcoming S106 contributions would provide the opportunity for an assessment to be made of potential improvements to bus services so this site remains connected to key destinations.
E1
High quality, secure cycle provision is needed at business premises.
Although the Ebury Way provides a good cycle route to the site, this will not be suitable for use all year round, at any time of day. As such improvements to the A412 corridor cycle infrastructure should be explored and provided. Developer contributions may be appropriate.
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
E2
Cycle and pedestrian routes through the site need improvement;
Via Watford Junction SPA site, there is a need to reduce severance and improve pedestrian and cycle connectivity to Watford Junction station and Clarendon Road.
WBC also needs to consider the implications of the Colonial Way Link road on development at site E2.
There is a need to consider potential transport implications of this site and the Watford Junction masterplan as a whole, including traffic accessing any new station multi-storey car parks, and the impact on the road network (eg. Colonial Way, Stephenson's Way, Radlett Road, Link Road, A41/M1 junction...).
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions.
E4
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions and on footways.
E5
Needs to link with SPA2 Watford Junction.
Development will need to assess impacts on road network and car parking demand in surrounding area.
Quality of pedestrian and cycle environment and urban realm on Clarendon Road should be considered and opportunities to enhance in consistent, coherent way should be explored to promote sustainable travel and improve route between town and Watford Junction.
Buildings will need to provide adequate, high quality secure cycle parking. If low car parking, may need to increase requirements or leave space to expand provision as required.
G6
Any change in land use/ status/ access provision to the south of Caxton Way and the south and east of Greenhill Crescent should not be permitted until its ability to provide the link for sustainable modes between Tolpits Lane and Caxton Way required by paragraph 10.6.9 of the WBC Core Strategy has been fully explored and ruled out.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF
1.1
The traffic and transport impacts of the masterplan scheme have not been modelled and thereby understood. The Highway Authority is, therefore, unable to fully support the plan until those impacts are assessed and deliverable mitigation measures agreed. HCC is developing traffic and transport models of Watford as part of its work to create a Growth & Transport Plan for the area. These will be used to test the impacts of the Watford Junction and other development proposals on transport infrastructure and services individually and cumulatively.
As part of earlier work on this site the County Council had required the construction of a road and bridge linking Colonial Way and St Albans Road via Penn Road. The scheme to build it received outline DfT funding and included a passenger transport (coach) interchange on the northeast side of the station. If the link road and bridge are no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
1.2
Correct reference to 'Abbey Link' in map to 'Abbey Line'.
2.1
The Barriers plan acknowledges the severance created by the presence of the Abbey Line. As part of earlier work on this site the County Council had required the construction of a road over the Abbey Line linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.2
Policy T1 in the borough council's Core Strategy supports conversion of the Abbey Line from heavy to light rail operation.
Correct reference to 'Abbey Flyover' in Objectives to 'Abbey Line'.
2.3
Correct reference to 'Abbey train line' under Transport and Parking to 'Abbey Line'.
As part of earlier work on this site the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.4
Gross External Areas values are different to those in 5.1 Area Schedules.
3D views might benefit from road names for orientation.
2.7
As part of earlier work on this site, the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
It is recommended that all roads are usable by cycles to aid permeability.
The road hierarchy titles have different meanings in the Highway Authority's own existing hierarchy. As the design is refined it is recommended that confusion is avoided by using different names.
2.8
The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.
3.3
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
3.4
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
4.1
The County Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order that they can be considered in the emerging Watford Growth & Transport Plan. Joint working with the County Council will remain key in order to maximise access to appropriate funding streams and delivery programmes.
Special Policy Area 2 is zero-CIL-rated so that all planning obligations will be derived via Section 106 agreements with service providers.
4.2
An overall Travel Plan for the site will be required and one for each subsequent development area should be provided and agreed.
5.1
Total car parking number differs from that given in 2.4 and Station Quarter East breakdown (p 46).
Gross External Areas values are different to those in 2.4.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF VIABILITY APPRAISAL
4.2
The County Council is concerned about the unrealistically low estimates given in figure 4.1 for the costings of infrastructure required to mitigate the impact of the masterplan.
CROXLEY VIEW/ ASCOT ROAD STUDY
Introduction
Mention must be made of the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The need for a link both for Watford and Three Rivers grows as pressure to develop either side of the Ebury Way increases and its delivery should be seen as key to both authorities' Duty to Cooperate.
Plans
All plans refer to Watford County Council.
All plans show Croxley Green Business Park to the southwest of the masterplan area. This is correctly the Wolsey Business Park.
Most plans show the Grand Union Canal badged as the River Gade which runs to the south and east of it.
Some plans do not show the correct alignment of the Watford/ Three Rivers boundary.
Some plans erroneously label the NE corner of Croxley Common as Cassiobury Park Nature Reserve.
Masterplanning Strategy plan - asterisks and other labelling are not described and inconsistently applied.
Potential Development Sites plan
This omits to include the Tech Site (around Woodshots Meadow). This is subject to preapplication discussions now and should be considered with the adjacent sites as it is in Employment Policy Area E1 (Local Plan Part 2 appendix 1).
Proposed Vehicle and Pedestrian Movement plan
This omits the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The route currently being explored follows the cycle track between the Watford Enterprise Centre and number 27 Greenhill Crescent.
Historic environment, landscape and ecology
The County Council supports the overall policy intentions of the Local Plan covering landscape, ecology and the historic and built environment and provides the following comments to help strengthen these policies and their supplementary text.
Historic Environment
Development Management Policies
The County Council welcomes the Borough's consideration of the Historic Environment in Part 9 Urban Design and the Historic Environment. However, the historic environment should be referenced in line with the NPPF definition of heritage assets. In addition to historic buildings (both designated and undesignated), the historic environment of Watford includes archaeological remains, historic landscapes and historic parks. Therefore policies are needed to conserve the historic environment as whole, not just designated buildings, registered gardens and conservation areas as is currently stated.
Under Policy UD4, Archaeology, there appears to be repetition of the NPPF, the policy is unclear and should be re-written.
There is also reference to the conservation of heritage assets being secured by an archaeological Written Scheme of Investigation (WSI). Whilst the County Council welcomes the requirement for these documents and for them to include provision for publication and public dissemination of results where appropriate (NPPF 141), it is not clear if the WSI on its own is considered to be robust enough to secure appropriate conservation of the historic environment. Therefore it is unclear if this part too, is effective.
Watford Junction Draft Development Brief 2016
Paragraph 4.2 notes that a Heritage Statement and Desktop Archaeological Study may need to be submitted with any planning applications. However, it is unclear what is meant by a Heritage Statement. Also archaeological assessment may not be limited to a desktop study.
Site Allocations
An appraisal of the archaeological implications of development for the new areas identified in the Second Consultation document (2016) is summarised below.
1. Archaeology as a Development Constraint
N/A
2. Requirement for Pre-allocation Archaeological Assessment
The sites below have known archaeological remains within them or have significant archaeological potential by reason of their size and situation, such that there is a risk that archaeology could be a constraint on any development. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that archaeological assessments should be included within all development briefs and other proposals for the sites, before they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the sites, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent of archaeological remains that might be a constraint upon the principle of development of these sites.
Allocation numbers: SPA1, SPA4 and H9.
3. Requirement for Pre-application or Pre-determination Archaeological Assessment
The sites below have known archaeological remains within them or have archaeological potential. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that that pre-application or pre-determination archaeological assessments should be included within all development briefs and other proposals for the sites, if they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the proposals, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent
of archaeological remains worthy of preservation in situ, to enable the LPA to determine any specific application for development.
Allocation numbers: SPA 2, SPA3, SPA5, SPA6, MXD1, MXD3, R1, R2, R3, R4, H2, H3, H4, H 10, E1, E2, E3, E4, E5, E6.
4. Mitigation of archaeological impact by condition
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, any archaeological issues can probably be dealt with by condition, should planning permission be granted.
Allocation numbers: R5, CF1, H1, H5, H6, GT1.
5. No archaeological requirements
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, there are unlikely to be any archaeological implications. However this will depend on the details of any proposals and any new archaeological information.
Allocation numbers: MXD2, MXD4, H7, H8, H11.
Ecology
Development Management Policies
Policy SD15, External lighting, the County Council support the provisions set out in this policy and advise that there should be reference to the guidance provided by the Institute of Lighting Engineers which has been instrumental in seeking to reduce the impacts of artificial lighting within the environment.
Green Infrastructure, Biodiversity and Recreation, the County Council supports the reference to Green Infrastructure (GI).In defining GI there should also be reference to the provision of local food production as a key ecosystem service.
Policy G15, Trees, Woodlands and Hedgerows, this policy is supported in respect of highlighting ecological and cultural value of trees, woodlands and hedgerows. However, under paragraph 10.3, the reference to valuable habitats should be extended to include reference to ecological networks and corridors. Under paragraph 10.6 it should be clarified that replacing trees lost to development cannot compensate for the loss of biodiversity or amenity value in the short term.
Policy GI6, Protecting and Enhancing the Grand Union Canal, this policy is supported including the reference to enhancing biodiversity under paragraph 10.11. It is advised that the policy is extended to include a clause that seeks to improve the biodiversity of the canal corridor where possible. Development that would have an
adverse impact on the biodiversity of the canal would not be supported unless it can demonstrate provision of suitable mitigation or compensation.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, this policy is supported however recommend the following clarifications and amendments.
It is advised to make reference to the 'amenity value' of the river, specifically encouraging 'recreation' may increase disturbance to sensitive wildlife within river corridors. The term 'amenity' embraces visual and recreational importance without being too prescriptive or disruptive if more sensitive habitats or locations are affected an important consideration within this largely urban area.
With regards the provision of 'a corridor for wildlife and biodiversity,' the reference to biodiversity should be deleted as wildlife is biodiversity. With regards replacement structures and fish passage, liaison with the Environment Agency is essential if any such works are proposed. With regards access it should be designed in a way that also enables some undisturbed areas to be retained.
Policy GI9, Provision of Open Space and Play Space in Residential Development, aspects of this policy relevant to biodiversity are supported. The reference to green space typologies should be expanded to include allotments and community orchards, in order to reflect the types of functional sites which support both community and biodiversity benefits.
Biodiversity, it is not clear why this section is formatted differently to the preceding and subsequent sections. In particular it does not describe 'Why is this policy needed?' and 'what is it intended to do?' In setting out the need for the policy, it should reference the legislative requirements of statutorily protected sites and species which are a material consideration in planning, as well as the Duty placed on Local Authorities to have regard to conserving biodiversity in all of their functions as set out in the Natural Environment and rural Communities Act 2006. In setting out the intention of the policy there should also be reference to seeking to deliver the aims of the Local Nature Partnership - for which securing ecological resources, functions and services are a consideration when determining planning applications.
Under paragraph 10.37 the reference to the 'Biodiversity Plan' should be amended to reference to the 'Biodiversity Action Plan principles' (BAP). The BAP, nationally and locally, has ceased to be actively supported by National and Local Government, and has essentially been replaced by the Local Nature Partnership. However the principles underpinning it remain valid as statements and the intentions of the various habitat and species action plans are sound in themselves and could be followed if resources or interest permitted.
It is suggested that the statement under paragraph 10.39 should be amended as follows:
'This policy expects that where appropriate, development proposals will demonstrate the relative ecological value of a site before and after development. Proposals should follow the mitigation hierarchy and provide clear evidence of impacts and enhancements where appropriate, consistent with the aims of NPPF, BS42020
"Biodiversity - Code of Practice for Planning and Development'' and guidance provided by CIEEM. This will require sufficient detail and clarity to enable net losses and gains to be identified and monitored, consistent with the Code. Where unavoidable, Biodiversity Offsetting should be considered as a means to ensure there is no net loss of biodiversity resulting from development'.
Highlighting the specific use of Biodiversity Calculators such as the one mentioned in paragraph 10.39 can be a little misleading. BS42020 does not mention the use of biodiversity calculators, and taken out of context the results of such calculations can sometimes show net gains where there should be none (removal of ancient woodland for example cannot reasonably be compensated in the real world). Other wider landscape issues are also not always considered by these calculators; if the land is part of a wider corridor, or a biodiversity network for example. It has taken several years for Warwickshire County Council to incorporate their use in to the planning system and there is still not universal agreement on them.
The County Council would therefore advise caution on their avocation, but rather emphasise the need to prove that biodiversity has not been lost and in the most part enhanced through "appropriate methods in-line with BS42020".
Policy GI10 Managing Biodiversity in new Developments. The County Council supports Watford Borough Council's commitment to increasing biodiversity within the district. The Policy is consistent with other Hertfordshire Local Authorities, and in-line with the National Planning Policy Framework.
The following amendments are advised. There should be reference to avoiding negative impacts upon ' local ecological networks...,'as each site sits within a local environmental and should retain or enhance any existing ecological resources or corridors to and from adjacent sites.
'Compensation will only be considered as a last resort. Development proposals will be expected to evaluate the impact on local biodiversity where appropriate and propose measures to maintain and enhance biodiversity. This approach should follow the principles outlined within BS42020 "Biodiversity - Code of Practice for Planning and Development" or other measures of best practice, including Biodiversity Offsetting where necessary'.
The above wording embraces the mitigation hierarchy as well as defining means to achieve no net loss as sought by NPPF, without being too prescriptive.
It is considered that paragraph 10.40 regarding the biodiversity calculator is not needed if references requiring its specific use are otherwise removed. The County Council remain concerned that some caution needs to be taken regarding the generation of positive scores which indicate a net gain despite losses that may otherwise be considered unacceptable.
Site Allocations
Please refer to Appendix 1.
Landscape
Green Infrastructure, Biodiversity and Recreation, the policy framework for green infrastructure (GI) was significantly strengthened in Feb 2016 with the introduction of detailed Planning Policy Guidance. The guidance states that GI is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water and should be a key consideration in both local plans and planning decisions.
The Herts Landscape and Green Infrastructure Group is currently looking at GI delivery and practice across Hertfordshire with a view to presenting a project proposal to Herts Infrastructure Planning Partnership (HIPP) in November. The key aim of the project is to mainstream the delivery of GI through the local plan and development management processes. The outputs and deliverables of the project are currently being shaped and should help provide local planning authorities with a good practice approach to GI delivery, supported by robust evidence and case studies.
The Landscape Institute Position Statement for Green Infrastructure provides a widely supported definition of GI (assets and functions) and a comprehensive overview of the key benefits it can deliver, supported by case studies http://www.landscapeinstitute.org/policy/GreenInfrastructure.php
There is no reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans. (The strategies provide an opportunity to address cross boundary issues and meet the Duty to Cooperate. (Hertfordshire and GreenArc Area Strategic Highlights Plan (SHiP) and the All London Green Grid.)
There should be greater emphasis on GI in place-making and conserving and enhancing local distinctiveness. There should be reference to any local character assessments and the guidelines for managing change that should help shape proposals, and conserve and enhance local character.
At a national level there is also the National Character Areas produced by Natural England https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making, and at a regional level there is the East of England Landscape Framework http://landscape-east.org.uk/.
Where proposals are likely to result in landscape and visual effects a landscape and visual impact assessment, in line with industry good practice guidance (Landscape and Visual Impact Assessment third edition Landscape Institute and Institute for Environmental Management and Assessment) may be required as part of an application. The mitigation hierarchy should be referenced to ensure that proposals seek to avoid and minimise any negative effects.
The reference to Green Infrastructure under paragraph 10.1, is fully supported, however it is suggested to expand the definition to include reference to blue assets
such as the Grand Union Canal. Also suggest amend reference to 'mitigating climate change' to 'mitigating the effects of climate change.'
Under paragraph 10.3, it should be clear that biodiversity is not the only driver for Green Infrastructure; other key drivers include a single or multiple land-use functions and include waste/water management, recreation, food production, local distinctiveness etc.
Policy GI5, Trees, Woodlands and Hedgerows, the reference to the protection of trees in line with current British Standard Institute code of practice is fully supported, however the full title of the standard does not appear to be referenced and should be 'Trees in relation to design, demolition and construction' (BS5837:2012). In addition it is advised that where required by the planning authority, tree surveys, arboricultural impact assessments and method statements should all be carried out in compliance with this standard.
The policy should be expanded to include reference to the current hedgerow regulations, the provision of a landscape strategy, planting plans and specifications, and the provision of aftercare (long term management plans) and replacement of failures.
Policy GI6, Protecting and Enhancing the Grand Union Canal, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Yours sincerely,
Paul Donovan
Environment Department
Hertfordshire County Council
APPENDIX 1
Please find below a brief ecological assessment of the site allocations. A 'standard' template for each Site has been provided.
Ecosites do not have any form of status of importance, but are merely sites that we have some ecological information on - thus they do support some wildlife interest, at least at a local level. Whilst these sites are often a valuable starting point in identifying the county's wildlife resource, they do not meet the rigorous and quantifiable assessment criteria needed to identify them as non-statutory Local (County) Wildlife Sites.
SPA1 Town Centre
Recognised sites adjacent / close to Site: close to eastern end of Cassiobury Park Local Wildlife Site.
Other features: Little semi natural habitat present, possibly some mature trees.
Protected species: Probably bats, badger records to the west.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road)
Protected species: Unknown - no records
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA3 Health Campus (includes a Borough Council Depot and Waste Transfer Station at Wiggenhall Road)
Recognised nature sites within Site: The Lairage Land Local Wildlife Site (LWS) and Local Nature Reserve (LNR), Croxley Green Junction Sidings LWS, Oxhey Park River & Margins LWS; Riverside Road Waste Ground ecosite (local database site), The Island, off Cardiff Road ecosite, Oxhey Park ecosite
Recognised sites adjacent / close to Site: Horwoods Avenue Playground ecosite, Moor View ecosite, Cardiff Road Embankment ecosite.
Other features: includes village green - "Green situated between Riverside Road & the River Colne"
Protected species: Birds and Water voles.
Opportunities: High. Habitat management to maintain and enhance biodiversity interest, green infrastructure / corridors.
Ecological sensitivity: Medium to high depending on location.
Fundamental ecological constraint: Presumption to avoid development on Local Wildlife Sites, fragmentation of green corridor,
Loss of Farm Terrace allotment site - should be offset elsewhere as open space / community food growing / ecological resource.
SPA4 Lower High Street
Recognised sites adjacent / close to Site: Bushey Hall Farm ecosite, Oxhey Park ecosite.
Other features: "Recreation Allotments" village green.
Protected species: Unknown - no records. Birds in trees.
Opportunities: Limited as previously developed site. Potential green corridors along railways lines.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA5 Dome Roundabout (includes a Waste Transfer Station at Colne Way)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA6 Western Gateway (includes area of search ELAS221 in the Hertfordshire Waste Site Allocations Document)
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite, Ascot Road ecosite.
Recognised sites adjacent / close to Site: close to eastern end of Croxley Common Moor Site of Specific Scienttific Interest (SSSI) and LNR.
Other features: Grassland strip along eastern boundary with bordering trees.
Protected species: Unknown - no records.
Opportunities: Enhance green infrastructure corridor along eastern boundary.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds in trees.
The ecosites have largely been destroyed by development.
MXD1 North Watford library, Lemarie Centre for Charities, and health facilities (within SPA5)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
MXD2 The Brow
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
MXD3 Gas holder site (within SPA4)
Other features: River Colne borders the eastern boundary.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site. Potential to enhance the river margins as a green corridor.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in the trees.
Largely developed but riverside trees most important and scrub on site.
MXD4 Ascot Road
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite.
Other features: As well as the rough ground and bordering trees of the area to the west, the Site includes part of the school playing fields to the east, which is short mown amenity grassland. There are also some mature trees.
Protected species: Unknown - no records.
Opportunities: Potential enhancement of the areas of semi-natural habitat to improve green corridor connectivity.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds. Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R1 Sainsbury's and adjoining land
Other features: The north-eastern part of the Site includes an area of grassland and mature trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R2 Former TJ Hughes and adjoining land
Other features: Small area of amenity grassland on the north-eastern side.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R3 BT Telephone Exchange and adjoining Wellstones
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R4 Church Street Car Park and land fronting Market Street/Market Place
Other features: area of amenity grassland and scattered trees on the southern side.
Protected species: Unknown - no records.
Opportunities: Limited as predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R5 Charter Place centre and adjoining land onto the High Street
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
CF1 Community Facility Tolpits Lane.
Other features: Site appears to be rough grassland with scattered scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to enhance the habitats on site. The northern boundary is a wooded bank bordering the railway line. Maintain / enhance green corridor along railway.
Ecological sensitivity: Low - medium as semi-natural habitats on site.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H1 Land at Pinner Road
Other features: There are small areas of rough (possibly amenity) grassland with scrub and scattered trees.
Protected species: Unknown - no records.
Opportunities: Limited as a predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H2 Skatepark, Lower Derby Road
Other features: There is an area of grassland with trees in the north-west corner.
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a predominantly a previously developed site. Potential to maintain / enhance the semi-natural habitats on site for green corridor links to nearby habitats, river corridor and wooded railway banks.
Ecological sensitivity:
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H3 Vicarage Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H4 Telephone Exchange - First Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H5 Builder's Yard, Queens Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H6 Bill Everett Community Centre
Recognised sites adjacent / close to Site: adjacent to Long Spring and Harebreaks Wood (Watford) Local Wildlife Site and Local Nature Reserve.
Other features: some areas of grassland (probably amenity?) and occasional scattered trees.
Protected species: Bat roost in building nearby.
Opportunities: Potential to link woodland to the south to area to the north - depending on what the latter is like, as it appears to be bare ground on our aerial photographs.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H7 Rickmansworth Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H8 Garages- The Gossamers
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H9 Watford Station, Cassiobury Park Avenue
Recognised nature sites within Site: Cassiobury Park Avenue allotments ecosite.
Recognised sites adjacent / close to Site: close to "Gade Avenue" Local Wildlife Site.
Other features: Includes an area of allotment gardens and mature trees.
Protected species: Unknown - no records. Potential for bats and reptiles.
Opportunities: Maintain and enhance the green corridor link along the railway line.
Ecological sensitivity: Low - medium?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H10 Croxley View
Other features: Area of semi-natural grassland with scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to manage the existing habitats to maintain / improve biodiversity. Maintain as a green infrastructure link from open grasslands to the south towards the River Gade corridor and semi-natural habitats to the north
Ecological sensitivity: Low.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H11 Garages, Bowmans Green
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
GT1 Lands at Tolpits Lane
Other features: Area of rough grassland with bordering trees.
Protected species: Unknown - no records.
Opportunities: Limited, but part of semi-natural grassland complex in the area so potential for linking hedgerows. Any loss of grassland could be compensated for by enhancement elsewhere and landscaping may provide additional buffering habitats locally if this site were to be developed as such.
Ecological sensitivity: Low?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
E1 Watford Business
Recognised sites adjacent / close to Site: adjacent to Croxley Common Moor Site of Special Scientific Interest (SSSI and Local Nature Reserve (LNR) and Commonland; adjacent to Ascot Road Car Park and Waste ecosite, adjacent to Ascot Road ecosite; close to Ascot Road Scrub Local Wildlife Site.
Other features: Some areas with trees.
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
Part of the edge of this currently provides a valuable buffer and boundary edge to Croxley Common Moor SSSI and LNR. We would object to any development which further degraded this boundary habitat, although much of the former area has already been lost to hard surfacing.
E2 Imperial Way / Colonial
Protected species: Limited as a previously developed site.
Opportunities: Low.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E3 Fishers
Recognised nature sites within Site: Cardiff Road Embankment ecosite.
Recognised sites adjacent / close to Site: adjacent to Croxley Green Junction Sidings Local Wildlife Site.
Other features: Disused railway line to the west is bordered by woody vegetation.
Protected species: Unknown - no records.
Opportunities: Potential green corridors east / west across the site and along the western boundary. Maintain a buffer against LWS to the south.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
E4 Greycaine Road / Odhams / Sandown Road
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E5 Clarendon Road / Station Road / Bridle Path Office Area
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E6 Leavesden Studios - the Island site
Recognised nature sites within Site: part of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Recognised sites adjacent / close to Site: adjacent to the rest of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Other features: Semi-improved grassland habitat, part of a much larger complex.
Protected species: Badger setts on site and nearby.
Opportunities: Linking habitats to similar adjacent grasslands.
Ecological sensitivity: Low - medium.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species, with particular attention to badgers

Object

Watford Junction Draft Development Brief 2016

Representation ID: 853

Received: 03/10/2016

Respondent: Hertfordshire County Council SLU

Representation Summary:

The traffic and transport impacts of the masterplan scheme have been modelled and thereby understood and HCC are unable to fully support.

Full text:

Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
With regard to Policy SPMX1: Special Policy Areas, the council is pleased to see the insertion of reference to the county council's documents. The text should however refer to the' Waste Local Plan' which includes both the Waste Core Strategy and Development Management Policies document and the Waste Site Allocations document.
With regard to Special Policy Area 2: Watford Junction, the council is pleased to see that there is reference to the need to safeguard the rail aggregates depot at Orphanage Road.
Further information on SPA2 is contained in Appendix I: Site Schedules of the Local Plan Part 2. The council is pleased that the rail aggregates depot is included as a
Spatial Planning and the Economy
Environment Department
Hertfordshire County Council
County Hall
Hertford
Hertfordshire
SG13 8DN
paul.donovan@hertfordshire.gov.uk
01992 556289
Planning Policy Team,
Room 65,
Watford Borough Council,
Town Hall,
Watford,
Herts,
WD17 3EX.
development consideration where it states 'This will need to be retained, or a new comparable facility provided within the local area'. However it should be noted that the text should refer to the 'rail aggregates depot' as opposed to the 'waste aggregates depot'.
However, in practice, taken together with the masterplan and accompanying viability report, there appears to be a strong likelihood that the rail aggregates depot is not to be retained on site and the collective impact of the Local Plan is not to safeguard the rail aggregates depot. Given this, the Inspector may well wish to see what evidence exists with regard to securing a replacement facility and currently no such evidence accompanies the Local Plan. As a consequence, there is considerable uncertainty in relation to whether the Local Plan satisfies potentially all soundness tests.
With regard to SPA6 Western Gateway, this includes ELAS221 and it is also worth pointing out that the areas designated as PS2 and PS3 potential in the Croxley View/Ascot Road Masterplanning Study are also located in ELAS221.
It is agreed that it is useful to insert text in relation to the circular economy as part of the waste section under paragraph 3.30, supporting text to Policy SD10: Waste. The second bullet point should state 'drive greater resource productivity.'
The relevant policy basis has been applied in the waste section and the Watford Local Plan with regard to responsibility for waste management. Whilst there appears to no longer be specific reference to Waste Policy 12, there is text to cover the use of this policy along with others within the Waste Core Strategy and Development Management Polices document. One comment to make is that in the wider context of the Watford Local Plan with there also being reference to ELAS221, the text in paragraph 3.30 should refer to the Waste Local Plan, which covers policies within the Waste Core Strategy and Development Management Policies document, adopted November 2012 and the Waste Site Allocations document, adopted July 2014.
Watford Junction Development Brief
As previously stated, most recently in respect of the Infrastructure Delivery Plan, the key matter of concern to the Minerals and Waste Planning Authority is the impact that any proposed development may have upon the safeguarded rail aggregate depot located at Orphanage Road, Watford which is a current operational facility.
The planning policy status, as detailed within the introduction of the brief, refers to consideration being had to national planning policy and the Watford Borough Council Local Plan. To ensure that the Development Plan has been considered as a whole the brief needs to also refer to the Minerals Local Plan and the Waste Local Plan. In terms of national policy, there is the need to ensure that the NPPF is considered in respect of para 143 which states that Mineral Planning Authorities should safeguard existing, planned and potential rail heads, so as to prevent their redevelopment for other uses and loss of the mineral infrastructure. This safeguarding is also applicable to storage, handling and processing facilities associated with them.
It is considered that due to the location of the rail aggregate depot within the development brief area that the county council's Minerals Local Plan 2002-2016, adopted March 2007 is also considered with specific regard to minerals policy 10: Railheads and Wharves. The Minerals Local Plan is being reviewed at present. It is envisaged, due to the requirement of the NPPF, that there will be a policy on Rail heads and Wharves in the Draft Minerals Local Plan.
The siting of the rail aggregate depot is shown within the county council's Mineral Consultation Area Supplementary Planning Document, adopted November 2007. The consultation area covers the majority of the Special Policy Area 2 Watford Junction. In accordance with the NPPF and Minerals Local Plan, in respect of minerals policy 10 the county council seeks to safeguard the rail aggregate depot which continues to serve as a sustainable mode of transporting minerals over long distances and the concrete batching facility which this site also supports. Given that the site is viable for use as a rail aggregate depot, its retention is expected unless the facility can be satisfactorily relocated within the development proposals in terms of operational requirements and environmental criteria or it has been or will be replaced in an alternative location.
The development brief identifies the rail aggregate depot as being a 'weakness' for the redevelopment of Watford junction in the SWOT analysis in paragraph 2.1. Minerals are important to the economy. Aggregate is needed to facilitate development and volumes of construction material being transported by rail in increasing. In light of this it could be considered that a rail aggregate depot in close proximity to the construction project could be considered to be a strength.
The issue of addressing such a 'weakness' is not however further expanded upon. It is clear from the illustrative masterplan that the retention of the rail aggregate depot is not part of the scheme. Whilst it is intended to be flexible enough to accommodate alternative layouts so long as it achieves the guiding principles and core ambitions of the masterplan, there does not appear to be sufficient scope to accommodate the existing or a relocated rail aggregate depot within the redevelopment area. As such this leaves the only option of relocating the rail aggregate depot offsite at another location along the railway line.
There is the need to establish an alternative well positioned strategic location for the rail aggregate depot to ensure its continued operation for imports and exports of minerals and secondary and recycled aggregates. The SWOT analysis in the development brief states that there is a 'weakness' in terms of a lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling. The Borough Council is referred back to paragraph 143 of the NPPF, the adopted Minerals Local Plan and specifically minerals policy 10 and the adopted Minerals Consultation Area SPD as detailed above in terms of the clarity for the safeguarding of the rail aggregates depot at Orphanage Road.
The brief states under the land use and quantum section of Station Quarter East within paragraph 3.4 that the development will be required to relocate the Rail Aggregates Depot within the local area, in consultation with Hertfordshire County Council and the operator of the site. The County Council will continue to work with the Borough Council in respect of this matter. The land use and quantum section in
paragraph 3.4 should also refer to the need to work with Network Rail with regard to the relocation of the Rail Aggregates Depot. The County Council understands that Network Rail Freight Management has been consulted and will provide comments to this consultation. There is however no further detail with regard a precise location having been secured.
To this end the relocation of the rail aggregate depot is fundamental to the delivery of the masterplan. A statement should be made in the delivery section of the brief at paragraph 4.1 specifically in relation to the requirement to ensure that the relocation of the rail aggregates depot forms part of the Watford Junction Delivery Plan.
Croxley View/Ascot Road Masterplanning Study
The Croxley View/Ascot Road Masterplanning Study has been considered by the county council as Waste Planning Authority due to the proximity of redevelopment to the Employment Land Area of Search (ELAS) 221 Watford Business Park.
The masterplan aims to build on the policy foundations of the district Local Plan Core Strategy Policy SPA6 to facilitate redevelopment. The location of potential residential development is shown within the Masterplanning Study to be directly adjacent to ELAS221 as designated within the county council's Waste Site Allocations document 2011-2026, adopted July 2014.
It is considered that ELAS that are predominantly used for general industry (B2) and storage and distribution (B8) are compatible with waste management uses. ELAS221 contains B1 and B2 uses and as such is acceptable in principle for a range of potential waste uses listed in the general waste brief during the 15 year plan period 2011-2026. Further planning guidance into the suitability of waste related development on the identified ELAS is within the ELAS Supplementary Planning Document, adopted November 2015. For this area, the Supplementary Planning Document states 'only enclosed waste transfer stations and materials recovery facilities that handle dry recyclables would be acceptable, along with enclosed inert waste recycling facilities. No other potential uses that may generate a leachate or liquor, which poses a risk to groundwater resources would be appropriate'.
The council does not wish to see the loss of identified ELAS for non-waste uses in order to safeguard it for future potential waste uses that may be sited in this location. Whilst the residential development would not directly encroach onto the ELAS, the council is mindful that the residential development is identified along the eastern boundary of the designated site and as a result there could be the potential for indirect impact upon the siting of waste uses within the ELAS.
The Waste Local Plan does not rely on the need for all land within ELAS across the county for the delivery of waste uses. However the cumulative loss of ELAS to non-waste uses is monitored and the safeguarding of remaining ELAS land is important to ensure there is a sufficient amount of land that could come forward for waste management facilities in the future, particularly with additional growth resulting in an increase in waste produced which needs to be managed.
There are currently no extant planning permissions on land directly adjacent to the masterplanned residential development to be aware of. The nearest waste site is the Household Waste Recycling Centre at Caxton Way in ELAS221. There is sufficient land remaining in ELAS221 to be brought forward for waste management uses.
The County Council does not wish to object to the masterplanning for potential residential development at this stage but reserves its right to object to future planning applications adjacent to the ELAS should a waste site be development in advance of residential. The reason for this would be to safeguard any waste use(s) under waste policy 5: Safeguarding of Sites within the Waste Core Strategy and Development Management Policies document 2011-2026, adopted November 2012. Further discussions would need to take place in the event that negative effects are identified that would restrict the waste operation to continue. A buffer between two land uses or mitigation measures in some cases may be appropriate to allow opposing land uses to exist in harmony adjacent to each other.
The County Council's adopted Waste Core Strategy and Development Management Policies document, does not stipulate a distance whereby other development in close proximity to a safeguarded waste site should be discouraged, the 2004 ODPM document: Planning for Waste Management Facilities: A Research Study states that for waste transfer stations: "sites closer than 250m from residential, commercial or recreational areas should be avoided." This guidance was used in the production of the Waste Site Allocations document. Depending upon the location of any potential future waste management facility within the ELAS, there is the potential that facilities may well be sited closer than the suggested 250m to any future housing.
Transport
Overarching/ general comments
Watford and the surrounding transport network face growing challenges as a result of the desired housing and economic growth in the area and increasing demand for travel. The County Council is developing a countywide transport model that will help all local authorities in the county to plan positively for growth and infrastructure investment in a way that safeguards the health and wellbeing of our communities and the environment. Already the model has identified notably worsening congestion issues in the Watford area as a result of planned growth. The next outputs of the enhanced Watford area version of the model will be available by the end of October 2016. The existing model is already available to Watford Borough Council to test development scenarios and proposals from the Local Plan.
In parallel with this, the County Council is developing a Growth & Transport Plan for South West Hertfordshire, which includes Watford and the surrounding towns and transport networks that make up a coherent area of travel demand. The Growth & Transport Plan will put forward packages of transport interventions to respond to strategic transport challenges and objectives for the area, derived through robust evidence analysis and engagement with stakeholders. Watford Borough Council officers and members have been involved from the early stages in GTP workshops
at key stages. The GTP is about identifying needs, planning for and enabling investment and delivery of a transport network and public realm that will support a healthy economy, environment and communities.
As a result of the current ongoing work being incomplete, at this stage there is insufficient evidence available to assess the implications of Local Plan Part 2 on the transportation network. As a consequence, there is uncertainty in relation to the mitigations that will be required to support the proposals and we remain in doubt that it potentially satisfies all soundness tests.
Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
Contents
'Appendix I - Site Allocations' is referred to later as 'Site Schedule'
'Appendix L' and 'Appendix M' missing from content list
Policy SD10
Refuse collection vehicles must be able to stop within the 'maximum refuse carry distance' specified by the Local Planning Authority or within 25m of any bin storage area, whichever is the lesser distance. Residents should not have to carry their rubbish more than 30m to a storage point. (Sources BS5906:2005 and Schedule 1 Part H Building Regulations)
Policy TLC14
On-street parking continues to need to be managed to manage congestion and avoid hazards, particularly at junctions.
Policy HS7
The subjective "undue pressure" on on-street parking should not lead to increased congestion and / or hazards on the highway network, particularly at junctions.
The siting of bin stores should not adversely impact on the operation of the highway network.
Policy HS8
The Highway Authority recommends that consideration of deliveries is made explicit in this policy.
6.9 and Policy EMP5
The County Council supports urban realm enhancement of Clarendon Road to encourage walking and cycling and improve the key pedestrian route between the town centre and Watford Junction.
Consideration should be given to amending the policy wording to explicitly include an expectation for development along Clarendon Road to contribute towards urban realm enhancements directly through works delivered or through developer contributions to fund such works.
Policy T6
The County Council is supportive of the zonal approach to car parking guidance to encourage lower car ownership and usage in more accessible zones. The principle of 'Car Lite' development in the most accessible areas, within 5 or so minutes' walk of a major transport hub, is also supported as long as the needs of disabled drivers and visitors are considered.
Lower car parking provision must be accompanied by appropriate restrictions in surrounding residential streets and any public car parks to prevent spill-over parking. In order for this approach to lowering car usage to be successful, there needs to be parallel investment in infrastructure (eg significantly better cycle and bus routes) and urban realm improvements to support and actively encourage alternative modes of travel.
The County Council welcomes the requirements for car club spaces in the SPAs and where parking does not meet the guidance.
Policy T8 and Appendix H
The policy on cycle parking provision and the stipulations relating to quality contained in the policy is welcomed. Adequate cycle storage must also be provided for existing and high predicted future levels.
A small change is recommended to allow for cycle parking provision for dwelling houses to be in a private garage as well as within the private garden area - subject to the dimensions of the garage being adequate to accommodate cycles as well as any vehicle.
However, the policy only specifies one long-term space per unit (regardless of size or location) where there is no garage or shed. In some instances such as within SPA2 and SPA6 where housing will be in the form of apartments and where there will be reduced car parking, it may be necessary for additional capacity for cycle storage beyond one space per unit, especially for larger flats or any flats without car parking provided.
Policy UD3
Structures abutting and overhanging the public highway will need the approval of the Highway Authority (HCC) as will illumination visible from the highway.
Policy TB1
From a transport network and user perspective, locations near to major passenger transport hubs, offering good interchange between different services and modes, are the most appropriate for denser development (i.e. taller buildings). However, development proposals should all be subject to Core Strategy policies T2-T5 to ensure that their impacts are understood and mitigated.
In order for such development to be acceptable, there must be adequate and appropriate improvements to transport infrastructure and urban realm within the site and in the wider area, to ensure no significant adverse impact on the highway and passenger transport networks, as a direct, indirect or cumulative result of development at the site and in the Borough as a whole.
Policy TB2
Suggest change to text at 8. Transport, parking and infrastructure:
'The design should detail a transport strategy for the proposed development to include how cycle parking, car parking, cycle permeability and pedestrian permeability have been integrated into the overall design. This should be based on a Transport Assessment and should avoid negative impacts on the public realm. The scheme will also need to demonstrate that the required infrastructure and utility capacity has been fully appraised.'
Appendix G
Parking bay dimensions only seem to consider residential element, parking bay at 2.4 x 4.8m is fine for standard bay but dimensions of other bays should be provided e.g. parallel arrangement. The garage dimensions provided are 3m x 5.5m whereas the industry standards are 3m x 6m (MfS para 8.3.41). Should minimum circulatory space for car parks be covered here (i.e. 6m) or will it be covered elsewhere?
SPA1
The ring road constrains pedestrian and cycle accessibility to the heart of the town centre. nb includes EMP5, R1, R2, R3, R4, R5. See Highway Authority comments in regard to each of these.
SPA2
Any development within the Watford Junction SPA should ensure that connectivity for pedestrians and cyclists is improved across the site, between the site and the town centre and on other key routes to Watford Junction Station.
Development of the station building, forecourt and car parks must address current limitations including capacity, access and circulation issues, for pedestrians, cyclists, buses, bus users, taxis, as well as users of the car parks. Opportunities to make Watford Junction an attractive and functional transport interchange that can accommodate future growth should be maximised.
See Highway Authority comments on Draft Development Brief (below).
SPA3
Good quality cycle and pedestrian links through the site and between the site and surrounding area and key destinations (town centre, Vicarage Road MLX station, local schools etc.) must be provided, or contributions to support infrastructure improvements in the wider area made through developer contributions.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
SPA4
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
Support improvements to green infrastructure and public realm as a complement to improvements to pedestrian and cycle links.
Flooding is a known issue affecting this area. Any development in this area should be designed to avoid and mitigate flood risk. Sustainable drainage approaches and green infrastructure should be used where appropriate to reduce and manage flood risk.
SPA5
Development at this location will need to consider transport impacts on the highway network, including operation of the Dome roundabout and St Albans Road notably at peak times. Also junctions including M25/A405/M1, and M1/A41.
There is a need to improve cycle, pedestrian and passenger transport connectivity to the site, and between the site and the town centre and Watford Junction.
It is recognised that the Abbey Line (North Watford) station is closer to the site, but there are limitations to this service at present which will reduce its attractiveness as an alternative to the car for journeys to Watford Junction or St Albans Abbey stations.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
There is a typo on second bullet point - should read 'improve air quality'.
SPA6
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Cycle improvements on Rickmansworth Road may be required as this is a key corridor between Rickmansworth and Watford.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
Secure, high quality cycle parking is needed at the proposed Cassiobridge station, as well as within the employment premises.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
See Highway Authority comments on Masterplanning Study (below)
MXD3
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
R1
It is agreed that robust pedestrian links with the town centre should form part of the new development at this location.
Good cycle access and high quality cycle parking also needs to be provided, for customers as well as employees.
R2
Agree that clear pedestrian connections between the site and the High Street are needed.
Good cycle access and cycle parking must also be provided.
There is a need to consider access needs to the site by different modes. A planned highway improvement scheme will make Clarendon Road one-way (NE-SW only) from Beechen Grove to High Street, with a contraflow cycle lane. Access to the street will be restricted by a Traffic Regulation Order to buses, taxis, cycles, 'blue badge' vehicles, and other vehicles 'for access only' to premises. All accessing vehicles will need to leave either via High Street or Watford House Lane (private road) for those accessing that area.
Development of this site should complement public realm enhancements proposed or already delivered on Clarendon Road and the High Street.
R3
Good cycle access and storage facilities must be provided, as well as good pedestrian links.
Developments at this location must take into account severance issues caused by the ring road for pedestrians and cyclists. Improvements required such as crossing improvements, new accesses into/through the site, should be delivered as part of the development or through developer contributions.
R4
Strong pedestrian and cycle links between this site and the town centre must be provided.
The quality of cycle routes and access to/from the west needs to be improved - eg. Market Street west of ring road and the Hornets Gyratory.
H1
This site is in close proximity to Bushey Station and includes its car park.
Opportunities to upgrade access to the station by non-car modes should be pursued.
Need to consider quantity and quality of cycle parking and cycle access to station from surrounding area.
Cycle access and cycle parking provision at Bushey station should be improved as part of any car parking replacement/improvement scheme.
Bushey Arches is a known congestion hotspot. Impacts of development on Bushey Arches must be considered and mitigation provided. This should include contributions to needed improvements to key walking and cycling routes and passenger transport infrastructure in the area.
H2
The ring road causes significant severance to people travelling by foot and cycle. Particular issues have been reported for people with visual impairments.
Improved cycle and pedestrian links to town centre and to Watford High Street and Watford Junction stations are needed from the site.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
H3
This site is about half mile from both the proposed Vicarage Road Met Line station and Watford High Street station, which is 10 to 12 minutes walking time.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
Vicarage Road is a busy road without dedicated cycle facilities. As such improvements to this route for cyclists should be considered. Developer contributions to improving cycle routes may be appropriate.
H5
The traffic impact on west Watford's road network needs to be considered and mitigated.
Cycle and pedestrian links into the site from different directions are required.
Adequate cycle storage must also be provided for existing and high predicted future levels.
Cycle infrastructure and the pedestrian environment of the surrounding area needs consideration.
H9
The impact of development at this site on the road network must be considered and mitigated if needed, including Rickmansworth Road and West Watford.
Good cycle links are needed including between the site, the town centre, and Ascot Road.
Bus services and infrastructure, including linking to new Cassiobridge Met Line station.
Bus services in this area may well be subject to change following the loss of the underground station. Development of this site and any forthcoming S106 contributions would provide the opportunity for an assessment to be made of potential improvements to bus services so this site remains connected to key destinations.
E1
High quality, secure cycle provision is needed at business premises.
Although the Ebury Way provides a good cycle route to the site, this will not be suitable for use all year round, at any time of day. As such improvements to the A412 corridor cycle infrastructure should be explored and provided. Developer contributions may be appropriate.
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
E2
Cycle and pedestrian routes through the site need improvement;
Via Watford Junction SPA site, there is a need to reduce severance and improve pedestrian and cycle connectivity to Watford Junction station and Clarendon Road.
WBC also needs to consider the implications of the Colonial Way Link road on development at site E2.
There is a need to consider potential transport implications of this site and the Watford Junction masterplan as a whole, including traffic accessing any new station multi-storey car parks, and the impact on the road network (eg. Colonial Way, Stephenson's Way, Radlett Road, Link Road, A41/M1 junction...).
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions.
E4
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions and on footways.
E5
Needs to link with SPA2 Watford Junction.
Development will need to assess impacts on road network and car parking demand in surrounding area.
Quality of pedestrian and cycle environment and urban realm on Clarendon Road should be considered and opportunities to enhance in consistent, coherent way should be explored to promote sustainable travel and improve route between town and Watford Junction.
Buildings will need to provide adequate, high quality secure cycle parking. If low car parking, may need to increase requirements or leave space to expand provision as required.
G6
Any change in land use/ status/ access provision to the south of Caxton Way and the south and east of Greenhill Crescent should not be permitted until its ability to provide the link for sustainable modes between Tolpits Lane and Caxton Way required by paragraph 10.6.9 of the WBC Core Strategy has been fully explored and ruled out.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF
1.1
The traffic and transport impacts of the masterplan scheme have not been modelled and thereby understood. The Highway Authority is, therefore, unable to fully support the plan until those impacts are assessed and deliverable mitigation measures agreed. HCC is developing traffic and transport models of Watford as part of its work to create a Growth & Transport Plan for the area. These will be used to test the impacts of the Watford Junction and other development proposals on transport infrastructure and services individually and cumulatively.
As part of earlier work on this site the County Council had required the construction of a road and bridge linking Colonial Way and St Albans Road via Penn Road. The scheme to build it received outline DfT funding and included a passenger transport (coach) interchange on the northeast side of the station. If the link road and bridge are no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
1.2
Correct reference to 'Abbey Link' in map to 'Abbey Line'.
2.1
The Barriers plan acknowledges the severance created by the presence of the Abbey Line. As part of earlier work on this site the County Council had required the construction of a road over the Abbey Line linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.2
Policy T1 in the borough council's Core Strategy supports conversion of the Abbey Line from heavy to light rail operation.
Correct reference to 'Abbey Flyover' in Objectives to 'Abbey Line'.
2.3
Correct reference to 'Abbey train line' under Transport and Parking to 'Abbey Line'.
As part of earlier work on this site the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.4
Gross External Areas values are different to those in 5.1 Area Schedules.
3D views might benefit from road names for orientation.
2.7
As part of earlier work on this site, the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
It is recommended that all roads are usable by cycles to aid permeability.
The road hierarchy titles have different meanings in the Highway Authority's own existing hierarchy. As the design is refined it is recommended that confusion is avoided by using different names.
2.8
The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.
3.3
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
3.4
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
4.1
The County Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order that they can be considered in the emerging Watford Growth & Transport Plan. Joint working with the County Council will remain key in order to maximise access to appropriate funding streams and delivery programmes.
Special Policy Area 2 is zero-CIL-rated so that all planning obligations will be derived via Section 106 agreements with service providers.
4.2
An overall Travel Plan for the site will be required and one for each subsequent development area should be provided and agreed.
5.1
Total car parking number differs from that given in 2.4 and Station Quarter East breakdown (p 46).
Gross External Areas values are different to those in 2.4.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF VIABILITY APPRAISAL
4.2
The County Council is concerned about the unrealistically low estimates given in figure 4.1 for the costings of infrastructure required to mitigate the impact of the masterplan.
CROXLEY VIEW/ ASCOT ROAD STUDY
Introduction
Mention must be made of the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The need for a link both for Watford and Three Rivers grows as pressure to develop either side of the Ebury Way increases and its delivery should be seen as key to both authorities' Duty to Cooperate.
Plans
All plans refer to Watford County Council.
All plans show Croxley Green Business Park to the southwest of the masterplan area. This is correctly the Wolsey Business Park.
Most plans show the Grand Union Canal badged as the River Gade which runs to the south and east of it.
Some plans do not show the correct alignment of the Watford/ Three Rivers boundary.
Some plans erroneously label the NE corner of Croxley Common as Cassiobury Park Nature Reserve.
Masterplanning Strategy plan - asterisks and other labelling are not described and inconsistently applied.
Potential Development Sites plan
This omits to include the Tech Site (around Woodshots Meadow). This is subject to preapplication discussions now and should be considered with the adjacent sites as it is in Employment Policy Area E1 (Local Plan Part 2 appendix 1).
Proposed Vehicle and Pedestrian Movement plan
This omits the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The route currently being explored follows the cycle track between the Watford Enterprise Centre and number 27 Greenhill Crescent.
Historic environment, landscape and ecology
The County Council supports the overall policy intentions of the Local Plan covering landscape, ecology and the historic and built environment and provides the following comments to help strengthen these policies and their supplementary text.
Historic Environment
Development Management Policies
The County Council welcomes the Borough's consideration of the Historic Environment in Part 9 Urban Design and the Historic Environment. However, the historic environment should be referenced in line with the NPPF definition of heritage assets. In addition to historic buildings (both designated and undesignated), the historic environment of Watford includes archaeological remains, historic landscapes and historic parks. Therefore policies are needed to conserve the historic environment as whole, not just designated buildings, registered gardens and conservation areas as is currently stated.
Under Policy UD4, Archaeology, there appears to be repetition of the NPPF, the policy is unclear and should be re-written.
There is also reference to the conservation of heritage assets being secured by an archaeological Written Scheme of Investigation (WSI). Whilst the County Council welcomes the requirement for these documents and for them to include provision for publication and public dissemination of results where appropriate (NPPF 141), it is not clear if the WSI on its own is considered to be robust enough to secure appropriate conservation of the historic environment. Therefore it is unclear if this part too, is effective.
Watford Junction Draft Development Brief 2016
Paragraph 4.2 notes that a Heritage Statement and Desktop Archaeological Study may need to be submitted with any planning applications. However, it is unclear what is meant by a Heritage Statement. Also archaeological assessment may not be limited to a desktop study.
Site Allocations
An appraisal of the archaeological implications of development for the new areas identified in the Second Consultation document (2016) is summarised below.
1. Archaeology as a Development Constraint
N/A
2. Requirement for Pre-allocation Archaeological Assessment
The sites below have known archaeological remains within them or have significant archaeological potential by reason of their size and situation, such that there is a risk that archaeology could be a constraint on any development. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that archaeological assessments should be included within all development briefs and other proposals for the sites, before they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the sites, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent of archaeological remains that might be a constraint upon the principle of development of these sites.
Allocation numbers: SPA1, SPA4 and H9.
3. Requirement for Pre-application or Pre-determination Archaeological Assessment
The sites below have known archaeological remains within them or have archaeological potential. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that that pre-application or pre-determination archaeological assessments should be included within all development briefs and other proposals for the sites, if they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the proposals, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent
of archaeological remains worthy of preservation in situ, to enable the LPA to determine any specific application for development.
Allocation numbers: SPA 2, SPA3, SPA5, SPA6, MXD1, MXD3, R1, R2, R3, R4, H2, H3, H4, H 10, E1, E2, E3, E4, E5, E6.
4. Mitigation of archaeological impact by condition
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, any archaeological issues can probably be dealt with by condition, should planning permission be granted.
Allocation numbers: R5, CF1, H1, H5, H6, GT1.
5. No archaeological requirements
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, there are unlikely to be any archaeological implications. However this will depend on the details of any proposals and any new archaeological information.
Allocation numbers: MXD2, MXD4, H7, H8, H11.
Ecology
Development Management Policies
Policy SD15, External lighting, the County Council support the provisions set out in this policy and advise that there should be reference to the guidance provided by the Institute of Lighting Engineers which has been instrumental in seeking to reduce the impacts of artificial lighting within the environment.
Green Infrastructure, Biodiversity and Recreation, the County Council supports the reference to Green Infrastructure (GI).In defining GI there should also be reference to the provision of local food production as a key ecosystem service.
Policy G15, Trees, Woodlands and Hedgerows, this policy is supported in respect of highlighting ecological and cultural value of trees, woodlands and hedgerows. However, under paragraph 10.3, the reference to valuable habitats should be extended to include reference to ecological networks and corridors. Under paragraph 10.6 it should be clarified that replacing trees lost to development cannot compensate for the loss of biodiversity or amenity value in the short term.
Policy GI6, Protecting and Enhancing the Grand Union Canal, this policy is supported including the reference to enhancing biodiversity under paragraph 10.11. It is advised that the policy is extended to include a clause that seeks to improve the biodiversity of the canal corridor where possible. Development that would have an
adverse impact on the biodiversity of the canal would not be supported unless it can demonstrate provision of suitable mitigation or compensation.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, this policy is supported however recommend the following clarifications and amendments.
It is advised to make reference to the 'amenity value' of the river, specifically encouraging 'recreation' may increase disturbance to sensitive wildlife within river corridors. The term 'amenity' embraces visual and recreational importance without being too prescriptive or disruptive if more sensitive habitats or locations are affected an important consideration within this largely urban area.
With regards the provision of 'a corridor for wildlife and biodiversity,' the reference to biodiversity should be deleted as wildlife is biodiversity. With regards replacement structures and fish passage, liaison with the Environment Agency is essential if any such works are proposed. With regards access it should be designed in a way that also enables some undisturbed areas to be retained.
Policy GI9, Provision of Open Space and Play Space in Residential Development, aspects of this policy relevant to biodiversity are supported. The reference to green space typologies should be expanded to include allotments and community orchards, in order to reflect the types of functional sites which support both community and biodiversity benefits.
Biodiversity, it is not clear why this section is formatted differently to the preceding and subsequent sections. In particular it does not describe 'Why is this policy needed?' and 'what is it intended to do?' In setting out the need for the policy, it should reference the legislative requirements of statutorily protected sites and species which are a material consideration in planning, as well as the Duty placed on Local Authorities to have regard to conserving biodiversity in all of their functions as set out in the Natural Environment and rural Communities Act 2006. In setting out the intention of the policy there should also be reference to seeking to deliver the aims of the Local Nature Partnership - for which securing ecological resources, functions and services are a consideration when determining planning applications.
Under paragraph 10.37 the reference to the 'Biodiversity Plan' should be amended to reference to the 'Biodiversity Action Plan principles' (BAP). The BAP, nationally and locally, has ceased to be actively supported by National and Local Government, and has essentially been replaced by the Local Nature Partnership. However the principles underpinning it remain valid as statements and the intentions of the various habitat and species action plans are sound in themselves and could be followed if resources or interest permitted.
It is suggested that the statement under paragraph 10.39 should be amended as follows:
'This policy expects that where appropriate, development proposals will demonstrate the relative ecological value of a site before and after development. Proposals should follow the mitigation hierarchy and provide clear evidence of impacts and enhancements where appropriate, consistent with the aims of NPPF, BS42020
"Biodiversity - Code of Practice for Planning and Development'' and guidance provided by CIEEM. This will require sufficient detail and clarity to enable net losses and gains to be identified and monitored, consistent with the Code. Where unavoidable, Biodiversity Offsetting should be considered as a means to ensure there is no net loss of biodiversity resulting from development'.
Highlighting the specific use of Biodiversity Calculators such as the one mentioned in paragraph 10.39 can be a little misleading. BS42020 does not mention the use of biodiversity calculators, and taken out of context the results of such calculations can sometimes show net gains where there should be none (removal of ancient woodland for example cannot reasonably be compensated in the real world). Other wider landscape issues are also not always considered by these calculators; if the land is part of a wider corridor, or a biodiversity network for example. It has taken several years for Warwickshire County Council to incorporate their use in to the planning system and there is still not universal agreement on them.
The County Council would therefore advise caution on their avocation, but rather emphasise the need to prove that biodiversity has not been lost and in the most part enhanced through "appropriate methods in-line with BS42020".
Policy GI10 Managing Biodiversity in new Developments. The County Council supports Watford Borough Council's commitment to increasing biodiversity within the district. The Policy is consistent with other Hertfordshire Local Authorities, and in-line with the National Planning Policy Framework.
The following amendments are advised. There should be reference to avoiding negative impacts upon ' local ecological networks...,'as each site sits within a local environmental and should retain or enhance any existing ecological resources or corridors to and from adjacent sites.
'Compensation will only be considered as a last resort. Development proposals will be expected to evaluate the impact on local biodiversity where appropriate and propose measures to maintain and enhance biodiversity. This approach should follow the principles outlined within BS42020 "Biodiversity - Code of Practice for Planning and Development" or other measures of best practice, including Biodiversity Offsetting where necessary'.
The above wording embraces the mitigation hierarchy as well as defining means to achieve no net loss as sought by NPPF, without being too prescriptive.
It is considered that paragraph 10.40 regarding the biodiversity calculator is not needed if references requiring its specific use are otherwise removed. The County Council remain concerned that some caution needs to be taken regarding the generation of positive scores which indicate a net gain despite losses that may otherwise be considered unacceptable.
Site Allocations
Please refer to Appendix 1.
Landscape
Green Infrastructure, Biodiversity and Recreation, the policy framework for green infrastructure (GI) was significantly strengthened in Feb 2016 with the introduction of detailed Planning Policy Guidance. The guidance states that GI is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water and should be a key consideration in both local plans and planning decisions.
The Herts Landscape and Green Infrastructure Group is currently looking at GI delivery and practice across Hertfordshire with a view to presenting a project proposal to Herts Infrastructure Planning Partnership (HIPP) in November. The key aim of the project is to mainstream the delivery of GI through the local plan and development management processes. The outputs and deliverables of the project are currently being shaped and should help provide local planning authorities with a good practice approach to GI delivery, supported by robust evidence and case studies.
The Landscape Institute Position Statement for Green Infrastructure provides a widely supported definition of GI (assets and functions) and a comprehensive overview of the key benefits it can deliver, supported by case studies http://www.landscapeinstitute.org/policy/GreenInfrastructure.php
There is no reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans. (The strategies provide an opportunity to address cross boundary issues and meet the Duty to Cooperate. (Hertfordshire and GreenArc Area Strategic Highlights Plan (SHiP) and the All London Green Grid.)
There should be greater emphasis on GI in place-making and conserving and enhancing local distinctiveness. There should be reference to any local character assessments and the guidelines for managing change that should help shape proposals, and conserve and enhance local character.
At a national level there is also the National Character Areas produced by Natural England https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making, and at a regional level there is the East of England Landscape Framework http://landscape-east.org.uk/.
Where proposals are likely to result in landscape and visual effects a landscape and visual impact assessment, in line with industry good practice guidance (Landscape and Visual Impact Assessment third edition Landscape Institute and Institute for Environmental Management and Assessment) may be required as part of an application. The mitigation hierarchy should be referenced to ensure that proposals seek to avoid and minimise any negative effects.
The reference to Green Infrastructure under paragraph 10.1, is fully supported, however it is suggested to expand the definition to include reference to blue assets
such as the Grand Union Canal. Also suggest amend reference to 'mitigating climate change' to 'mitigating the effects of climate change.'
Under paragraph 10.3, it should be clear that biodiversity is not the only driver for Green Infrastructure; other key drivers include a single or multiple land-use functions and include waste/water management, recreation, food production, local distinctiveness etc.
Policy GI5, Trees, Woodlands and Hedgerows, the reference to the protection of trees in line with current British Standard Institute code of practice is fully supported, however the full title of the standard does not appear to be referenced and should be 'Trees in relation to design, demolition and construction' (BS5837:2012). In addition it is advised that where required by the planning authority, tree surveys, arboricultural impact assessments and method statements should all be carried out in compliance with this standard.
The policy should be expanded to include reference to the current hedgerow regulations, the provision of a landscape strategy, planting plans and specifications, and the provision of aftercare (long term management plans) and replacement of failures.
Policy GI6, Protecting and Enhancing the Grand Union Canal, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Yours sincerely,
Paul Donovan
Environment Department
Hertfordshire County Council
APPENDIX 1
Please find below a brief ecological assessment of the site allocations. A 'standard' template for each Site has been provided.
Ecosites do not have any form of status of importance, but are merely sites that we have some ecological information on - thus they do support some wildlife interest, at least at a local level. Whilst these sites are often a valuable starting point in identifying the county's wildlife resource, they do not meet the rigorous and quantifiable assessment criteria needed to identify them as non-statutory Local (County) Wildlife Sites.
SPA1 Town Centre
Recognised sites adjacent / close to Site: close to eastern end of Cassiobury Park Local Wildlife Site.
Other features: Little semi natural habitat present, possibly some mature trees.
Protected species: Probably bats, badger records to the west.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road)
Protected species: Unknown - no records
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA3 Health Campus (includes a Borough Council Depot and Waste Transfer Station at Wiggenhall Road)
Recognised nature sites within Site: The Lairage Land Local Wildlife Site (LWS) and Local Nature Reserve (LNR), Croxley Green Junction Sidings LWS, Oxhey Park River & Margins LWS; Riverside Road Waste Ground ecosite (local database site), The Island, off Cardiff Road ecosite, Oxhey Park ecosite
Recognised sites adjacent / close to Site: Horwoods Avenue Playground ecosite, Moor View ecosite, Cardiff Road Embankment ecosite.
Other features: includes village green - "Green situated between Riverside Road & the River Colne"
Protected species: Birds and Water voles.
Opportunities: High. Habitat management to maintain and enhance biodiversity interest, green infrastructure / corridors.
Ecological sensitivity: Medium to high depending on location.
Fundamental ecological constraint: Presumption to avoid development on Local Wildlife Sites, fragmentation of green corridor,
Loss of Farm Terrace allotment site - should be offset elsewhere as open space / community food growing / ecological resource.
SPA4 Lower High Street
Recognised sites adjacent / close to Site: Bushey Hall Farm ecosite, Oxhey Park ecosite.
Other features: "Recreation Allotments" village green.
Protected species: Unknown - no records. Birds in trees.
Opportunities: Limited as previously developed site. Potential green corridors along railways lines.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA5 Dome Roundabout (includes a Waste Transfer Station at Colne Way)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA6 Western Gateway (includes area of search ELAS221 in the Hertfordshire Waste Site Allocations Document)
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite, Ascot Road ecosite.
Recognised sites adjacent / close to Site: close to eastern end of Croxley Common Moor Site of Specific Scienttific Interest (SSSI) and LNR.
Other features: Grassland strip along eastern boundary with bordering trees.
Protected species: Unknown - no records.
Opportunities: Enhance green infrastructure corridor along eastern boundary.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds in trees.
The ecosites have largely been destroyed by development.
MXD1 North Watford library, Lemarie Centre for Charities, and health facilities (within SPA5)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
MXD2 The Brow
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
MXD3 Gas holder site (within SPA4)
Other features: River Colne borders the eastern boundary.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site. Potential to enhance the river margins as a green corridor.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in the trees.
Largely developed but riverside trees most important and scrub on site.
MXD4 Ascot Road
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite.
Other features: As well as the rough ground and bordering trees of the area to the west, the Site includes part of the school playing fields to the east, which is short mown amenity grassland. There are also some mature trees.
Protected species: Unknown - no records.
Opportunities: Potential enhancement of the areas of semi-natural habitat to improve green corridor connectivity.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds. Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R1 Sainsbury's and adjoining land
Other features: The north-eastern part of the Site includes an area of grassland and mature trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R2 Former TJ Hughes and adjoining land
Other features: Small area of amenity grassland on the north-eastern side.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R3 BT Telephone Exchange and adjoining Wellstones
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R4 Church Street Car Park and land fronting Market Street/Market Place
Other features: area of amenity grassland and scattered trees on the southern side.
Protected species: Unknown - no records.
Opportunities: Limited as predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R5 Charter Place centre and adjoining land onto the High Street
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
CF1 Community Facility Tolpits Lane.
Other features: Site appears to be rough grassland with scattered scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to enhance the habitats on site. The northern boundary is a wooded bank bordering the railway line. Maintain / enhance green corridor along railway.
Ecological sensitivity: Low - medium as semi-natural habitats on site.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H1 Land at Pinner Road
Other features: There are small areas of rough (possibly amenity) grassland with scrub and scattered trees.
Protected species: Unknown - no records.
Opportunities: Limited as a predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H2 Skatepark, Lower Derby Road
Other features: There is an area of grassland with trees in the north-west corner.
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a predominantly a previously developed site. Potential to maintain / enhance the semi-natural habitats on site for green corridor links to nearby habitats, river corridor and wooded railway banks.
Ecological sensitivity:
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H3 Vicarage Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H4 Telephone Exchange - First Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H5 Builder's Yard, Queens Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H6 Bill Everett Community Centre
Recognised sites adjacent / close to Site: adjacent to Long Spring and Harebreaks Wood (Watford) Local Wildlife Site and Local Nature Reserve.
Other features: some areas of grassland (probably amenity?) and occasional scattered trees.
Protected species: Bat roost in building nearby.
Opportunities: Potential to link woodland to the south to area to the north - depending on what the latter is like, as it appears to be bare ground on our aerial photographs.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H7 Rickmansworth Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H8 Garages- The Gossamers
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H9 Watford Station, Cassiobury Park Avenue
Recognised nature sites within Site: Cassiobury Park Avenue allotments ecosite.
Recognised sites adjacent / close to Site: close to "Gade Avenue" Local Wildlife Site.
Other features: Includes an area of allotment gardens and mature trees.
Protected species: Unknown - no records. Potential for bats and reptiles.
Opportunities: Maintain and enhance the green corridor link along the railway line.
Ecological sensitivity: Low - medium?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H10 Croxley View
Other features: Area of semi-natural grassland with scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to manage the existing habitats to maintain / improve biodiversity. Maintain as a green infrastructure link from open grasslands to the south towards the River Gade corridor and semi-natural habitats to the north
Ecological sensitivity: Low.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H11 Garages, Bowmans Green
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
GT1 Lands at Tolpits Lane
Other features: Area of rough grassland with bordering trees.
Protected species: Unknown - no records.
Opportunities: Limited, but part of semi-natural grassland complex in the area so potential for linking hedgerows. Any loss of grassland could be compensated for by enhancement elsewhere and landscaping may provide additional buffering habitats locally if this site were to be developed as such.
Ecological sensitivity: Low?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
E1 Watford Business
Recognised sites adjacent / close to Site: adjacent to Croxley Common Moor Site of Special Scientific Interest (SSSI and Local Nature Reserve (LNR) and Commonland; adjacent to Ascot Road Car Park and Waste ecosite, adjacent to Ascot Road ecosite; close to Ascot Road Scrub Local Wildlife Site.
Other features: Some areas with trees.
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
Part of the edge of this currently provides a valuable buffer and boundary edge to Croxley Common Moor SSSI and LNR. We would object to any development which further degraded this boundary habitat, although much of the former area has already been lost to hard surfacing.
E2 Imperial Way / Colonial
Protected species: Limited as a previously developed site.
Opportunities: Low.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E3 Fishers
Recognised nature sites within Site: Cardiff Road Embankment ecosite.
Recognised sites adjacent / close to Site: adjacent to Croxley Green Junction Sidings Local Wildlife Site.
Other features: Disused railway line to the west is bordered by woody vegetation.
Protected species: Unknown - no records.
Opportunities: Potential green corridors east / west across the site and along the western boundary. Maintain a buffer against LWS to the south.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
E4 Greycaine Road / Odhams / Sandown Road
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E5 Clarendon Road / Station Road / Bridle Path Office Area
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E6 Leavesden Studios - the Island site
Recognised nature sites within Site: part of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Recognised sites adjacent / close to Site: adjacent to the rest of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Other features: Semi-improved grassland habitat, part of a much larger complex.
Protected species: Badger setts on site and nearby.
Opportunities: Linking habitats to similar adjacent grasslands.
Ecological sensitivity: Low - medium.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species, with particular attention to badgers

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 854

Received: 03/10/2016

Respondent: Hertfordshire County Council SLU

Representation Summary:

If the link road and bridge are no longer to be provided the the impacts will need to be assessed and accepted by the council

Full text:

Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
With regard to Policy SPMX1: Special Policy Areas, the council is pleased to see the insertion of reference to the county council's documents. The text should however refer to the' Waste Local Plan' which includes both the Waste Core Strategy and Development Management Policies document and the Waste Site Allocations document.
With regard to Special Policy Area 2: Watford Junction, the council is pleased to see that there is reference to the need to safeguard the rail aggregates depot at Orphanage Road.
Further information on SPA2 is contained in Appendix I: Site Schedules of the Local Plan Part 2. The council is pleased that the rail aggregates depot is included as a
Spatial Planning and the Economy
Environment Department
Hertfordshire County Council
County Hall
Hertford
Hertfordshire
SG13 8DN
paul.donovan@hertfordshire.gov.uk
01992 556289
Planning Policy Team,
Room 65,
Watford Borough Council,
Town Hall,
Watford,
Herts,
WD17 3EX.
development consideration where it states 'This will need to be retained, or a new comparable facility provided within the local area'. However it should be noted that the text should refer to the 'rail aggregates depot' as opposed to the 'waste aggregates depot'.
However, in practice, taken together with the masterplan and accompanying viability report, there appears to be a strong likelihood that the rail aggregates depot is not to be retained on site and the collective impact of the Local Plan is not to safeguard the rail aggregates depot. Given this, the Inspector may well wish to see what evidence exists with regard to securing a replacement facility and currently no such evidence accompanies the Local Plan. As a consequence, there is considerable uncertainty in relation to whether the Local Plan satisfies potentially all soundness tests.
With regard to SPA6 Western Gateway, this includes ELAS221 and it is also worth pointing out that the areas designated as PS2 and PS3 potential in the Croxley View/Ascot Road Masterplanning Study are also located in ELAS221.
It is agreed that it is useful to insert text in relation to the circular economy as part of the waste section under paragraph 3.30, supporting text to Policy SD10: Waste. The second bullet point should state 'drive greater resource productivity.'
The relevant policy basis has been applied in the waste section and the Watford Local Plan with regard to responsibility for waste management. Whilst there appears to no longer be specific reference to Waste Policy 12, there is text to cover the use of this policy along with others within the Waste Core Strategy and Development Management Polices document. One comment to make is that in the wider context of the Watford Local Plan with there also being reference to ELAS221, the text in paragraph 3.30 should refer to the Waste Local Plan, which covers policies within the Waste Core Strategy and Development Management Policies document, adopted November 2012 and the Waste Site Allocations document, adopted July 2014.
Watford Junction Development Brief
As previously stated, most recently in respect of the Infrastructure Delivery Plan, the key matter of concern to the Minerals and Waste Planning Authority is the impact that any proposed development may have upon the safeguarded rail aggregate depot located at Orphanage Road, Watford which is a current operational facility.
The planning policy status, as detailed within the introduction of the brief, refers to consideration being had to national planning policy and the Watford Borough Council Local Plan. To ensure that the Development Plan has been considered as a whole the brief needs to also refer to the Minerals Local Plan and the Waste Local Plan. In terms of national policy, there is the need to ensure that the NPPF is considered in respect of para 143 which states that Mineral Planning Authorities should safeguard existing, planned and potential rail heads, so as to prevent their redevelopment for other uses and loss of the mineral infrastructure. This safeguarding is also applicable to storage, handling and processing facilities associated with them.
It is considered that due to the location of the rail aggregate depot within the development brief area that the county council's Minerals Local Plan 2002-2016, adopted March 2007 is also considered with specific regard to minerals policy 10: Railheads and Wharves. The Minerals Local Plan is being reviewed at present. It is envisaged, due to the requirement of the NPPF, that there will be a policy on Rail heads and Wharves in the Draft Minerals Local Plan.
The siting of the rail aggregate depot is shown within the county council's Mineral Consultation Area Supplementary Planning Document, adopted November 2007. The consultation area covers the majority of the Special Policy Area 2 Watford Junction. In accordance with the NPPF and Minerals Local Plan, in respect of minerals policy 10 the county council seeks to safeguard the rail aggregate depot which continues to serve as a sustainable mode of transporting minerals over long distances and the concrete batching facility which this site also supports. Given that the site is viable for use as a rail aggregate depot, its retention is expected unless the facility can be satisfactorily relocated within the development proposals in terms of operational requirements and environmental criteria or it has been or will be replaced in an alternative location.
The development brief identifies the rail aggregate depot as being a 'weakness' for the redevelopment of Watford junction in the SWOT analysis in paragraph 2.1. Minerals are important to the economy. Aggregate is needed to facilitate development and volumes of construction material being transported by rail in increasing. In light of this it could be considered that a rail aggregate depot in close proximity to the construction project could be considered to be a strength.
The issue of addressing such a 'weakness' is not however further expanded upon. It is clear from the illustrative masterplan that the retention of the rail aggregate depot is not part of the scheme. Whilst it is intended to be flexible enough to accommodate alternative layouts so long as it achieves the guiding principles and core ambitions of the masterplan, there does not appear to be sufficient scope to accommodate the existing or a relocated rail aggregate depot within the redevelopment area. As such this leaves the only option of relocating the rail aggregate depot offsite at another location along the railway line.
There is the need to establish an alternative well positioned strategic location for the rail aggregate depot to ensure its continued operation for imports and exports of minerals and secondary and recycled aggregates. The SWOT analysis in the development brief states that there is a 'weakness' in terms of a lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling. The Borough Council is referred back to paragraph 143 of the NPPF, the adopted Minerals Local Plan and specifically minerals policy 10 and the adopted Minerals Consultation Area SPD as detailed above in terms of the clarity for the safeguarding of the rail aggregates depot at Orphanage Road.
The brief states under the land use and quantum section of Station Quarter East within paragraph 3.4 that the development will be required to relocate the Rail Aggregates Depot within the local area, in consultation with Hertfordshire County Council and the operator of the site. The County Council will continue to work with the Borough Council in respect of this matter. The land use and quantum section in
paragraph 3.4 should also refer to the need to work with Network Rail with regard to the relocation of the Rail Aggregates Depot. The County Council understands that Network Rail Freight Management has been consulted and will provide comments to this consultation. There is however no further detail with regard a precise location having been secured.
To this end the relocation of the rail aggregate depot is fundamental to the delivery of the masterplan. A statement should be made in the delivery section of the brief at paragraph 4.1 specifically in relation to the requirement to ensure that the relocation of the rail aggregates depot forms part of the Watford Junction Delivery Plan.
Croxley View/Ascot Road Masterplanning Study
The Croxley View/Ascot Road Masterplanning Study has been considered by the county council as Waste Planning Authority due to the proximity of redevelopment to the Employment Land Area of Search (ELAS) 221 Watford Business Park.
The masterplan aims to build on the policy foundations of the district Local Plan Core Strategy Policy SPA6 to facilitate redevelopment. The location of potential residential development is shown within the Masterplanning Study to be directly adjacent to ELAS221 as designated within the county council's Waste Site Allocations document 2011-2026, adopted July 2014.
It is considered that ELAS that are predominantly used for general industry (B2) and storage and distribution (B8) are compatible with waste management uses. ELAS221 contains B1 and B2 uses and as such is acceptable in principle for a range of potential waste uses listed in the general waste brief during the 15 year plan period 2011-2026. Further planning guidance into the suitability of waste related development on the identified ELAS is within the ELAS Supplementary Planning Document, adopted November 2015. For this area, the Supplementary Planning Document states 'only enclosed waste transfer stations and materials recovery facilities that handle dry recyclables would be acceptable, along with enclosed inert waste recycling facilities. No other potential uses that may generate a leachate or liquor, which poses a risk to groundwater resources would be appropriate'.
The council does not wish to see the loss of identified ELAS for non-waste uses in order to safeguard it for future potential waste uses that may be sited in this location. Whilst the residential development would not directly encroach onto the ELAS, the council is mindful that the residential development is identified along the eastern boundary of the designated site and as a result there could be the potential for indirect impact upon the siting of waste uses within the ELAS.
The Waste Local Plan does not rely on the need for all land within ELAS across the county for the delivery of waste uses. However the cumulative loss of ELAS to non-waste uses is monitored and the safeguarding of remaining ELAS land is important to ensure there is a sufficient amount of land that could come forward for waste management facilities in the future, particularly with additional growth resulting in an increase in waste produced which needs to be managed.
There are currently no extant planning permissions on land directly adjacent to the masterplanned residential development to be aware of. The nearest waste site is the Household Waste Recycling Centre at Caxton Way in ELAS221. There is sufficient land remaining in ELAS221 to be brought forward for waste management uses.
The County Council does not wish to object to the masterplanning for potential residential development at this stage but reserves its right to object to future planning applications adjacent to the ELAS should a waste site be development in advance of residential. The reason for this would be to safeguard any waste use(s) under waste policy 5: Safeguarding of Sites within the Waste Core Strategy and Development Management Policies document 2011-2026, adopted November 2012. Further discussions would need to take place in the event that negative effects are identified that would restrict the waste operation to continue. A buffer between two land uses or mitigation measures in some cases may be appropriate to allow opposing land uses to exist in harmony adjacent to each other.
The County Council's adopted Waste Core Strategy and Development Management Policies document, does not stipulate a distance whereby other development in close proximity to a safeguarded waste site should be discouraged, the 2004 ODPM document: Planning for Waste Management Facilities: A Research Study states that for waste transfer stations: "sites closer than 250m from residential, commercial or recreational areas should be avoided." This guidance was used in the production of the Waste Site Allocations document. Depending upon the location of any potential future waste management facility within the ELAS, there is the potential that facilities may well be sited closer than the suggested 250m to any future housing.
Transport
Overarching/ general comments
Watford and the surrounding transport network face growing challenges as a result of the desired housing and economic growth in the area and increasing demand for travel. The County Council is developing a countywide transport model that will help all local authorities in the county to plan positively for growth and infrastructure investment in a way that safeguards the health and wellbeing of our communities and the environment. Already the model has identified notably worsening congestion issues in the Watford area as a result of planned growth. The next outputs of the enhanced Watford area version of the model will be available by the end of October 2016. The existing model is already available to Watford Borough Council to test development scenarios and proposals from the Local Plan.
In parallel with this, the County Council is developing a Growth & Transport Plan for South West Hertfordshire, which includes Watford and the surrounding towns and transport networks that make up a coherent area of travel demand. The Growth & Transport Plan will put forward packages of transport interventions to respond to strategic transport challenges and objectives for the area, derived through robust evidence analysis and engagement with stakeholders. Watford Borough Council officers and members have been involved from the early stages in GTP workshops
at key stages. The GTP is about identifying needs, planning for and enabling investment and delivery of a transport network and public realm that will support a healthy economy, environment and communities.
As a result of the current ongoing work being incomplete, at this stage there is insufficient evidence available to assess the implications of Local Plan Part 2 on the transportation network. As a consequence, there is uncertainty in relation to the mitigations that will be required to support the proposals and we remain in doubt that it potentially satisfies all soundness tests.
Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
Contents
'Appendix I - Site Allocations' is referred to later as 'Site Schedule'
'Appendix L' and 'Appendix M' missing from content list
Policy SD10
Refuse collection vehicles must be able to stop within the 'maximum refuse carry distance' specified by the Local Planning Authority or within 25m of any bin storage area, whichever is the lesser distance. Residents should not have to carry their rubbish more than 30m to a storage point. (Sources BS5906:2005 and Schedule 1 Part H Building Regulations)
Policy TLC14
On-street parking continues to need to be managed to manage congestion and avoid hazards, particularly at junctions.
Policy HS7
The subjective "undue pressure" on on-street parking should not lead to increased congestion and / or hazards on the highway network, particularly at junctions.
The siting of bin stores should not adversely impact on the operation of the highway network.
Policy HS8
The Highway Authority recommends that consideration of deliveries is made explicit in this policy.
6.9 and Policy EMP5
The County Council supports urban realm enhancement of Clarendon Road to encourage walking and cycling and improve the key pedestrian route between the town centre and Watford Junction.
Consideration should be given to amending the policy wording to explicitly include an expectation for development along Clarendon Road to contribute towards urban realm enhancements directly through works delivered or through developer contributions to fund such works.
Policy T6
The County Council is supportive of the zonal approach to car parking guidance to encourage lower car ownership and usage in more accessible zones. The principle of 'Car Lite' development in the most accessible areas, within 5 or so minutes' walk of a major transport hub, is also supported as long as the needs of disabled drivers and visitors are considered.
Lower car parking provision must be accompanied by appropriate restrictions in surrounding residential streets and any public car parks to prevent spill-over parking. In order for this approach to lowering car usage to be successful, there needs to be parallel investment in infrastructure (eg significantly better cycle and bus routes) and urban realm improvements to support and actively encourage alternative modes of travel.
The County Council welcomes the requirements for car club spaces in the SPAs and where parking does not meet the guidance.
Policy T8 and Appendix H
The policy on cycle parking provision and the stipulations relating to quality contained in the policy is welcomed. Adequate cycle storage must also be provided for existing and high predicted future levels.
A small change is recommended to allow for cycle parking provision for dwelling houses to be in a private garage as well as within the private garden area - subject to the dimensions of the garage being adequate to accommodate cycles as well as any vehicle.
However, the policy only specifies one long-term space per unit (regardless of size or location) where there is no garage or shed. In some instances such as within SPA2 and SPA6 where housing will be in the form of apartments and where there will be reduced car parking, it may be necessary for additional capacity for cycle storage beyond one space per unit, especially for larger flats or any flats without car parking provided.
Policy UD3
Structures abutting and overhanging the public highway will need the approval of the Highway Authority (HCC) as will illumination visible from the highway.
Policy TB1
From a transport network and user perspective, locations near to major passenger transport hubs, offering good interchange between different services and modes, are the most appropriate for denser development (i.e. taller buildings). However, development proposals should all be subject to Core Strategy policies T2-T5 to ensure that their impacts are understood and mitigated.
In order for such development to be acceptable, there must be adequate and appropriate improvements to transport infrastructure and urban realm within the site and in the wider area, to ensure no significant adverse impact on the highway and passenger transport networks, as a direct, indirect or cumulative result of development at the site and in the Borough as a whole.
Policy TB2
Suggest change to text at 8. Transport, parking and infrastructure:
'The design should detail a transport strategy for the proposed development to include how cycle parking, car parking, cycle permeability and pedestrian permeability have been integrated into the overall design. This should be based on a Transport Assessment and should avoid negative impacts on the public realm. The scheme will also need to demonstrate that the required infrastructure and utility capacity has been fully appraised.'
Appendix G
Parking bay dimensions only seem to consider residential element, parking bay at 2.4 x 4.8m is fine for standard bay but dimensions of other bays should be provided e.g. parallel arrangement. The garage dimensions provided are 3m x 5.5m whereas the industry standards are 3m x 6m (MfS para 8.3.41). Should minimum circulatory space for car parks be covered here (i.e. 6m) or will it be covered elsewhere?
SPA1
The ring road constrains pedestrian and cycle accessibility to the heart of the town centre. nb includes EMP5, R1, R2, R3, R4, R5. See Highway Authority comments in regard to each of these.
SPA2
Any development within the Watford Junction SPA should ensure that connectivity for pedestrians and cyclists is improved across the site, between the site and the town centre and on other key routes to Watford Junction Station.
Development of the station building, forecourt and car parks must address current limitations including capacity, access and circulation issues, for pedestrians, cyclists, buses, bus users, taxis, as well as users of the car parks. Opportunities to make Watford Junction an attractive and functional transport interchange that can accommodate future growth should be maximised.
See Highway Authority comments on Draft Development Brief (below).
SPA3
Good quality cycle and pedestrian links through the site and between the site and surrounding area and key destinations (town centre, Vicarage Road MLX station, local schools etc.) must be provided, or contributions to support infrastructure improvements in the wider area made through developer contributions.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
SPA4
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
Support improvements to green infrastructure and public realm as a complement to improvements to pedestrian and cycle links.
Flooding is a known issue affecting this area. Any development in this area should be designed to avoid and mitigate flood risk. Sustainable drainage approaches and green infrastructure should be used where appropriate to reduce and manage flood risk.
SPA5
Development at this location will need to consider transport impacts on the highway network, including operation of the Dome roundabout and St Albans Road notably at peak times. Also junctions including M25/A405/M1, and M1/A41.
There is a need to improve cycle, pedestrian and passenger transport connectivity to the site, and between the site and the town centre and Watford Junction.
It is recognised that the Abbey Line (North Watford) station is closer to the site, but there are limitations to this service at present which will reduce its attractiveness as an alternative to the car for journeys to Watford Junction or St Albans Abbey stations.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
There is a typo on second bullet point - should read 'improve air quality'.
SPA6
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Cycle improvements on Rickmansworth Road may be required as this is a key corridor between Rickmansworth and Watford.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
Secure, high quality cycle parking is needed at the proposed Cassiobridge station, as well as within the employment premises.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
See Highway Authority comments on Masterplanning Study (below)
MXD3
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
R1
It is agreed that robust pedestrian links with the town centre should form part of the new development at this location.
Good cycle access and high quality cycle parking also needs to be provided, for customers as well as employees.
R2
Agree that clear pedestrian connections between the site and the High Street are needed.
Good cycle access and cycle parking must also be provided.
There is a need to consider access needs to the site by different modes. A planned highway improvement scheme will make Clarendon Road one-way (NE-SW only) from Beechen Grove to High Street, with a contraflow cycle lane. Access to the street will be restricted by a Traffic Regulation Order to buses, taxis, cycles, 'blue badge' vehicles, and other vehicles 'for access only' to premises. All accessing vehicles will need to leave either via High Street or Watford House Lane (private road) for those accessing that area.
Development of this site should complement public realm enhancements proposed or already delivered on Clarendon Road and the High Street.
R3
Good cycle access and storage facilities must be provided, as well as good pedestrian links.
Developments at this location must take into account severance issues caused by the ring road for pedestrians and cyclists. Improvements required such as crossing improvements, new accesses into/through the site, should be delivered as part of the development or through developer contributions.
R4
Strong pedestrian and cycle links between this site and the town centre must be provided.
The quality of cycle routes and access to/from the west needs to be improved - eg. Market Street west of ring road and the Hornets Gyratory.
H1
This site is in close proximity to Bushey Station and includes its car park.
Opportunities to upgrade access to the station by non-car modes should be pursued.
Need to consider quantity and quality of cycle parking and cycle access to station from surrounding area.
Cycle access and cycle parking provision at Bushey station should be improved as part of any car parking replacement/improvement scheme.
Bushey Arches is a known congestion hotspot. Impacts of development on Bushey Arches must be considered and mitigation provided. This should include contributions to needed improvements to key walking and cycling routes and passenger transport infrastructure in the area.
H2
The ring road causes significant severance to people travelling by foot and cycle. Particular issues have been reported for people with visual impairments.
Improved cycle and pedestrian links to town centre and to Watford High Street and Watford Junction stations are needed from the site.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
H3
This site is about half mile from both the proposed Vicarage Road Met Line station and Watford High Street station, which is 10 to 12 minutes walking time.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
Vicarage Road is a busy road without dedicated cycle facilities. As such improvements to this route for cyclists should be considered. Developer contributions to improving cycle routes may be appropriate.
H5
The traffic impact on west Watford's road network needs to be considered and mitigated.
Cycle and pedestrian links into the site from different directions are required.
Adequate cycle storage must also be provided for existing and high predicted future levels.
Cycle infrastructure and the pedestrian environment of the surrounding area needs consideration.
H9
The impact of development at this site on the road network must be considered and mitigated if needed, including Rickmansworth Road and West Watford.
Good cycle links are needed including between the site, the town centre, and Ascot Road.
Bus services and infrastructure, including linking to new Cassiobridge Met Line station.
Bus services in this area may well be subject to change following the loss of the underground station. Development of this site and any forthcoming S106 contributions would provide the opportunity for an assessment to be made of potential improvements to bus services so this site remains connected to key destinations.
E1
High quality, secure cycle provision is needed at business premises.
Although the Ebury Way provides a good cycle route to the site, this will not be suitable for use all year round, at any time of day. As such improvements to the A412 corridor cycle infrastructure should be explored and provided. Developer contributions may be appropriate.
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
E2
Cycle and pedestrian routes through the site need improvement;
Via Watford Junction SPA site, there is a need to reduce severance and improve pedestrian and cycle connectivity to Watford Junction station and Clarendon Road.
WBC also needs to consider the implications of the Colonial Way Link road on development at site E2.
There is a need to consider potential transport implications of this site and the Watford Junction masterplan as a whole, including traffic accessing any new station multi-storey car parks, and the impact on the road network (eg. Colonial Way, Stephenson's Way, Radlett Road, Link Road, A41/M1 junction...).
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions.
E4
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions and on footways.
E5
Needs to link with SPA2 Watford Junction.
Development will need to assess impacts on road network and car parking demand in surrounding area.
Quality of pedestrian and cycle environment and urban realm on Clarendon Road should be considered and opportunities to enhance in consistent, coherent way should be explored to promote sustainable travel and improve route between town and Watford Junction.
Buildings will need to provide adequate, high quality secure cycle parking. If low car parking, may need to increase requirements or leave space to expand provision as required.
G6
Any change in land use/ status/ access provision to the south of Caxton Way and the south and east of Greenhill Crescent should not be permitted until its ability to provide the link for sustainable modes between Tolpits Lane and Caxton Way required by paragraph 10.6.9 of the WBC Core Strategy has been fully explored and ruled out.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF
1.1
The traffic and transport impacts of the masterplan scheme have not been modelled and thereby understood. The Highway Authority is, therefore, unable to fully support the plan until those impacts are assessed and deliverable mitigation measures agreed. HCC is developing traffic and transport models of Watford as part of its work to create a Growth & Transport Plan for the area. These will be used to test the impacts of the Watford Junction and other development proposals on transport infrastructure and services individually and cumulatively.
As part of earlier work on this site the County Council had required the construction of a road and bridge linking Colonial Way and St Albans Road via Penn Road. The scheme to build it received outline DfT funding and included a passenger transport (coach) interchange on the northeast side of the station. If the link road and bridge are no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
1.2
Correct reference to 'Abbey Link' in map to 'Abbey Line'.
2.1
The Barriers plan acknowledges the severance created by the presence of the Abbey Line. As part of earlier work on this site the County Council had required the construction of a road over the Abbey Line linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.2
Policy T1 in the borough council's Core Strategy supports conversion of the Abbey Line from heavy to light rail operation.
Correct reference to 'Abbey Flyover' in Objectives to 'Abbey Line'.
2.3
Correct reference to 'Abbey train line' under Transport and Parking to 'Abbey Line'.
As part of earlier work on this site the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.4
Gross External Areas values are different to those in 5.1 Area Schedules.
3D views might benefit from road names for orientation.
2.7
As part of earlier work on this site, the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
It is recommended that all roads are usable by cycles to aid permeability.
The road hierarchy titles have different meanings in the Highway Authority's own existing hierarchy. As the design is refined it is recommended that confusion is avoided by using different names.
2.8
The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.
3.3
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
3.4
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
4.1
The County Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order that they can be considered in the emerging Watford Growth & Transport Plan. Joint working with the County Council will remain key in order to maximise access to appropriate funding streams and delivery programmes.
Special Policy Area 2 is zero-CIL-rated so that all planning obligations will be derived via Section 106 agreements with service providers.
4.2
An overall Travel Plan for the site will be required and one for each subsequent development area should be provided and agreed.
5.1
Total car parking number differs from that given in 2.4 and Station Quarter East breakdown (p 46).
Gross External Areas values are different to those in 2.4.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF VIABILITY APPRAISAL
4.2
The County Council is concerned about the unrealistically low estimates given in figure 4.1 for the costings of infrastructure required to mitigate the impact of the masterplan.
CROXLEY VIEW/ ASCOT ROAD STUDY
Introduction
Mention must be made of the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The need for a link both for Watford and Three Rivers grows as pressure to develop either side of the Ebury Way increases and its delivery should be seen as key to both authorities' Duty to Cooperate.
Plans
All plans refer to Watford County Council.
All plans show Croxley Green Business Park to the southwest of the masterplan area. This is correctly the Wolsey Business Park.
Most plans show the Grand Union Canal badged as the River Gade which runs to the south and east of it.
Some plans do not show the correct alignment of the Watford/ Three Rivers boundary.
Some plans erroneously label the NE corner of Croxley Common as Cassiobury Park Nature Reserve.
Masterplanning Strategy plan - asterisks and other labelling are not described and inconsistently applied.
Potential Development Sites plan
This omits to include the Tech Site (around Woodshots Meadow). This is subject to preapplication discussions now and should be considered with the adjacent sites as it is in Employment Policy Area E1 (Local Plan Part 2 appendix 1).
Proposed Vehicle and Pedestrian Movement plan
This omits the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The route currently being explored follows the cycle track between the Watford Enterprise Centre and number 27 Greenhill Crescent.
Historic environment, landscape and ecology
The County Council supports the overall policy intentions of the Local Plan covering landscape, ecology and the historic and built environment and provides the following comments to help strengthen these policies and their supplementary text.
Historic Environment
Development Management Policies
The County Council welcomes the Borough's consideration of the Historic Environment in Part 9 Urban Design and the Historic Environment. However, the historic environment should be referenced in line with the NPPF definition of heritage assets. In addition to historic buildings (both designated and undesignated), the historic environment of Watford includes archaeological remains, historic landscapes and historic parks. Therefore policies are needed to conserve the historic environment as whole, not just designated buildings, registered gardens and conservation areas as is currently stated.
Under Policy UD4, Archaeology, there appears to be repetition of the NPPF, the policy is unclear and should be re-written.
There is also reference to the conservation of heritage assets being secured by an archaeological Written Scheme of Investigation (WSI). Whilst the County Council welcomes the requirement for these documents and for them to include provision for publication and public dissemination of results where appropriate (NPPF 141), it is not clear if the WSI on its own is considered to be robust enough to secure appropriate conservation of the historic environment. Therefore it is unclear if this part too, is effective.
Watford Junction Draft Development Brief 2016
Paragraph 4.2 notes that a Heritage Statement and Desktop Archaeological Study may need to be submitted with any planning applications. However, it is unclear what is meant by a Heritage Statement. Also archaeological assessment may not be limited to a desktop study.
Site Allocations
An appraisal of the archaeological implications of development for the new areas identified in the Second Consultation document (2016) is summarised below.
1. Archaeology as a Development Constraint
N/A
2. Requirement for Pre-allocation Archaeological Assessment
The sites below have known archaeological remains within them or have significant archaeological potential by reason of their size and situation, such that there is a risk that archaeology could be a constraint on any development. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that archaeological assessments should be included within all development briefs and other proposals for the sites, before they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the sites, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent of archaeological remains that might be a constraint upon the principle of development of these sites.
Allocation numbers: SPA1, SPA4 and H9.
3. Requirement for Pre-application or Pre-determination Archaeological Assessment
The sites below have known archaeological remains within them or have archaeological potential. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that that pre-application or pre-determination archaeological assessments should be included within all development briefs and other proposals for the sites, if they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the proposals, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent
of archaeological remains worthy of preservation in situ, to enable the LPA to determine any specific application for development.
Allocation numbers: SPA 2, SPA3, SPA5, SPA6, MXD1, MXD3, R1, R2, R3, R4, H2, H3, H4, H 10, E1, E2, E3, E4, E5, E6.
4. Mitigation of archaeological impact by condition
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, any archaeological issues can probably be dealt with by condition, should planning permission be granted.
Allocation numbers: R5, CF1, H1, H5, H6, GT1.
5. No archaeological requirements
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, there are unlikely to be any archaeological implications. However this will depend on the details of any proposals and any new archaeological information.
Allocation numbers: MXD2, MXD4, H7, H8, H11.
Ecology
Development Management Policies
Policy SD15, External lighting, the County Council support the provisions set out in this policy and advise that there should be reference to the guidance provided by the Institute of Lighting Engineers which has been instrumental in seeking to reduce the impacts of artificial lighting within the environment.
Green Infrastructure, Biodiversity and Recreation, the County Council supports the reference to Green Infrastructure (GI).In defining GI there should also be reference to the provision of local food production as a key ecosystem service.
Policy G15, Trees, Woodlands and Hedgerows, this policy is supported in respect of highlighting ecological and cultural value of trees, woodlands and hedgerows. However, under paragraph 10.3, the reference to valuable habitats should be extended to include reference to ecological networks and corridors. Under paragraph 10.6 it should be clarified that replacing trees lost to development cannot compensate for the loss of biodiversity or amenity value in the short term.
Policy GI6, Protecting and Enhancing the Grand Union Canal, this policy is supported including the reference to enhancing biodiversity under paragraph 10.11. It is advised that the policy is extended to include a clause that seeks to improve the biodiversity of the canal corridor where possible. Development that would have an
adverse impact on the biodiversity of the canal would not be supported unless it can demonstrate provision of suitable mitigation or compensation.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, this policy is supported however recommend the following clarifications and amendments.
It is advised to make reference to the 'amenity value' of the river, specifically encouraging 'recreation' may increase disturbance to sensitive wildlife within river corridors. The term 'amenity' embraces visual and recreational importance without being too prescriptive or disruptive if more sensitive habitats or locations are affected an important consideration within this largely urban area.
With regards the provision of 'a corridor for wildlife and biodiversity,' the reference to biodiversity should be deleted as wildlife is biodiversity. With regards replacement structures and fish passage, liaison with the Environment Agency is essential if any such works are proposed. With regards access it should be designed in a way that also enables some undisturbed areas to be retained.
Policy GI9, Provision of Open Space and Play Space in Residential Development, aspects of this policy relevant to biodiversity are supported. The reference to green space typologies should be expanded to include allotments and community orchards, in order to reflect the types of functional sites which support both community and biodiversity benefits.
Biodiversity, it is not clear why this section is formatted differently to the preceding and subsequent sections. In particular it does not describe 'Why is this policy needed?' and 'what is it intended to do?' In setting out the need for the policy, it should reference the legislative requirements of statutorily protected sites and species which are a material consideration in planning, as well as the Duty placed on Local Authorities to have regard to conserving biodiversity in all of their functions as set out in the Natural Environment and rural Communities Act 2006. In setting out the intention of the policy there should also be reference to seeking to deliver the aims of the Local Nature Partnership - for which securing ecological resources, functions and services are a consideration when determining planning applications.
Under paragraph 10.37 the reference to the 'Biodiversity Plan' should be amended to reference to the 'Biodiversity Action Plan principles' (BAP). The BAP, nationally and locally, has ceased to be actively supported by National and Local Government, and has essentially been replaced by the Local Nature Partnership. However the principles underpinning it remain valid as statements and the intentions of the various habitat and species action plans are sound in themselves and could be followed if resources or interest permitted.
It is suggested that the statement under paragraph 10.39 should be amended as follows:
'This policy expects that where appropriate, development proposals will demonstrate the relative ecological value of a site before and after development. Proposals should follow the mitigation hierarchy and provide clear evidence of impacts and enhancements where appropriate, consistent with the aims of NPPF, BS42020
"Biodiversity - Code of Practice for Planning and Development'' and guidance provided by CIEEM. This will require sufficient detail and clarity to enable net losses and gains to be identified and monitored, consistent with the Code. Where unavoidable, Biodiversity Offsetting should be considered as a means to ensure there is no net loss of biodiversity resulting from development'.
Highlighting the specific use of Biodiversity Calculators such as the one mentioned in paragraph 10.39 can be a little misleading. BS42020 does not mention the use of biodiversity calculators, and taken out of context the results of such calculations can sometimes show net gains where there should be none (removal of ancient woodland for example cannot reasonably be compensated in the real world). Other wider landscape issues are also not always considered by these calculators; if the land is part of a wider corridor, or a biodiversity network for example. It has taken several years for Warwickshire County Council to incorporate their use in to the planning system and there is still not universal agreement on them.
The County Council would therefore advise caution on their avocation, but rather emphasise the need to prove that biodiversity has not been lost and in the most part enhanced through "appropriate methods in-line with BS42020".
Policy GI10 Managing Biodiversity in new Developments. The County Council supports Watford Borough Council's commitment to increasing biodiversity within the district. The Policy is consistent with other Hertfordshire Local Authorities, and in-line with the National Planning Policy Framework.
The following amendments are advised. There should be reference to avoiding negative impacts upon ' local ecological networks...,'as each site sits within a local environmental and should retain or enhance any existing ecological resources or corridors to and from adjacent sites.
'Compensation will only be considered as a last resort. Development proposals will be expected to evaluate the impact on local biodiversity where appropriate and propose measures to maintain and enhance biodiversity. This approach should follow the principles outlined within BS42020 "Biodiversity - Code of Practice for Planning and Development" or other measures of best practice, including Biodiversity Offsetting where necessary'.
The above wording embraces the mitigation hierarchy as well as defining means to achieve no net loss as sought by NPPF, without being too prescriptive.
It is considered that paragraph 10.40 regarding the biodiversity calculator is not needed if references requiring its specific use are otherwise removed. The County Council remain concerned that some caution needs to be taken regarding the generation of positive scores which indicate a net gain despite losses that may otherwise be considered unacceptable.
Site Allocations
Please refer to Appendix 1.
Landscape
Green Infrastructure, Biodiversity and Recreation, the policy framework for green infrastructure (GI) was significantly strengthened in Feb 2016 with the introduction of detailed Planning Policy Guidance. The guidance states that GI is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water and should be a key consideration in both local plans and planning decisions.
The Herts Landscape and Green Infrastructure Group is currently looking at GI delivery and practice across Hertfordshire with a view to presenting a project proposal to Herts Infrastructure Planning Partnership (HIPP) in November. The key aim of the project is to mainstream the delivery of GI through the local plan and development management processes. The outputs and deliverables of the project are currently being shaped and should help provide local planning authorities with a good practice approach to GI delivery, supported by robust evidence and case studies.
The Landscape Institute Position Statement for Green Infrastructure provides a widely supported definition of GI (assets and functions) and a comprehensive overview of the key benefits it can deliver, supported by case studies http://www.landscapeinstitute.org/policy/GreenInfrastructure.php
There is no reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans. (The strategies provide an opportunity to address cross boundary issues and meet the Duty to Cooperate. (Hertfordshire and GreenArc Area Strategic Highlights Plan (SHiP) and the All London Green Grid.)
There should be greater emphasis on GI in place-making and conserving and enhancing local distinctiveness. There should be reference to any local character assessments and the guidelines for managing change that should help shape proposals, and conserve and enhance local character.
At a national level there is also the National Character Areas produced by Natural England https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making, and at a regional level there is the East of England Landscape Framework http://landscape-east.org.uk/.
Where proposals are likely to result in landscape and visual effects a landscape and visual impact assessment, in line with industry good practice guidance (Landscape and Visual Impact Assessment third edition Landscape Institute and Institute for Environmental Management and Assessment) may be required as part of an application. The mitigation hierarchy should be referenced to ensure that proposals seek to avoid and minimise any negative effects.
The reference to Green Infrastructure under paragraph 10.1, is fully supported, however it is suggested to expand the definition to include reference to blue assets
such as the Grand Union Canal. Also suggest amend reference to 'mitigating climate change' to 'mitigating the effects of climate change.'
Under paragraph 10.3, it should be clear that biodiversity is not the only driver for Green Infrastructure; other key drivers include a single or multiple land-use functions and include waste/water management, recreation, food production, local distinctiveness etc.
Policy GI5, Trees, Woodlands and Hedgerows, the reference to the protection of trees in line with current British Standard Institute code of practice is fully supported, however the full title of the standard does not appear to be referenced and should be 'Trees in relation to design, demolition and construction' (BS5837:2012). In addition it is advised that where required by the planning authority, tree surveys, arboricultural impact assessments and method statements should all be carried out in compliance with this standard.
The policy should be expanded to include reference to the current hedgerow regulations, the provision of a landscape strategy, planting plans and specifications, and the provision of aftercare (long term management plans) and replacement of failures.
Policy GI6, Protecting and Enhancing the Grand Union Canal, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Yours sincerely,
Paul Donovan
Environment Department
Hertfordshire County Council
APPENDIX 1
Please find below a brief ecological assessment of the site allocations. A 'standard' template for each Site has been provided.
Ecosites do not have any form of status of importance, but are merely sites that we have some ecological information on - thus they do support some wildlife interest, at least at a local level. Whilst these sites are often a valuable starting point in identifying the county's wildlife resource, they do not meet the rigorous and quantifiable assessment criteria needed to identify them as non-statutory Local (County) Wildlife Sites.
SPA1 Town Centre
Recognised sites adjacent / close to Site: close to eastern end of Cassiobury Park Local Wildlife Site.
Other features: Little semi natural habitat present, possibly some mature trees.
Protected species: Probably bats, badger records to the west.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road)
Protected species: Unknown - no records
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA3 Health Campus (includes a Borough Council Depot and Waste Transfer Station at Wiggenhall Road)
Recognised nature sites within Site: The Lairage Land Local Wildlife Site (LWS) and Local Nature Reserve (LNR), Croxley Green Junction Sidings LWS, Oxhey Park River & Margins LWS; Riverside Road Waste Ground ecosite (local database site), The Island, off Cardiff Road ecosite, Oxhey Park ecosite
Recognised sites adjacent / close to Site: Horwoods Avenue Playground ecosite, Moor View ecosite, Cardiff Road Embankment ecosite.
Other features: includes village green - "Green situated between Riverside Road & the River Colne"
Protected species: Birds and Water voles.
Opportunities: High. Habitat management to maintain and enhance biodiversity interest, green infrastructure / corridors.
Ecological sensitivity: Medium to high depending on location.
Fundamental ecological constraint: Presumption to avoid development on Local Wildlife Sites, fragmentation of green corridor,
Loss of Farm Terrace allotment site - should be offset elsewhere as open space / community food growing / ecological resource.
SPA4 Lower High Street
Recognised sites adjacent / close to Site: Bushey Hall Farm ecosite, Oxhey Park ecosite.
Other features: "Recreation Allotments" village green.
Protected species: Unknown - no records. Birds in trees.
Opportunities: Limited as previously developed site. Potential green corridors along railways lines.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA5 Dome Roundabout (includes a Waste Transfer Station at Colne Way)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA6 Western Gateway (includes area of search ELAS221 in the Hertfordshire Waste Site Allocations Document)
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite, Ascot Road ecosite.
Recognised sites adjacent / close to Site: close to eastern end of Croxley Common Moor Site of Specific Scienttific Interest (SSSI) and LNR.
Other features: Grassland strip along eastern boundary with bordering trees.
Protected species: Unknown - no records.
Opportunities: Enhance green infrastructure corridor along eastern boundary.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds in trees.
The ecosites have largely been destroyed by development.
MXD1 North Watford library, Lemarie Centre for Charities, and health facilities (within SPA5)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
MXD2 The Brow
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
MXD3 Gas holder site (within SPA4)
Other features: River Colne borders the eastern boundary.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site. Potential to enhance the river margins as a green corridor.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in the trees.
Largely developed but riverside trees most important and scrub on site.
MXD4 Ascot Road
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite.
Other features: As well as the rough ground and bordering trees of the area to the west, the Site includes part of the school playing fields to the east, which is short mown amenity grassland. There are also some mature trees.
Protected species: Unknown - no records.
Opportunities: Potential enhancement of the areas of semi-natural habitat to improve green corridor connectivity.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds. Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R1 Sainsbury's and adjoining land
Other features: The north-eastern part of the Site includes an area of grassland and mature trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R2 Former TJ Hughes and adjoining land
Other features: Small area of amenity grassland on the north-eastern side.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R3 BT Telephone Exchange and adjoining Wellstones
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R4 Church Street Car Park and land fronting Market Street/Market Place
Other features: area of amenity grassland and scattered trees on the southern side.
Protected species: Unknown - no records.
Opportunities: Limited as predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R5 Charter Place centre and adjoining land onto the High Street
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
CF1 Community Facility Tolpits Lane.
Other features: Site appears to be rough grassland with scattered scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to enhance the habitats on site. The northern boundary is a wooded bank bordering the railway line. Maintain / enhance green corridor along railway.
Ecological sensitivity: Low - medium as semi-natural habitats on site.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H1 Land at Pinner Road
Other features: There are small areas of rough (possibly amenity) grassland with scrub and scattered trees.
Protected species: Unknown - no records.
Opportunities: Limited as a predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H2 Skatepark, Lower Derby Road
Other features: There is an area of grassland with trees in the north-west corner.
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a predominantly a previously developed site. Potential to maintain / enhance the semi-natural habitats on site for green corridor links to nearby habitats, river corridor and wooded railway banks.
Ecological sensitivity:
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H3 Vicarage Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H4 Telephone Exchange - First Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H5 Builder's Yard, Queens Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H6 Bill Everett Community Centre
Recognised sites adjacent / close to Site: adjacent to Long Spring and Harebreaks Wood (Watford) Local Wildlife Site and Local Nature Reserve.
Other features: some areas of grassland (probably amenity?) and occasional scattered trees.
Protected species: Bat roost in building nearby.
Opportunities: Potential to link woodland to the south to area to the north - depending on what the latter is like, as it appears to be bare ground on our aerial photographs.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H7 Rickmansworth Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H8 Garages- The Gossamers
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H9 Watford Station, Cassiobury Park Avenue
Recognised nature sites within Site: Cassiobury Park Avenue allotments ecosite.
Recognised sites adjacent / close to Site: close to "Gade Avenue" Local Wildlife Site.
Other features: Includes an area of allotment gardens and mature trees.
Protected species: Unknown - no records. Potential for bats and reptiles.
Opportunities: Maintain and enhance the green corridor link along the railway line.
Ecological sensitivity: Low - medium?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H10 Croxley View
Other features: Area of semi-natural grassland with scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to manage the existing habitats to maintain / improve biodiversity. Maintain as a green infrastructure link from open grasslands to the south towards the River Gade corridor and semi-natural habitats to the north
Ecological sensitivity: Low.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H11 Garages, Bowmans Green
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
GT1 Lands at Tolpits Lane
Other features: Area of rough grassland with bordering trees.
Protected species: Unknown - no records.
Opportunities: Limited, but part of semi-natural grassland complex in the area so potential for linking hedgerows. Any loss of grassland could be compensated for by enhancement elsewhere and landscaping may provide additional buffering habitats locally if this site were to be developed as such.
Ecological sensitivity: Low?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
E1 Watford Business
Recognised sites adjacent / close to Site: adjacent to Croxley Common Moor Site of Special Scientific Interest (SSSI and Local Nature Reserve (LNR) and Commonland; adjacent to Ascot Road Car Park and Waste ecosite, adjacent to Ascot Road ecosite; close to Ascot Road Scrub Local Wildlife Site.
Other features: Some areas with trees.
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
Part of the edge of this currently provides a valuable buffer and boundary edge to Croxley Common Moor SSSI and LNR. We would object to any development which further degraded this boundary habitat, although much of the former area has already been lost to hard surfacing.
E2 Imperial Way / Colonial
Protected species: Limited as a previously developed site.
Opportunities: Low.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E3 Fishers
Recognised nature sites within Site: Cardiff Road Embankment ecosite.
Recognised sites adjacent / close to Site: adjacent to Croxley Green Junction Sidings Local Wildlife Site.
Other features: Disused railway line to the west is bordered by woody vegetation.
Protected species: Unknown - no records.
Opportunities: Potential green corridors east / west across the site and along the western boundary. Maintain a buffer against LWS to the south.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
E4 Greycaine Road / Odhams / Sandown Road
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E5 Clarendon Road / Station Road / Bridle Path Office Area
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E6 Leavesden Studios - the Island site
Recognised nature sites within Site: part of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Recognised sites adjacent / close to Site: adjacent to the rest of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Other features: Semi-improved grassland habitat, part of a much larger complex.
Protected species: Badger setts on site and nearby.
Opportunities: Linking habitats to similar adjacent grasslands.
Ecological sensitivity: Low - medium.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species, with particular attention to badgers

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 855

Received: 03/10/2016

Respondent: Hertfordshire County Council SLU

Representation Summary:

A number of minor typo, clarifications and corrections identified.

Full text:

Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
With regard to Policy SPMX1: Special Policy Areas, the council is pleased to see the insertion of reference to the county council's documents. The text should however refer to the' Waste Local Plan' which includes both the Waste Core Strategy and Development Management Policies document and the Waste Site Allocations document.
With regard to Special Policy Area 2: Watford Junction, the council is pleased to see that there is reference to the need to safeguard the rail aggregates depot at Orphanage Road.
Further information on SPA2 is contained in Appendix I: Site Schedules of the Local Plan Part 2. The council is pleased that the rail aggregates depot is included as a
Spatial Planning and the Economy
Environment Department
Hertfordshire County Council
County Hall
Hertford
Hertfordshire
SG13 8DN
paul.donovan@hertfordshire.gov.uk
01992 556289
Planning Policy Team,
Room 65,
Watford Borough Council,
Town Hall,
Watford,
Herts,
WD17 3EX.
development consideration where it states 'This will need to be retained, or a new comparable facility provided within the local area'. However it should be noted that the text should refer to the 'rail aggregates depot' as opposed to the 'waste aggregates depot'.
However, in practice, taken together with the masterplan and accompanying viability report, there appears to be a strong likelihood that the rail aggregates depot is not to be retained on site and the collective impact of the Local Plan is not to safeguard the rail aggregates depot. Given this, the Inspector may well wish to see what evidence exists with regard to securing a replacement facility and currently no such evidence accompanies the Local Plan. As a consequence, there is considerable uncertainty in relation to whether the Local Plan satisfies potentially all soundness tests.
With regard to SPA6 Western Gateway, this includes ELAS221 and it is also worth pointing out that the areas designated as PS2 and PS3 potential in the Croxley View/Ascot Road Masterplanning Study are also located in ELAS221.
It is agreed that it is useful to insert text in relation to the circular economy as part of the waste section under paragraph 3.30, supporting text to Policy SD10: Waste. The second bullet point should state 'drive greater resource productivity.'
The relevant policy basis has been applied in the waste section and the Watford Local Plan with regard to responsibility for waste management. Whilst there appears to no longer be specific reference to Waste Policy 12, there is text to cover the use of this policy along with others within the Waste Core Strategy and Development Management Polices document. One comment to make is that in the wider context of the Watford Local Plan with there also being reference to ELAS221, the text in paragraph 3.30 should refer to the Waste Local Plan, which covers policies within the Waste Core Strategy and Development Management Policies document, adopted November 2012 and the Waste Site Allocations document, adopted July 2014.
Watford Junction Development Brief
As previously stated, most recently in respect of the Infrastructure Delivery Plan, the key matter of concern to the Minerals and Waste Planning Authority is the impact that any proposed development may have upon the safeguarded rail aggregate depot located at Orphanage Road, Watford which is a current operational facility.
The planning policy status, as detailed within the introduction of the brief, refers to consideration being had to national planning policy and the Watford Borough Council Local Plan. To ensure that the Development Plan has been considered as a whole the brief needs to also refer to the Minerals Local Plan and the Waste Local Plan. In terms of national policy, there is the need to ensure that the NPPF is considered in respect of para 143 which states that Mineral Planning Authorities should safeguard existing, planned and potential rail heads, so as to prevent their redevelopment for other uses and loss of the mineral infrastructure. This safeguarding is also applicable to storage, handling and processing facilities associated with them.
It is considered that due to the location of the rail aggregate depot within the development brief area that the county council's Minerals Local Plan 2002-2016, adopted March 2007 is also considered with specific regard to minerals policy 10: Railheads and Wharves. The Minerals Local Plan is being reviewed at present. It is envisaged, due to the requirement of the NPPF, that there will be a policy on Rail heads and Wharves in the Draft Minerals Local Plan.
The siting of the rail aggregate depot is shown within the county council's Mineral Consultation Area Supplementary Planning Document, adopted November 2007. The consultation area covers the majority of the Special Policy Area 2 Watford Junction. In accordance with the NPPF and Minerals Local Plan, in respect of minerals policy 10 the county council seeks to safeguard the rail aggregate depot which continues to serve as a sustainable mode of transporting minerals over long distances and the concrete batching facility which this site also supports. Given that the site is viable for use as a rail aggregate depot, its retention is expected unless the facility can be satisfactorily relocated within the development proposals in terms of operational requirements and environmental criteria or it has been or will be replaced in an alternative location.
The development brief identifies the rail aggregate depot as being a 'weakness' for the redevelopment of Watford junction in the SWOT analysis in paragraph 2.1. Minerals are important to the economy. Aggregate is needed to facilitate development and volumes of construction material being transported by rail in increasing. In light of this it could be considered that a rail aggregate depot in close proximity to the construction project could be considered to be a strength.
The issue of addressing such a 'weakness' is not however further expanded upon. It is clear from the illustrative masterplan that the retention of the rail aggregate depot is not part of the scheme. Whilst it is intended to be flexible enough to accommodate alternative layouts so long as it achieves the guiding principles and core ambitions of the masterplan, there does not appear to be sufficient scope to accommodate the existing or a relocated rail aggregate depot within the redevelopment area. As such this leaves the only option of relocating the rail aggregate depot offsite at another location along the railway line.
There is the need to establish an alternative well positioned strategic location for the rail aggregate depot to ensure its continued operation for imports and exports of minerals and secondary and recycled aggregates. The SWOT analysis in the development brief states that there is a 'weakness' in terms of a lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling. The Borough Council is referred back to paragraph 143 of the NPPF, the adopted Minerals Local Plan and specifically minerals policy 10 and the adopted Minerals Consultation Area SPD as detailed above in terms of the clarity for the safeguarding of the rail aggregates depot at Orphanage Road.
The brief states under the land use and quantum section of Station Quarter East within paragraph 3.4 that the development will be required to relocate the Rail Aggregates Depot within the local area, in consultation with Hertfordshire County Council and the operator of the site. The County Council will continue to work with the Borough Council in respect of this matter. The land use and quantum section in
paragraph 3.4 should also refer to the need to work with Network Rail with regard to the relocation of the Rail Aggregates Depot. The County Council understands that Network Rail Freight Management has been consulted and will provide comments to this consultation. There is however no further detail with regard a precise location having been secured.
To this end the relocation of the rail aggregate depot is fundamental to the delivery of the masterplan. A statement should be made in the delivery section of the brief at paragraph 4.1 specifically in relation to the requirement to ensure that the relocation of the rail aggregates depot forms part of the Watford Junction Delivery Plan.
Croxley View/Ascot Road Masterplanning Study
The Croxley View/Ascot Road Masterplanning Study has been considered by the county council as Waste Planning Authority due to the proximity of redevelopment to the Employment Land Area of Search (ELAS) 221 Watford Business Park.
The masterplan aims to build on the policy foundations of the district Local Plan Core Strategy Policy SPA6 to facilitate redevelopment. The location of potential residential development is shown within the Masterplanning Study to be directly adjacent to ELAS221 as designated within the county council's Waste Site Allocations document 2011-2026, adopted July 2014.
It is considered that ELAS that are predominantly used for general industry (B2) and storage and distribution (B8) are compatible with waste management uses. ELAS221 contains B1 and B2 uses and as such is acceptable in principle for a range of potential waste uses listed in the general waste brief during the 15 year plan period 2011-2026. Further planning guidance into the suitability of waste related development on the identified ELAS is within the ELAS Supplementary Planning Document, adopted November 2015. For this area, the Supplementary Planning Document states 'only enclosed waste transfer stations and materials recovery facilities that handle dry recyclables would be acceptable, along with enclosed inert waste recycling facilities. No other potential uses that may generate a leachate or liquor, which poses a risk to groundwater resources would be appropriate'.
The council does not wish to see the loss of identified ELAS for non-waste uses in order to safeguard it for future potential waste uses that may be sited in this location. Whilst the residential development would not directly encroach onto the ELAS, the council is mindful that the residential development is identified along the eastern boundary of the designated site and as a result there could be the potential for indirect impact upon the siting of waste uses within the ELAS.
The Waste Local Plan does not rely on the need for all land within ELAS across the county for the delivery of waste uses. However the cumulative loss of ELAS to non-waste uses is monitored and the safeguarding of remaining ELAS land is important to ensure there is a sufficient amount of land that could come forward for waste management facilities in the future, particularly with additional growth resulting in an increase in waste produced which needs to be managed.
There are currently no extant planning permissions on land directly adjacent to the masterplanned residential development to be aware of. The nearest waste site is the Household Waste Recycling Centre at Caxton Way in ELAS221. There is sufficient land remaining in ELAS221 to be brought forward for waste management uses.
The County Council does not wish to object to the masterplanning for potential residential development at this stage but reserves its right to object to future planning applications adjacent to the ELAS should a waste site be development in advance of residential. The reason for this would be to safeguard any waste use(s) under waste policy 5: Safeguarding of Sites within the Waste Core Strategy and Development Management Policies document 2011-2026, adopted November 2012. Further discussions would need to take place in the event that negative effects are identified that would restrict the waste operation to continue. A buffer between two land uses or mitigation measures in some cases may be appropriate to allow opposing land uses to exist in harmony adjacent to each other.
The County Council's adopted Waste Core Strategy and Development Management Policies document, does not stipulate a distance whereby other development in close proximity to a safeguarded waste site should be discouraged, the 2004 ODPM document: Planning for Waste Management Facilities: A Research Study states that for waste transfer stations: "sites closer than 250m from residential, commercial or recreational areas should be avoided." This guidance was used in the production of the Waste Site Allocations document. Depending upon the location of any potential future waste management facility within the ELAS, there is the potential that facilities may well be sited closer than the suggested 250m to any future housing.
Transport
Overarching/ general comments
Watford and the surrounding transport network face growing challenges as a result of the desired housing and economic growth in the area and increasing demand for travel. The County Council is developing a countywide transport model that will help all local authorities in the county to plan positively for growth and infrastructure investment in a way that safeguards the health and wellbeing of our communities and the environment. Already the model has identified notably worsening congestion issues in the Watford area as a result of planned growth. The next outputs of the enhanced Watford area version of the model will be available by the end of October 2016. The existing model is already available to Watford Borough Council to test development scenarios and proposals from the Local Plan.
In parallel with this, the County Council is developing a Growth & Transport Plan for South West Hertfordshire, which includes Watford and the surrounding towns and transport networks that make up a coherent area of travel demand. The Growth & Transport Plan will put forward packages of transport interventions to respond to strategic transport challenges and objectives for the area, derived through robust evidence analysis and engagement with stakeholders. Watford Borough Council officers and members have been involved from the early stages in GTP workshops
at key stages. The GTP is about identifying needs, planning for and enabling investment and delivery of a transport network and public realm that will support a healthy economy, environment and communities.
As a result of the current ongoing work being incomplete, at this stage there is insufficient evidence available to assess the implications of Local Plan Part 2 on the transportation network. As a consequence, there is uncertainty in relation to the mitigations that will be required to support the proposals and we remain in doubt that it potentially satisfies all soundness tests.
Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
Contents
'Appendix I - Site Allocations' is referred to later as 'Site Schedule'
'Appendix L' and 'Appendix M' missing from content list
Policy SD10
Refuse collection vehicles must be able to stop within the 'maximum refuse carry distance' specified by the Local Planning Authority or within 25m of any bin storage area, whichever is the lesser distance. Residents should not have to carry their rubbish more than 30m to a storage point. (Sources BS5906:2005 and Schedule 1 Part H Building Regulations)
Policy TLC14
On-street parking continues to need to be managed to manage congestion and avoid hazards, particularly at junctions.
Policy HS7
The subjective "undue pressure" on on-street parking should not lead to increased congestion and / or hazards on the highway network, particularly at junctions.
The siting of bin stores should not adversely impact on the operation of the highway network.
Policy HS8
The Highway Authority recommends that consideration of deliveries is made explicit in this policy.
6.9 and Policy EMP5
The County Council supports urban realm enhancement of Clarendon Road to encourage walking and cycling and improve the key pedestrian route between the town centre and Watford Junction.
Consideration should be given to amending the policy wording to explicitly include an expectation for development along Clarendon Road to contribute towards urban realm enhancements directly through works delivered or through developer contributions to fund such works.
Policy T6
The County Council is supportive of the zonal approach to car parking guidance to encourage lower car ownership and usage in more accessible zones. The principle of 'Car Lite' development in the most accessible areas, within 5 or so minutes' walk of a major transport hub, is also supported as long as the needs of disabled drivers and visitors are considered.
Lower car parking provision must be accompanied by appropriate restrictions in surrounding residential streets and any public car parks to prevent spill-over parking. In order for this approach to lowering car usage to be successful, there needs to be parallel investment in infrastructure (eg significantly better cycle and bus routes) and urban realm improvements to support and actively encourage alternative modes of travel.
The County Council welcomes the requirements for car club spaces in the SPAs and where parking does not meet the guidance.
Policy T8 and Appendix H
The policy on cycle parking provision and the stipulations relating to quality contained in the policy is welcomed. Adequate cycle storage must also be provided for existing and high predicted future levels.
A small change is recommended to allow for cycle parking provision for dwelling houses to be in a private garage as well as within the private garden area - subject to the dimensions of the garage being adequate to accommodate cycles as well as any vehicle.
However, the policy only specifies one long-term space per unit (regardless of size or location) where there is no garage or shed. In some instances such as within SPA2 and SPA6 where housing will be in the form of apartments and where there will be reduced car parking, it may be necessary for additional capacity for cycle storage beyond one space per unit, especially for larger flats or any flats without car parking provided.
Policy UD3
Structures abutting and overhanging the public highway will need the approval of the Highway Authority (HCC) as will illumination visible from the highway.
Policy TB1
From a transport network and user perspective, locations near to major passenger transport hubs, offering good interchange between different services and modes, are the most appropriate for denser development (i.e. taller buildings). However, development proposals should all be subject to Core Strategy policies T2-T5 to ensure that their impacts are understood and mitigated.
In order for such development to be acceptable, there must be adequate and appropriate improvements to transport infrastructure and urban realm within the site and in the wider area, to ensure no significant adverse impact on the highway and passenger transport networks, as a direct, indirect or cumulative result of development at the site and in the Borough as a whole.
Policy TB2
Suggest change to text at 8. Transport, parking and infrastructure:
'The design should detail a transport strategy for the proposed development to include how cycle parking, car parking, cycle permeability and pedestrian permeability have been integrated into the overall design. This should be based on a Transport Assessment and should avoid negative impacts on the public realm. The scheme will also need to demonstrate that the required infrastructure and utility capacity has been fully appraised.'
Appendix G
Parking bay dimensions only seem to consider residential element, parking bay at 2.4 x 4.8m is fine for standard bay but dimensions of other bays should be provided e.g. parallel arrangement. The garage dimensions provided are 3m x 5.5m whereas the industry standards are 3m x 6m (MfS para 8.3.41). Should minimum circulatory space for car parks be covered here (i.e. 6m) or will it be covered elsewhere?
SPA1
The ring road constrains pedestrian and cycle accessibility to the heart of the town centre. nb includes EMP5, R1, R2, R3, R4, R5. See Highway Authority comments in regard to each of these.
SPA2
Any development within the Watford Junction SPA should ensure that connectivity for pedestrians and cyclists is improved across the site, between the site and the town centre and on other key routes to Watford Junction Station.
Development of the station building, forecourt and car parks must address current limitations including capacity, access and circulation issues, for pedestrians, cyclists, buses, bus users, taxis, as well as users of the car parks. Opportunities to make Watford Junction an attractive and functional transport interchange that can accommodate future growth should be maximised.
See Highway Authority comments on Draft Development Brief (below).
SPA3
Good quality cycle and pedestrian links through the site and between the site and surrounding area and key destinations (town centre, Vicarage Road MLX station, local schools etc.) must be provided, or contributions to support infrastructure improvements in the wider area made through developer contributions.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
SPA4
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
Support improvements to green infrastructure and public realm as a complement to improvements to pedestrian and cycle links.
Flooding is a known issue affecting this area. Any development in this area should be designed to avoid and mitigate flood risk. Sustainable drainage approaches and green infrastructure should be used where appropriate to reduce and manage flood risk.
SPA5
Development at this location will need to consider transport impacts on the highway network, including operation of the Dome roundabout and St Albans Road notably at peak times. Also junctions including M25/A405/M1, and M1/A41.
There is a need to improve cycle, pedestrian and passenger transport connectivity to the site, and between the site and the town centre and Watford Junction.
It is recognised that the Abbey Line (North Watford) station is closer to the site, but there are limitations to this service at present which will reduce its attractiveness as an alternative to the car for journeys to Watford Junction or St Albans Abbey stations.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
There is a typo on second bullet point - should read 'improve air quality'.
SPA6
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Cycle improvements on Rickmansworth Road may be required as this is a key corridor between Rickmansworth and Watford.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
Secure, high quality cycle parking is needed at the proposed Cassiobridge station, as well as within the employment premises.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
See Highway Authority comments on Masterplanning Study (below)
MXD3
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
R1
It is agreed that robust pedestrian links with the town centre should form part of the new development at this location.
Good cycle access and high quality cycle parking also needs to be provided, for customers as well as employees.
R2
Agree that clear pedestrian connections between the site and the High Street are needed.
Good cycle access and cycle parking must also be provided.
There is a need to consider access needs to the site by different modes. A planned highway improvement scheme will make Clarendon Road one-way (NE-SW only) from Beechen Grove to High Street, with a contraflow cycle lane. Access to the street will be restricted by a Traffic Regulation Order to buses, taxis, cycles, 'blue badge' vehicles, and other vehicles 'for access only' to premises. All accessing vehicles will need to leave either via High Street or Watford House Lane (private road) for those accessing that area.
Development of this site should complement public realm enhancements proposed or already delivered on Clarendon Road and the High Street.
R3
Good cycle access and storage facilities must be provided, as well as good pedestrian links.
Developments at this location must take into account severance issues caused by the ring road for pedestrians and cyclists. Improvements required such as crossing improvements, new accesses into/through the site, should be delivered as part of the development or through developer contributions.
R4
Strong pedestrian and cycle links between this site and the town centre must be provided.
The quality of cycle routes and access to/from the west needs to be improved - eg. Market Street west of ring road and the Hornets Gyratory.
H1
This site is in close proximity to Bushey Station and includes its car park.
Opportunities to upgrade access to the station by non-car modes should be pursued.
Need to consider quantity and quality of cycle parking and cycle access to station from surrounding area.
Cycle access and cycle parking provision at Bushey station should be improved as part of any car parking replacement/improvement scheme.
Bushey Arches is a known congestion hotspot. Impacts of development on Bushey Arches must be considered and mitigation provided. This should include contributions to needed improvements to key walking and cycling routes and passenger transport infrastructure in the area.
H2
The ring road causes significant severance to people travelling by foot and cycle. Particular issues have been reported for people with visual impairments.
Improved cycle and pedestrian links to town centre and to Watford High Street and Watford Junction stations are needed from the site.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
H3
This site is about half mile from both the proposed Vicarage Road Met Line station and Watford High Street station, which is 10 to 12 minutes walking time.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
Vicarage Road is a busy road without dedicated cycle facilities. As such improvements to this route for cyclists should be considered. Developer contributions to improving cycle routes may be appropriate.
H5
The traffic impact on west Watford's road network needs to be considered and mitigated.
Cycle and pedestrian links into the site from different directions are required.
Adequate cycle storage must also be provided for existing and high predicted future levels.
Cycle infrastructure and the pedestrian environment of the surrounding area needs consideration.
H9
The impact of development at this site on the road network must be considered and mitigated if needed, including Rickmansworth Road and West Watford.
Good cycle links are needed including between the site, the town centre, and Ascot Road.
Bus services and infrastructure, including linking to new Cassiobridge Met Line station.
Bus services in this area may well be subject to change following the loss of the underground station. Development of this site and any forthcoming S106 contributions would provide the opportunity for an assessment to be made of potential improvements to bus services so this site remains connected to key destinations.
E1
High quality, secure cycle provision is needed at business premises.
Although the Ebury Way provides a good cycle route to the site, this will not be suitable for use all year round, at any time of day. As such improvements to the A412 corridor cycle infrastructure should be explored and provided. Developer contributions may be appropriate.
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
E2
Cycle and pedestrian routes through the site need improvement;
Via Watford Junction SPA site, there is a need to reduce severance and improve pedestrian and cycle connectivity to Watford Junction station and Clarendon Road.
WBC also needs to consider the implications of the Colonial Way Link road on development at site E2.
There is a need to consider potential transport implications of this site and the Watford Junction masterplan as a whole, including traffic accessing any new station multi-storey car parks, and the impact on the road network (eg. Colonial Way, Stephenson's Way, Radlett Road, Link Road, A41/M1 junction...).
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions.
E4
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions and on footways.
E5
Needs to link with SPA2 Watford Junction.
Development will need to assess impacts on road network and car parking demand in surrounding area.
Quality of pedestrian and cycle environment and urban realm on Clarendon Road should be considered and opportunities to enhance in consistent, coherent way should be explored to promote sustainable travel and improve route between town and Watford Junction.
Buildings will need to provide adequate, high quality secure cycle parking. If low car parking, may need to increase requirements or leave space to expand provision as required.
G6
Any change in land use/ status/ access provision to the south of Caxton Way and the south and east of Greenhill Crescent should not be permitted until its ability to provide the link for sustainable modes between Tolpits Lane and Caxton Way required by paragraph 10.6.9 of the WBC Core Strategy has been fully explored and ruled out.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF
1.1
The traffic and transport impacts of the masterplan scheme have not been modelled and thereby understood. The Highway Authority is, therefore, unable to fully support the plan until those impacts are assessed and deliverable mitigation measures agreed. HCC is developing traffic and transport models of Watford as part of its work to create a Growth & Transport Plan for the area. These will be used to test the impacts of the Watford Junction and other development proposals on transport infrastructure and services individually and cumulatively.
As part of earlier work on this site the County Council had required the construction of a road and bridge linking Colonial Way and St Albans Road via Penn Road. The scheme to build it received outline DfT funding and included a passenger transport (coach) interchange on the northeast side of the station. If the link road and bridge are no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
1.2
Correct reference to 'Abbey Link' in map to 'Abbey Line'.
2.1
The Barriers plan acknowledges the severance created by the presence of the Abbey Line. As part of earlier work on this site the County Council had required the construction of a road over the Abbey Line linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.2
Policy T1 in the borough council's Core Strategy supports conversion of the Abbey Line from heavy to light rail operation.
Correct reference to 'Abbey Flyover' in Objectives to 'Abbey Line'.
2.3
Correct reference to 'Abbey train line' under Transport and Parking to 'Abbey Line'.
As part of earlier work on this site the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.4
Gross External Areas values are different to those in 5.1 Area Schedules.
3D views might benefit from road names for orientation.
2.7
As part of earlier work on this site, the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
It is recommended that all roads are usable by cycles to aid permeability.
The road hierarchy titles have different meanings in the Highway Authority's own existing hierarchy. As the design is refined it is recommended that confusion is avoided by using different names.
2.8
The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.
3.3
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
3.4
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
4.1
The County Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order that they can be considered in the emerging Watford Growth & Transport Plan. Joint working with the County Council will remain key in order to maximise access to appropriate funding streams and delivery programmes.
Special Policy Area 2 is zero-CIL-rated so that all planning obligations will be derived via Section 106 agreements with service providers.
4.2
An overall Travel Plan for the site will be required and one for each subsequent development area should be provided and agreed.
5.1
Total car parking number differs from that given in 2.4 and Station Quarter East breakdown (p 46).
Gross External Areas values are different to those in 2.4.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF VIABILITY APPRAISAL
4.2
The County Council is concerned about the unrealistically low estimates given in figure 4.1 for the costings of infrastructure required to mitigate the impact of the masterplan.
CROXLEY VIEW/ ASCOT ROAD STUDY
Introduction
Mention must be made of the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The need for a link both for Watford and Three Rivers grows as pressure to develop either side of the Ebury Way increases and its delivery should be seen as key to both authorities' Duty to Cooperate.
Plans
All plans refer to Watford County Council.
All plans show Croxley Green Business Park to the southwest of the masterplan area. This is correctly the Wolsey Business Park.
Most plans show the Grand Union Canal badged as the River Gade which runs to the south and east of it.
Some plans do not show the correct alignment of the Watford/ Three Rivers boundary.
Some plans erroneously label the NE corner of Croxley Common as Cassiobury Park Nature Reserve.
Masterplanning Strategy plan - asterisks and other labelling are not described and inconsistently applied.
Potential Development Sites plan
This omits to include the Tech Site (around Woodshots Meadow). This is subject to preapplication discussions now and should be considered with the adjacent sites as it is in Employment Policy Area E1 (Local Plan Part 2 appendix 1).
Proposed Vehicle and Pedestrian Movement plan
This omits the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The route currently being explored follows the cycle track between the Watford Enterprise Centre and number 27 Greenhill Crescent.
Historic environment, landscape and ecology
The County Council supports the overall policy intentions of the Local Plan covering landscape, ecology and the historic and built environment and provides the following comments to help strengthen these policies and their supplementary text.
Historic Environment
Development Management Policies
The County Council welcomes the Borough's consideration of the Historic Environment in Part 9 Urban Design and the Historic Environment. However, the historic environment should be referenced in line with the NPPF definition of heritage assets. In addition to historic buildings (both designated and undesignated), the historic environment of Watford includes archaeological remains, historic landscapes and historic parks. Therefore policies are needed to conserve the historic environment as whole, not just designated buildings, registered gardens and conservation areas as is currently stated.
Under Policy UD4, Archaeology, there appears to be repetition of the NPPF, the policy is unclear and should be re-written.
There is also reference to the conservation of heritage assets being secured by an archaeological Written Scheme of Investigation (WSI). Whilst the County Council welcomes the requirement for these documents and for them to include provision for publication and public dissemination of results where appropriate (NPPF 141), it is not clear if the WSI on its own is considered to be robust enough to secure appropriate conservation of the historic environment. Therefore it is unclear if this part too, is effective.
Watford Junction Draft Development Brief 2016
Paragraph 4.2 notes that a Heritage Statement and Desktop Archaeological Study may need to be submitted with any planning applications. However, it is unclear what is meant by a Heritage Statement. Also archaeological assessment may not be limited to a desktop study.
Site Allocations
An appraisal of the archaeological implications of development for the new areas identified in the Second Consultation document (2016) is summarised below.
1. Archaeology as a Development Constraint
N/A
2. Requirement for Pre-allocation Archaeological Assessment
The sites below have known archaeological remains within them or have significant archaeological potential by reason of their size and situation, such that there is a risk that archaeology could be a constraint on any development. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that archaeological assessments should be included within all development briefs and other proposals for the sites, before they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the sites, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent of archaeological remains that might be a constraint upon the principle of development of these sites.
Allocation numbers: SPA1, SPA4 and H9.
3. Requirement for Pre-application or Pre-determination Archaeological Assessment
The sites below have known archaeological remains within them or have archaeological potential. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that that pre-application or pre-determination archaeological assessments should be included within all development briefs and other proposals for the sites, if they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the proposals, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent
of archaeological remains worthy of preservation in situ, to enable the LPA to determine any specific application for development.
Allocation numbers: SPA 2, SPA3, SPA5, SPA6, MXD1, MXD3, R1, R2, R3, R4, H2, H3, H4, H 10, E1, E2, E3, E4, E5, E6.
4. Mitigation of archaeological impact by condition
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, any archaeological issues can probably be dealt with by condition, should planning permission be granted.
Allocation numbers: R5, CF1, H1, H5, H6, GT1.
5. No archaeological requirements
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, there are unlikely to be any archaeological implications. However this will depend on the details of any proposals and any new archaeological information.
Allocation numbers: MXD2, MXD4, H7, H8, H11.
Ecology
Development Management Policies
Policy SD15, External lighting, the County Council support the provisions set out in this policy and advise that there should be reference to the guidance provided by the Institute of Lighting Engineers which has been instrumental in seeking to reduce the impacts of artificial lighting within the environment.
Green Infrastructure, Biodiversity and Recreation, the County Council supports the reference to Green Infrastructure (GI).In defining GI there should also be reference to the provision of local food production as a key ecosystem service.
Policy G15, Trees, Woodlands and Hedgerows, this policy is supported in respect of highlighting ecological and cultural value of trees, woodlands and hedgerows. However, under paragraph 10.3, the reference to valuable habitats should be extended to include reference to ecological networks and corridors. Under paragraph 10.6 it should be clarified that replacing trees lost to development cannot compensate for the loss of biodiversity or amenity value in the short term.
Policy GI6, Protecting and Enhancing the Grand Union Canal, this policy is supported including the reference to enhancing biodiversity under paragraph 10.11. It is advised that the policy is extended to include a clause that seeks to improve the biodiversity of the canal corridor where possible. Development that would have an
adverse impact on the biodiversity of the canal would not be supported unless it can demonstrate provision of suitable mitigation or compensation.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, this policy is supported however recommend the following clarifications and amendments.
It is advised to make reference to the 'amenity value' of the river, specifically encouraging 'recreation' may increase disturbance to sensitive wildlife within river corridors. The term 'amenity' embraces visual and recreational importance without being too prescriptive or disruptive if more sensitive habitats or locations are affected an important consideration within this largely urban area.
With regards the provision of 'a corridor for wildlife and biodiversity,' the reference to biodiversity should be deleted as wildlife is biodiversity. With regards replacement structures and fish passage, liaison with the Environment Agency is essential if any such works are proposed. With regards access it should be designed in a way that also enables some undisturbed areas to be retained.
Policy GI9, Provision of Open Space and Play Space in Residential Development, aspects of this policy relevant to biodiversity are supported. The reference to green space typologies should be expanded to include allotments and community orchards, in order to reflect the types of functional sites which support both community and biodiversity benefits.
Biodiversity, it is not clear why this section is formatted differently to the preceding and subsequent sections. In particular it does not describe 'Why is this policy needed?' and 'what is it intended to do?' In setting out the need for the policy, it should reference the legislative requirements of statutorily protected sites and species which are a material consideration in planning, as well as the Duty placed on Local Authorities to have regard to conserving biodiversity in all of their functions as set out in the Natural Environment and rural Communities Act 2006. In setting out the intention of the policy there should also be reference to seeking to deliver the aims of the Local Nature Partnership - for which securing ecological resources, functions and services are a consideration when determining planning applications.
Under paragraph 10.37 the reference to the 'Biodiversity Plan' should be amended to reference to the 'Biodiversity Action Plan principles' (BAP). The BAP, nationally and locally, has ceased to be actively supported by National and Local Government, and has essentially been replaced by the Local Nature Partnership. However the principles underpinning it remain valid as statements and the intentions of the various habitat and species action plans are sound in themselves and could be followed if resources or interest permitted.
It is suggested that the statement under paragraph 10.39 should be amended as follows:
'This policy expects that where appropriate, development proposals will demonstrate the relative ecological value of a site before and after development. Proposals should follow the mitigation hierarchy and provide clear evidence of impacts and enhancements where appropriate, consistent with the aims of NPPF, BS42020
"Biodiversity - Code of Practice for Planning and Development'' and guidance provided by CIEEM. This will require sufficient detail and clarity to enable net losses and gains to be identified and monitored, consistent with the Code. Where unavoidable, Biodiversity Offsetting should be considered as a means to ensure there is no net loss of biodiversity resulting from development'.
Highlighting the specific use of Biodiversity Calculators such as the one mentioned in paragraph 10.39 can be a little misleading. BS42020 does not mention the use of biodiversity calculators, and taken out of context the results of such calculations can sometimes show net gains where there should be none (removal of ancient woodland for example cannot reasonably be compensated in the real world). Other wider landscape issues are also not always considered by these calculators; if the land is part of a wider corridor, or a biodiversity network for example. It has taken several years for Warwickshire County Council to incorporate their use in to the planning system and there is still not universal agreement on them.
The County Council would therefore advise caution on their avocation, but rather emphasise the need to prove that biodiversity has not been lost and in the most part enhanced through "appropriate methods in-line with BS42020".
Policy GI10 Managing Biodiversity in new Developments. The County Council supports Watford Borough Council's commitment to increasing biodiversity within the district. The Policy is consistent with other Hertfordshire Local Authorities, and in-line with the National Planning Policy Framework.
The following amendments are advised. There should be reference to avoiding negative impacts upon ' local ecological networks...,'as each site sits within a local environmental and should retain or enhance any existing ecological resources or corridors to and from adjacent sites.
'Compensation will only be considered as a last resort. Development proposals will be expected to evaluate the impact on local biodiversity where appropriate and propose measures to maintain and enhance biodiversity. This approach should follow the principles outlined within BS42020 "Biodiversity - Code of Practice for Planning and Development" or other measures of best practice, including Biodiversity Offsetting where necessary'.
The above wording embraces the mitigation hierarchy as well as defining means to achieve no net loss as sought by NPPF, without being too prescriptive.
It is considered that paragraph 10.40 regarding the biodiversity calculator is not needed if references requiring its specific use are otherwise removed. The County Council remain concerned that some caution needs to be taken regarding the generation of positive scores which indicate a net gain despite losses that may otherwise be considered unacceptable.
Site Allocations
Please refer to Appendix 1.
Landscape
Green Infrastructure, Biodiversity and Recreation, the policy framework for green infrastructure (GI) was significantly strengthened in Feb 2016 with the introduction of detailed Planning Policy Guidance. The guidance states that GI is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water and should be a key consideration in both local plans and planning decisions.
The Herts Landscape and Green Infrastructure Group is currently looking at GI delivery and practice across Hertfordshire with a view to presenting a project proposal to Herts Infrastructure Planning Partnership (HIPP) in November. The key aim of the project is to mainstream the delivery of GI through the local plan and development management processes. The outputs and deliverables of the project are currently being shaped and should help provide local planning authorities with a good practice approach to GI delivery, supported by robust evidence and case studies.
The Landscape Institute Position Statement for Green Infrastructure provides a widely supported definition of GI (assets and functions) and a comprehensive overview of the key benefits it can deliver, supported by case studies http://www.landscapeinstitute.org/policy/GreenInfrastructure.php
There is no reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans. (The strategies provide an opportunity to address cross boundary issues and meet the Duty to Cooperate. (Hertfordshire and GreenArc Area Strategic Highlights Plan (SHiP) and the All London Green Grid.)
There should be greater emphasis on GI in place-making and conserving and enhancing local distinctiveness. There should be reference to any local character assessments and the guidelines for managing change that should help shape proposals, and conserve and enhance local character.
At a national level there is also the National Character Areas produced by Natural England https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making, and at a regional level there is the East of England Landscape Framework http://landscape-east.org.uk/.
Where proposals are likely to result in landscape and visual effects a landscape and visual impact assessment, in line with industry good practice guidance (Landscape and Visual Impact Assessment third edition Landscape Institute and Institute for Environmental Management and Assessment) may be required as part of an application. The mitigation hierarchy should be referenced to ensure that proposals seek to avoid and minimise any negative effects.
The reference to Green Infrastructure under paragraph 10.1, is fully supported, however it is suggested to expand the definition to include reference to blue assets
such as the Grand Union Canal. Also suggest amend reference to 'mitigating climate change' to 'mitigating the effects of climate change.'
Under paragraph 10.3, it should be clear that biodiversity is not the only driver for Green Infrastructure; other key drivers include a single or multiple land-use functions and include waste/water management, recreation, food production, local distinctiveness etc.
Policy GI5, Trees, Woodlands and Hedgerows, the reference to the protection of trees in line with current British Standard Institute code of practice is fully supported, however the full title of the standard does not appear to be referenced and should be 'Trees in relation to design, demolition and construction' (BS5837:2012). In addition it is advised that where required by the planning authority, tree surveys, arboricultural impact assessments and method statements should all be carried out in compliance with this standard.
The policy should be expanded to include reference to the current hedgerow regulations, the provision of a landscape strategy, planting plans and specifications, and the provision of aftercare (long term management plans) and replacement of failures.
Policy GI6, Protecting and Enhancing the Grand Union Canal, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Yours sincerely,
Paul Donovan
Environment Department
Hertfordshire County Council
APPENDIX 1
Please find below a brief ecological assessment of the site allocations. A 'standard' template for each Site has been provided.
Ecosites do not have any form of status of importance, but are merely sites that we have some ecological information on - thus they do support some wildlife interest, at least at a local level. Whilst these sites are often a valuable starting point in identifying the county's wildlife resource, they do not meet the rigorous and quantifiable assessment criteria needed to identify them as non-statutory Local (County) Wildlife Sites.
SPA1 Town Centre
Recognised sites adjacent / close to Site: close to eastern end of Cassiobury Park Local Wildlife Site.
Other features: Little semi natural habitat present, possibly some mature trees.
Protected species: Probably bats, badger records to the west.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road)
Protected species: Unknown - no records
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA3 Health Campus (includes a Borough Council Depot and Waste Transfer Station at Wiggenhall Road)
Recognised nature sites within Site: The Lairage Land Local Wildlife Site (LWS) and Local Nature Reserve (LNR), Croxley Green Junction Sidings LWS, Oxhey Park River & Margins LWS; Riverside Road Waste Ground ecosite (local database site), The Island, off Cardiff Road ecosite, Oxhey Park ecosite
Recognised sites adjacent / close to Site: Horwoods Avenue Playground ecosite, Moor View ecosite, Cardiff Road Embankment ecosite.
Other features: includes village green - "Green situated between Riverside Road & the River Colne"
Protected species: Birds and Water voles.
Opportunities: High. Habitat management to maintain and enhance biodiversity interest, green infrastructure / corridors.
Ecological sensitivity: Medium to high depending on location.
Fundamental ecological constraint: Presumption to avoid development on Local Wildlife Sites, fragmentation of green corridor,
Loss of Farm Terrace allotment site - should be offset elsewhere as open space / community food growing / ecological resource.
SPA4 Lower High Street
Recognised sites adjacent / close to Site: Bushey Hall Farm ecosite, Oxhey Park ecosite.
Other features: "Recreation Allotments" village green.
Protected species: Unknown - no records. Birds in trees.
Opportunities: Limited as previously developed site. Potential green corridors along railways lines.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA5 Dome Roundabout (includes a Waste Transfer Station at Colne Way)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA6 Western Gateway (includes area of search ELAS221 in the Hertfordshire Waste Site Allocations Document)
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite, Ascot Road ecosite.
Recognised sites adjacent / close to Site: close to eastern end of Croxley Common Moor Site of Specific Scienttific Interest (SSSI) and LNR.
Other features: Grassland strip along eastern boundary with bordering trees.
Protected species: Unknown - no records.
Opportunities: Enhance green infrastructure corridor along eastern boundary.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds in trees.
The ecosites have largely been destroyed by development.
MXD1 North Watford library, Lemarie Centre for Charities, and health facilities (within SPA5)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
MXD2 The Brow
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
MXD3 Gas holder site (within SPA4)
Other features: River Colne borders the eastern boundary.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site. Potential to enhance the river margins as a green corridor.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in the trees.
Largely developed but riverside trees most important and scrub on site.
MXD4 Ascot Road
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite.
Other features: As well as the rough ground and bordering trees of the area to the west, the Site includes part of the school playing fields to the east, which is short mown amenity grassland. There are also some mature trees.
Protected species: Unknown - no records.
Opportunities: Potential enhancement of the areas of semi-natural habitat to improve green corridor connectivity.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds. Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R1 Sainsbury's and adjoining land
Other features: The north-eastern part of the Site includes an area of grassland and mature trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R2 Former TJ Hughes and adjoining land
Other features: Small area of amenity grassland on the north-eastern side.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R3 BT Telephone Exchange and adjoining Wellstones
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R4 Church Street Car Park and land fronting Market Street/Market Place
Other features: area of amenity grassland and scattered trees on the southern side.
Protected species: Unknown - no records.
Opportunities: Limited as predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R5 Charter Place centre and adjoining land onto the High Street
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
CF1 Community Facility Tolpits Lane.
Other features: Site appears to be rough grassland with scattered scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to enhance the habitats on site. The northern boundary is a wooded bank bordering the railway line. Maintain / enhance green corridor along railway.
Ecological sensitivity: Low - medium as semi-natural habitats on site.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H1 Land at Pinner Road
Other features: There are small areas of rough (possibly amenity) grassland with scrub and scattered trees.
Protected species: Unknown - no records.
Opportunities: Limited as a predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H2 Skatepark, Lower Derby Road
Other features: There is an area of grassland with trees in the north-west corner.
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a predominantly a previously developed site. Potential to maintain / enhance the semi-natural habitats on site for green corridor links to nearby habitats, river corridor and wooded railway banks.
Ecological sensitivity:
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H3 Vicarage Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H4 Telephone Exchange - First Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H5 Builder's Yard, Queens Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H6 Bill Everett Community Centre
Recognised sites adjacent / close to Site: adjacent to Long Spring and Harebreaks Wood (Watford) Local Wildlife Site and Local Nature Reserve.
Other features: some areas of grassland (probably amenity?) and occasional scattered trees.
Protected species: Bat roost in building nearby.
Opportunities: Potential to link woodland to the south to area to the north - depending on what the latter is like, as it appears to be bare ground on our aerial photographs.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H7 Rickmansworth Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H8 Garages- The Gossamers
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H9 Watford Station, Cassiobury Park Avenue
Recognised nature sites within Site: Cassiobury Park Avenue allotments ecosite.
Recognised sites adjacent / close to Site: close to "Gade Avenue" Local Wildlife Site.
Other features: Includes an area of allotment gardens and mature trees.
Protected species: Unknown - no records. Potential for bats and reptiles.
Opportunities: Maintain and enhance the green corridor link along the railway line.
Ecological sensitivity: Low - medium?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H10 Croxley View
Other features: Area of semi-natural grassland with scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to manage the existing habitats to maintain / improve biodiversity. Maintain as a green infrastructure link from open grasslands to the south towards the River Gade corridor and semi-natural habitats to the north
Ecological sensitivity: Low.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H11 Garages, Bowmans Green
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
GT1 Lands at Tolpits Lane
Other features: Area of rough grassland with bordering trees.
Protected species: Unknown - no records.
Opportunities: Limited, but part of semi-natural grassland complex in the area so potential for linking hedgerows. Any loss of grassland could be compensated for by enhancement elsewhere and landscaping may provide additional buffering habitats locally if this site were to be developed as such.
Ecological sensitivity: Low?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
E1 Watford Business
Recognised sites adjacent / close to Site: adjacent to Croxley Common Moor Site of Special Scientific Interest (SSSI and Local Nature Reserve (LNR) and Commonland; adjacent to Ascot Road Car Park and Waste ecosite, adjacent to Ascot Road ecosite; close to Ascot Road Scrub Local Wildlife Site.
Other features: Some areas with trees.
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
Part of the edge of this currently provides a valuable buffer and boundary edge to Croxley Common Moor SSSI and LNR. We would object to any development which further degraded this boundary habitat, although much of the former area has already been lost to hard surfacing.
E2 Imperial Way / Colonial
Protected species: Limited as a previously developed site.
Opportunities: Low.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E3 Fishers
Recognised nature sites within Site: Cardiff Road Embankment ecosite.
Recognised sites adjacent / close to Site: adjacent to Croxley Green Junction Sidings Local Wildlife Site.
Other features: Disused railway line to the west is bordered by woody vegetation.
Protected species: Unknown - no records.
Opportunities: Potential green corridors east / west across the site and along the western boundary. Maintain a buffer against LWS to the south.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
E4 Greycaine Road / Odhams / Sandown Road
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E5 Clarendon Road / Station Road / Bridle Path Office Area
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E6 Leavesden Studios - the Island site
Recognised nature sites within Site: part of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Recognised sites adjacent / close to Site: adjacent to the rest of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Other features: Semi-improved grassland habitat, part of a much larger complex.
Protected species: Badger setts on site and nearby.
Opportunities: Linking habitats to similar adjacent grasslands.
Ecological sensitivity: Low - medium.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species, with particular attention to badgers

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 856

Received: 03/10/2016

Respondent: Hertfordshire County Council SLU

Representation Summary:

It is recommended that all roads are usable by cycles to aid permeability.

Full text:

Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
With regard to Policy SPMX1: Special Policy Areas, the council is pleased to see the insertion of reference to the county council's documents. The text should however refer to the' Waste Local Plan' which includes both the Waste Core Strategy and Development Management Policies document and the Waste Site Allocations document.
With regard to Special Policy Area 2: Watford Junction, the council is pleased to see that there is reference to the need to safeguard the rail aggregates depot at Orphanage Road.
Further information on SPA2 is contained in Appendix I: Site Schedules of the Local Plan Part 2. The council is pleased that the rail aggregates depot is included as a
Spatial Planning and the Economy
Environment Department
Hertfordshire County Council
County Hall
Hertford
Hertfordshire
SG13 8DN
paul.donovan@hertfordshire.gov.uk
01992 556289
Planning Policy Team,
Room 65,
Watford Borough Council,
Town Hall,
Watford,
Herts,
WD17 3EX.
development consideration where it states 'This will need to be retained, or a new comparable facility provided within the local area'. However it should be noted that the text should refer to the 'rail aggregates depot' as opposed to the 'waste aggregates depot'.
However, in practice, taken together with the masterplan and accompanying viability report, there appears to be a strong likelihood that the rail aggregates depot is not to be retained on site and the collective impact of the Local Plan is not to safeguard the rail aggregates depot. Given this, the Inspector may well wish to see what evidence exists with regard to securing a replacement facility and currently no such evidence accompanies the Local Plan. As a consequence, there is considerable uncertainty in relation to whether the Local Plan satisfies potentially all soundness tests.
With regard to SPA6 Western Gateway, this includes ELAS221 and it is also worth pointing out that the areas designated as PS2 and PS3 potential in the Croxley View/Ascot Road Masterplanning Study are also located in ELAS221.
It is agreed that it is useful to insert text in relation to the circular economy as part of the waste section under paragraph 3.30, supporting text to Policy SD10: Waste. The second bullet point should state 'drive greater resource productivity.'
The relevant policy basis has been applied in the waste section and the Watford Local Plan with regard to responsibility for waste management. Whilst there appears to no longer be specific reference to Waste Policy 12, there is text to cover the use of this policy along with others within the Waste Core Strategy and Development Management Polices document. One comment to make is that in the wider context of the Watford Local Plan with there also being reference to ELAS221, the text in paragraph 3.30 should refer to the Waste Local Plan, which covers policies within the Waste Core Strategy and Development Management Policies document, adopted November 2012 and the Waste Site Allocations document, adopted July 2014.
Watford Junction Development Brief
As previously stated, most recently in respect of the Infrastructure Delivery Plan, the key matter of concern to the Minerals and Waste Planning Authority is the impact that any proposed development may have upon the safeguarded rail aggregate depot located at Orphanage Road, Watford which is a current operational facility.
The planning policy status, as detailed within the introduction of the brief, refers to consideration being had to national planning policy and the Watford Borough Council Local Plan. To ensure that the Development Plan has been considered as a whole the brief needs to also refer to the Minerals Local Plan and the Waste Local Plan. In terms of national policy, there is the need to ensure that the NPPF is considered in respect of para 143 which states that Mineral Planning Authorities should safeguard existing, planned and potential rail heads, so as to prevent their redevelopment for other uses and loss of the mineral infrastructure. This safeguarding is also applicable to storage, handling and processing facilities associated with them.
It is considered that due to the location of the rail aggregate depot within the development brief area that the county council's Minerals Local Plan 2002-2016, adopted March 2007 is also considered with specific regard to minerals policy 10: Railheads and Wharves. The Minerals Local Plan is being reviewed at present. It is envisaged, due to the requirement of the NPPF, that there will be a policy on Rail heads and Wharves in the Draft Minerals Local Plan.
The siting of the rail aggregate depot is shown within the county council's Mineral Consultation Area Supplementary Planning Document, adopted November 2007. The consultation area covers the majority of the Special Policy Area 2 Watford Junction. In accordance with the NPPF and Minerals Local Plan, in respect of minerals policy 10 the county council seeks to safeguard the rail aggregate depot which continues to serve as a sustainable mode of transporting minerals over long distances and the concrete batching facility which this site also supports. Given that the site is viable for use as a rail aggregate depot, its retention is expected unless the facility can be satisfactorily relocated within the development proposals in terms of operational requirements and environmental criteria or it has been or will be replaced in an alternative location.
The development brief identifies the rail aggregate depot as being a 'weakness' for the redevelopment of Watford junction in the SWOT analysis in paragraph 2.1. Minerals are important to the economy. Aggregate is needed to facilitate development and volumes of construction material being transported by rail in increasing. In light of this it could be considered that a rail aggregate depot in close proximity to the construction project could be considered to be a strength.
The issue of addressing such a 'weakness' is not however further expanded upon. It is clear from the illustrative masterplan that the retention of the rail aggregate depot is not part of the scheme. Whilst it is intended to be flexible enough to accommodate alternative layouts so long as it achieves the guiding principles and core ambitions of the masterplan, there does not appear to be sufficient scope to accommodate the existing or a relocated rail aggregate depot within the redevelopment area. As such this leaves the only option of relocating the rail aggregate depot offsite at another location along the railway line.
There is the need to establish an alternative well positioned strategic location for the rail aggregate depot to ensure its continued operation for imports and exports of minerals and secondary and recycled aggregates. The SWOT analysis in the development brief states that there is a 'weakness' in terms of a lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling. The Borough Council is referred back to paragraph 143 of the NPPF, the adopted Minerals Local Plan and specifically minerals policy 10 and the adopted Minerals Consultation Area SPD as detailed above in terms of the clarity for the safeguarding of the rail aggregates depot at Orphanage Road.
The brief states under the land use and quantum section of Station Quarter East within paragraph 3.4 that the development will be required to relocate the Rail Aggregates Depot within the local area, in consultation with Hertfordshire County Council and the operator of the site. The County Council will continue to work with the Borough Council in respect of this matter. The land use and quantum section in
paragraph 3.4 should also refer to the need to work with Network Rail with regard to the relocation of the Rail Aggregates Depot. The County Council understands that Network Rail Freight Management has been consulted and will provide comments to this consultation. There is however no further detail with regard a precise location having been secured.
To this end the relocation of the rail aggregate depot is fundamental to the delivery of the masterplan. A statement should be made in the delivery section of the brief at paragraph 4.1 specifically in relation to the requirement to ensure that the relocation of the rail aggregates depot forms part of the Watford Junction Delivery Plan.
Croxley View/Ascot Road Masterplanning Study
The Croxley View/Ascot Road Masterplanning Study has been considered by the county council as Waste Planning Authority due to the proximity of redevelopment to the Employment Land Area of Search (ELAS) 221 Watford Business Park.
The masterplan aims to build on the policy foundations of the district Local Plan Core Strategy Policy SPA6 to facilitate redevelopment. The location of potential residential development is shown within the Masterplanning Study to be directly adjacent to ELAS221 as designated within the county council's Waste Site Allocations document 2011-2026, adopted July 2014.
It is considered that ELAS that are predominantly used for general industry (B2) and storage and distribution (B8) are compatible with waste management uses. ELAS221 contains B1 and B2 uses and as such is acceptable in principle for a range of potential waste uses listed in the general waste brief during the 15 year plan period 2011-2026. Further planning guidance into the suitability of waste related development on the identified ELAS is within the ELAS Supplementary Planning Document, adopted November 2015. For this area, the Supplementary Planning Document states 'only enclosed waste transfer stations and materials recovery facilities that handle dry recyclables would be acceptable, along with enclosed inert waste recycling facilities. No other potential uses that may generate a leachate or liquor, which poses a risk to groundwater resources would be appropriate'.
The council does not wish to see the loss of identified ELAS for non-waste uses in order to safeguard it for future potential waste uses that may be sited in this location. Whilst the residential development would not directly encroach onto the ELAS, the council is mindful that the residential development is identified along the eastern boundary of the designated site and as a result there could be the potential for indirect impact upon the siting of waste uses within the ELAS.
The Waste Local Plan does not rely on the need for all land within ELAS across the county for the delivery of waste uses. However the cumulative loss of ELAS to non-waste uses is monitored and the safeguarding of remaining ELAS land is important to ensure there is a sufficient amount of land that could come forward for waste management facilities in the future, particularly with additional growth resulting in an increase in waste produced which needs to be managed.
There are currently no extant planning permissions on land directly adjacent to the masterplanned residential development to be aware of. The nearest waste site is the Household Waste Recycling Centre at Caxton Way in ELAS221. There is sufficient land remaining in ELAS221 to be brought forward for waste management uses.
The County Council does not wish to object to the masterplanning for potential residential development at this stage but reserves its right to object to future planning applications adjacent to the ELAS should a waste site be development in advance of residential. The reason for this would be to safeguard any waste use(s) under waste policy 5: Safeguarding of Sites within the Waste Core Strategy and Development Management Policies document 2011-2026, adopted November 2012. Further discussions would need to take place in the event that negative effects are identified that would restrict the waste operation to continue. A buffer between two land uses or mitigation measures in some cases may be appropriate to allow opposing land uses to exist in harmony adjacent to each other.
The County Council's adopted Waste Core Strategy and Development Management Policies document, does not stipulate a distance whereby other development in close proximity to a safeguarded waste site should be discouraged, the 2004 ODPM document: Planning for Waste Management Facilities: A Research Study states that for waste transfer stations: "sites closer than 250m from residential, commercial or recreational areas should be avoided." This guidance was used in the production of the Waste Site Allocations document. Depending upon the location of any potential future waste management facility within the ELAS, there is the potential that facilities may well be sited closer than the suggested 250m to any future housing.
Transport
Overarching/ general comments
Watford and the surrounding transport network face growing challenges as a result of the desired housing and economic growth in the area and increasing demand for travel. The County Council is developing a countywide transport model that will help all local authorities in the county to plan positively for growth and infrastructure investment in a way that safeguards the health and wellbeing of our communities and the environment. Already the model has identified notably worsening congestion issues in the Watford area as a result of planned growth. The next outputs of the enhanced Watford area version of the model will be available by the end of October 2016. The existing model is already available to Watford Borough Council to test development scenarios and proposals from the Local Plan.
In parallel with this, the County Council is developing a Growth & Transport Plan for South West Hertfordshire, which includes Watford and the surrounding towns and transport networks that make up a coherent area of travel demand. The Growth & Transport Plan will put forward packages of transport interventions to respond to strategic transport challenges and objectives for the area, derived through robust evidence analysis and engagement with stakeholders. Watford Borough Council officers and members have been involved from the early stages in GTP workshops
at key stages. The GTP is about identifying needs, planning for and enabling investment and delivery of a transport network and public realm that will support a healthy economy, environment and communities.
As a result of the current ongoing work being incomplete, at this stage there is insufficient evidence available to assess the implications of Local Plan Part 2 on the transportation network. As a consequence, there is uncertainty in relation to the mitigations that will be required to support the proposals and we remain in doubt that it potentially satisfies all soundness tests.
Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
Contents
'Appendix I - Site Allocations' is referred to later as 'Site Schedule'
'Appendix L' and 'Appendix M' missing from content list
Policy SD10
Refuse collection vehicles must be able to stop within the 'maximum refuse carry distance' specified by the Local Planning Authority or within 25m of any bin storage area, whichever is the lesser distance. Residents should not have to carry their rubbish more than 30m to a storage point. (Sources BS5906:2005 and Schedule 1 Part H Building Regulations)
Policy TLC14
On-street parking continues to need to be managed to manage congestion and avoid hazards, particularly at junctions.
Policy HS7
The subjective "undue pressure" on on-street parking should not lead to increased congestion and / or hazards on the highway network, particularly at junctions.
The siting of bin stores should not adversely impact on the operation of the highway network.
Policy HS8
The Highway Authority recommends that consideration of deliveries is made explicit in this policy.
6.9 and Policy EMP5
The County Council supports urban realm enhancement of Clarendon Road to encourage walking and cycling and improve the key pedestrian route between the town centre and Watford Junction.
Consideration should be given to amending the policy wording to explicitly include an expectation for development along Clarendon Road to contribute towards urban realm enhancements directly through works delivered or through developer contributions to fund such works.
Policy T6
The County Council is supportive of the zonal approach to car parking guidance to encourage lower car ownership and usage in more accessible zones. The principle of 'Car Lite' development in the most accessible areas, within 5 or so minutes' walk of a major transport hub, is also supported as long as the needs of disabled drivers and visitors are considered.
Lower car parking provision must be accompanied by appropriate restrictions in surrounding residential streets and any public car parks to prevent spill-over parking. In order for this approach to lowering car usage to be successful, there needs to be parallel investment in infrastructure (eg significantly better cycle and bus routes) and urban realm improvements to support and actively encourage alternative modes of travel.
The County Council welcomes the requirements for car club spaces in the SPAs and where parking does not meet the guidance.
Policy T8 and Appendix H
The policy on cycle parking provision and the stipulations relating to quality contained in the policy is welcomed. Adequate cycle storage must also be provided for existing and high predicted future levels.
A small change is recommended to allow for cycle parking provision for dwelling houses to be in a private garage as well as within the private garden area - subject to the dimensions of the garage being adequate to accommodate cycles as well as any vehicle.
However, the policy only specifies one long-term space per unit (regardless of size or location) where there is no garage or shed. In some instances such as within SPA2 and SPA6 where housing will be in the form of apartments and where there will be reduced car parking, it may be necessary for additional capacity for cycle storage beyond one space per unit, especially for larger flats or any flats without car parking provided.
Policy UD3
Structures abutting and overhanging the public highway will need the approval of the Highway Authority (HCC) as will illumination visible from the highway.
Policy TB1
From a transport network and user perspective, locations near to major passenger transport hubs, offering good interchange between different services and modes, are the most appropriate for denser development (i.e. taller buildings). However, development proposals should all be subject to Core Strategy policies T2-T5 to ensure that their impacts are understood and mitigated.
In order for such development to be acceptable, there must be adequate and appropriate improvements to transport infrastructure and urban realm within the site and in the wider area, to ensure no significant adverse impact on the highway and passenger transport networks, as a direct, indirect or cumulative result of development at the site and in the Borough as a whole.
Policy TB2
Suggest change to text at 8. Transport, parking and infrastructure:
'The design should detail a transport strategy for the proposed development to include how cycle parking, car parking, cycle permeability and pedestrian permeability have been integrated into the overall design. This should be based on a Transport Assessment and should avoid negative impacts on the public realm. The scheme will also need to demonstrate that the required infrastructure and utility capacity has been fully appraised.'
Appendix G
Parking bay dimensions only seem to consider residential element, parking bay at 2.4 x 4.8m is fine for standard bay but dimensions of other bays should be provided e.g. parallel arrangement. The garage dimensions provided are 3m x 5.5m whereas the industry standards are 3m x 6m (MfS para 8.3.41). Should minimum circulatory space for car parks be covered here (i.e. 6m) or will it be covered elsewhere?
SPA1
The ring road constrains pedestrian and cycle accessibility to the heart of the town centre. nb includes EMP5, R1, R2, R3, R4, R5. See Highway Authority comments in regard to each of these.
SPA2
Any development within the Watford Junction SPA should ensure that connectivity for pedestrians and cyclists is improved across the site, between the site and the town centre and on other key routes to Watford Junction Station.
Development of the station building, forecourt and car parks must address current limitations including capacity, access and circulation issues, for pedestrians, cyclists, buses, bus users, taxis, as well as users of the car parks. Opportunities to make Watford Junction an attractive and functional transport interchange that can accommodate future growth should be maximised.
See Highway Authority comments on Draft Development Brief (below).
SPA3
Good quality cycle and pedestrian links through the site and between the site and surrounding area and key destinations (town centre, Vicarage Road MLX station, local schools etc.) must be provided, or contributions to support infrastructure improvements in the wider area made through developer contributions.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
SPA4
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
Support improvements to green infrastructure and public realm as a complement to improvements to pedestrian and cycle links.
Flooding is a known issue affecting this area. Any development in this area should be designed to avoid and mitigate flood risk. Sustainable drainage approaches and green infrastructure should be used where appropriate to reduce and manage flood risk.
SPA5
Development at this location will need to consider transport impacts on the highway network, including operation of the Dome roundabout and St Albans Road notably at peak times. Also junctions including M25/A405/M1, and M1/A41.
There is a need to improve cycle, pedestrian and passenger transport connectivity to the site, and between the site and the town centre and Watford Junction.
It is recognised that the Abbey Line (North Watford) station is closer to the site, but there are limitations to this service at present which will reduce its attractiveness as an alternative to the car for journeys to Watford Junction or St Albans Abbey stations.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
There is a typo on second bullet point - should read 'improve air quality'.
SPA6
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Cycle improvements on Rickmansworth Road may be required as this is a key corridor between Rickmansworth and Watford.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
Secure, high quality cycle parking is needed at the proposed Cassiobridge station, as well as within the employment premises.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
See Highway Authority comments on Masterplanning Study (below)
MXD3
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
R1
It is agreed that robust pedestrian links with the town centre should form part of the new development at this location.
Good cycle access and high quality cycle parking also needs to be provided, for customers as well as employees.
R2
Agree that clear pedestrian connections between the site and the High Street are needed.
Good cycle access and cycle parking must also be provided.
There is a need to consider access needs to the site by different modes. A planned highway improvement scheme will make Clarendon Road one-way (NE-SW only) from Beechen Grove to High Street, with a contraflow cycle lane. Access to the street will be restricted by a Traffic Regulation Order to buses, taxis, cycles, 'blue badge' vehicles, and other vehicles 'for access only' to premises. All accessing vehicles will need to leave either via High Street or Watford House Lane (private road) for those accessing that area.
Development of this site should complement public realm enhancements proposed or already delivered on Clarendon Road and the High Street.
R3
Good cycle access and storage facilities must be provided, as well as good pedestrian links.
Developments at this location must take into account severance issues caused by the ring road for pedestrians and cyclists. Improvements required such as crossing improvements, new accesses into/through the site, should be delivered as part of the development or through developer contributions.
R4
Strong pedestrian and cycle links between this site and the town centre must be provided.
The quality of cycle routes and access to/from the west needs to be improved - eg. Market Street west of ring road and the Hornets Gyratory.
H1
This site is in close proximity to Bushey Station and includes its car park.
Opportunities to upgrade access to the station by non-car modes should be pursued.
Need to consider quantity and quality of cycle parking and cycle access to station from surrounding area.
Cycle access and cycle parking provision at Bushey station should be improved as part of any car parking replacement/improvement scheme.
Bushey Arches is a known congestion hotspot. Impacts of development on Bushey Arches must be considered and mitigation provided. This should include contributions to needed improvements to key walking and cycling routes and passenger transport infrastructure in the area.
H2
The ring road causes significant severance to people travelling by foot and cycle. Particular issues have been reported for people with visual impairments.
Improved cycle and pedestrian links to town centre and to Watford High Street and Watford Junction stations are needed from the site.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
H3
This site is about half mile from both the proposed Vicarage Road Met Line station and Watford High Street station, which is 10 to 12 minutes walking time.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
Vicarage Road is a busy road without dedicated cycle facilities. As such improvements to this route for cyclists should be considered. Developer contributions to improving cycle routes may be appropriate.
H5
The traffic impact on west Watford's road network needs to be considered and mitigated.
Cycle and pedestrian links into the site from different directions are required.
Adequate cycle storage must also be provided for existing and high predicted future levels.
Cycle infrastructure and the pedestrian environment of the surrounding area needs consideration.
H9
The impact of development at this site on the road network must be considered and mitigated if needed, including Rickmansworth Road and West Watford.
Good cycle links are needed including between the site, the town centre, and Ascot Road.
Bus services and infrastructure, including linking to new Cassiobridge Met Line station.
Bus services in this area may well be subject to change following the loss of the underground station. Development of this site and any forthcoming S106 contributions would provide the opportunity for an assessment to be made of potential improvements to bus services so this site remains connected to key destinations.
E1
High quality, secure cycle provision is needed at business premises.
Although the Ebury Way provides a good cycle route to the site, this will not be suitable for use all year round, at any time of day. As such improvements to the A412 corridor cycle infrastructure should be explored and provided. Developer contributions may be appropriate.
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
E2
Cycle and pedestrian routes through the site need improvement;
Via Watford Junction SPA site, there is a need to reduce severance and improve pedestrian and cycle connectivity to Watford Junction station and Clarendon Road.
WBC also needs to consider the implications of the Colonial Way Link road on development at site E2.
There is a need to consider potential transport implications of this site and the Watford Junction masterplan as a whole, including traffic accessing any new station multi-storey car parks, and the impact on the road network (eg. Colonial Way, Stephenson's Way, Radlett Road, Link Road, A41/M1 junction...).
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions.
E4
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions and on footways.
E5
Needs to link with SPA2 Watford Junction.
Development will need to assess impacts on road network and car parking demand in surrounding area.
Quality of pedestrian and cycle environment and urban realm on Clarendon Road should be considered and opportunities to enhance in consistent, coherent way should be explored to promote sustainable travel and improve route between town and Watford Junction.
Buildings will need to provide adequate, high quality secure cycle parking. If low car parking, may need to increase requirements or leave space to expand provision as required.
G6
Any change in land use/ status/ access provision to the south of Caxton Way and the south and east of Greenhill Crescent should not be permitted until its ability to provide the link for sustainable modes between Tolpits Lane and Caxton Way required by paragraph 10.6.9 of the WBC Core Strategy has been fully explored and ruled out.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF
1.1
The traffic and transport impacts of the masterplan scheme have not been modelled and thereby understood. The Highway Authority is, therefore, unable to fully support the plan until those impacts are assessed and deliverable mitigation measures agreed. HCC is developing traffic and transport models of Watford as part of its work to create a Growth & Transport Plan for the area. These will be used to test the impacts of the Watford Junction and other development proposals on transport infrastructure and services individually and cumulatively.
As part of earlier work on this site the County Council had required the construction of a road and bridge linking Colonial Way and St Albans Road via Penn Road. The scheme to build it received outline DfT funding and included a passenger transport (coach) interchange on the northeast side of the station. If the link road and bridge are no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
1.2
Correct reference to 'Abbey Link' in map to 'Abbey Line'.
2.1
The Barriers plan acknowledges the severance created by the presence of the Abbey Line. As part of earlier work on this site the County Council had required the construction of a road over the Abbey Line linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.2
Policy T1 in the borough council's Core Strategy supports conversion of the Abbey Line from heavy to light rail operation.
Correct reference to 'Abbey Flyover' in Objectives to 'Abbey Line'.
2.3
Correct reference to 'Abbey train line' under Transport and Parking to 'Abbey Line'.
As part of earlier work on this site the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.4
Gross External Areas values are different to those in 5.1 Area Schedules.
3D views might benefit from road names for orientation.
2.7
As part of earlier work on this site, the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
It is recommended that all roads are usable by cycles to aid permeability.
The road hierarchy titles have different meanings in the Highway Authority's own existing hierarchy. As the design is refined it is recommended that confusion is avoided by using different names.
2.8
The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.
3.3
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
3.4
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
4.1
The County Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order that they can be considered in the emerging Watford Growth & Transport Plan. Joint working with the County Council will remain key in order to maximise access to appropriate funding streams and delivery programmes.
Special Policy Area 2 is zero-CIL-rated so that all planning obligations will be derived via Section 106 agreements with service providers.
4.2
An overall Travel Plan for the site will be required and one for each subsequent development area should be provided and agreed.
5.1
Total car parking number differs from that given in 2.4 and Station Quarter East breakdown (p 46).
Gross External Areas values are different to those in 2.4.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF VIABILITY APPRAISAL
4.2
The County Council is concerned about the unrealistically low estimates given in figure 4.1 for the costings of infrastructure required to mitigate the impact of the masterplan.
CROXLEY VIEW/ ASCOT ROAD STUDY
Introduction
Mention must be made of the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The need for a link both for Watford and Three Rivers grows as pressure to develop either side of the Ebury Way increases and its delivery should be seen as key to both authorities' Duty to Cooperate.
Plans
All plans refer to Watford County Council.
All plans show Croxley Green Business Park to the southwest of the masterplan area. This is correctly the Wolsey Business Park.
Most plans show the Grand Union Canal badged as the River Gade which runs to the south and east of it.
Some plans do not show the correct alignment of the Watford/ Three Rivers boundary.
Some plans erroneously label the NE corner of Croxley Common as Cassiobury Park Nature Reserve.
Masterplanning Strategy plan - asterisks and other labelling are not described and inconsistently applied.
Potential Development Sites plan
This omits to include the Tech Site (around Woodshots Meadow). This is subject to preapplication discussions now and should be considered with the adjacent sites as it is in Employment Policy Area E1 (Local Plan Part 2 appendix 1).
Proposed Vehicle and Pedestrian Movement plan
This omits the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The route currently being explored follows the cycle track between the Watford Enterprise Centre and number 27 Greenhill Crescent.
Historic environment, landscape and ecology
The County Council supports the overall policy intentions of the Local Plan covering landscape, ecology and the historic and built environment and provides the following comments to help strengthen these policies and their supplementary text.
Historic Environment
Development Management Policies
The County Council welcomes the Borough's consideration of the Historic Environment in Part 9 Urban Design and the Historic Environment. However, the historic environment should be referenced in line with the NPPF definition of heritage assets. In addition to historic buildings (both designated and undesignated), the historic environment of Watford includes archaeological remains, historic landscapes and historic parks. Therefore policies are needed to conserve the historic environment as whole, not just designated buildings, registered gardens and conservation areas as is currently stated.
Under Policy UD4, Archaeology, there appears to be repetition of the NPPF, the policy is unclear and should be re-written.
There is also reference to the conservation of heritage assets being secured by an archaeological Written Scheme of Investigation (WSI). Whilst the County Council welcomes the requirement for these documents and for them to include provision for publication and public dissemination of results where appropriate (NPPF 141), it is not clear if the WSI on its own is considered to be robust enough to secure appropriate conservation of the historic environment. Therefore it is unclear if this part too, is effective.
Watford Junction Draft Development Brief 2016
Paragraph 4.2 notes that a Heritage Statement and Desktop Archaeological Study may need to be submitted with any planning applications. However, it is unclear what is meant by a Heritage Statement. Also archaeological assessment may not be limited to a desktop study.
Site Allocations
An appraisal of the archaeological implications of development for the new areas identified in the Second Consultation document (2016) is summarised below.
1. Archaeology as a Development Constraint
N/A
2. Requirement for Pre-allocation Archaeological Assessment
The sites below have known archaeological remains within them or have significant archaeological potential by reason of their size and situation, such that there is a risk that archaeology could be a constraint on any development. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that archaeological assessments should be included within all development briefs and other proposals for the sites, before they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the sites, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent of archaeological remains that might be a constraint upon the principle of development of these sites.
Allocation numbers: SPA1, SPA4 and H9.
3. Requirement for Pre-application or Pre-determination Archaeological Assessment
The sites below have known archaeological remains within them or have archaeological potential. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that that pre-application or pre-determination archaeological assessments should be included within all development briefs and other proposals for the sites, if they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the proposals, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent
of archaeological remains worthy of preservation in situ, to enable the LPA to determine any specific application for development.
Allocation numbers: SPA 2, SPA3, SPA5, SPA6, MXD1, MXD3, R1, R2, R3, R4, H2, H3, H4, H 10, E1, E2, E3, E4, E5, E6.
4. Mitigation of archaeological impact by condition
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, any archaeological issues can probably be dealt with by condition, should planning permission be granted.
Allocation numbers: R5, CF1, H1, H5, H6, GT1.
5. No archaeological requirements
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, there are unlikely to be any archaeological implications. However this will depend on the details of any proposals and any new archaeological information.
Allocation numbers: MXD2, MXD4, H7, H8, H11.
Ecology
Development Management Policies
Policy SD15, External lighting, the County Council support the provisions set out in this policy and advise that there should be reference to the guidance provided by the Institute of Lighting Engineers which has been instrumental in seeking to reduce the impacts of artificial lighting within the environment.
Green Infrastructure, Biodiversity and Recreation, the County Council supports the reference to Green Infrastructure (GI).In defining GI there should also be reference to the provision of local food production as a key ecosystem service.
Policy G15, Trees, Woodlands and Hedgerows, this policy is supported in respect of highlighting ecological and cultural value of trees, woodlands and hedgerows. However, under paragraph 10.3, the reference to valuable habitats should be extended to include reference to ecological networks and corridors. Under paragraph 10.6 it should be clarified that replacing trees lost to development cannot compensate for the loss of biodiversity or amenity value in the short term.
Policy GI6, Protecting and Enhancing the Grand Union Canal, this policy is supported including the reference to enhancing biodiversity under paragraph 10.11. It is advised that the policy is extended to include a clause that seeks to improve the biodiversity of the canal corridor where possible. Development that would have an
adverse impact on the biodiversity of the canal would not be supported unless it can demonstrate provision of suitable mitigation or compensation.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, this policy is supported however recommend the following clarifications and amendments.
It is advised to make reference to the 'amenity value' of the river, specifically encouraging 'recreation' may increase disturbance to sensitive wildlife within river corridors. The term 'amenity' embraces visual and recreational importance without being too prescriptive or disruptive if more sensitive habitats or locations are affected an important consideration within this largely urban area.
With regards the provision of 'a corridor for wildlife and biodiversity,' the reference to biodiversity should be deleted as wildlife is biodiversity. With regards replacement structures and fish passage, liaison with the Environment Agency is essential if any such works are proposed. With regards access it should be designed in a way that also enables some undisturbed areas to be retained.
Policy GI9, Provision of Open Space and Play Space in Residential Development, aspects of this policy relevant to biodiversity are supported. The reference to green space typologies should be expanded to include allotments and community orchards, in order to reflect the types of functional sites which support both community and biodiversity benefits.
Biodiversity, it is not clear why this section is formatted differently to the preceding and subsequent sections. In particular it does not describe 'Why is this policy needed?' and 'what is it intended to do?' In setting out the need for the policy, it should reference the legislative requirements of statutorily protected sites and species which are a material consideration in planning, as well as the Duty placed on Local Authorities to have regard to conserving biodiversity in all of their functions as set out in the Natural Environment and rural Communities Act 2006. In setting out the intention of the policy there should also be reference to seeking to deliver the aims of the Local Nature Partnership - for which securing ecological resources, functions and services are a consideration when determining planning applications.
Under paragraph 10.37 the reference to the 'Biodiversity Plan' should be amended to reference to the 'Biodiversity Action Plan principles' (BAP). The BAP, nationally and locally, has ceased to be actively supported by National and Local Government, and has essentially been replaced by the Local Nature Partnership. However the principles underpinning it remain valid as statements and the intentions of the various habitat and species action plans are sound in themselves and could be followed if resources or interest permitted.
It is suggested that the statement under paragraph 10.39 should be amended as follows:
'This policy expects that where appropriate, development proposals will demonstrate the relative ecological value of a site before and after development. Proposals should follow the mitigation hierarchy and provide clear evidence of impacts and enhancements where appropriate, consistent with the aims of NPPF, BS42020
"Biodiversity - Code of Practice for Planning and Development'' and guidance provided by CIEEM. This will require sufficient detail and clarity to enable net losses and gains to be identified and monitored, consistent with the Code. Where unavoidable, Biodiversity Offsetting should be considered as a means to ensure there is no net loss of biodiversity resulting from development'.
Highlighting the specific use of Biodiversity Calculators such as the one mentioned in paragraph 10.39 can be a little misleading. BS42020 does not mention the use of biodiversity calculators, and taken out of context the results of such calculations can sometimes show net gains where there should be none (removal of ancient woodland for example cannot reasonably be compensated in the real world). Other wider landscape issues are also not always considered by these calculators; if the land is part of a wider corridor, or a biodiversity network for example. It has taken several years for Warwickshire County Council to incorporate their use in to the planning system and there is still not universal agreement on them.
The County Council would therefore advise caution on their avocation, but rather emphasise the need to prove that biodiversity has not been lost and in the most part enhanced through "appropriate methods in-line with BS42020".
Policy GI10 Managing Biodiversity in new Developments. The County Council supports Watford Borough Council's commitment to increasing biodiversity within the district. The Policy is consistent with other Hertfordshire Local Authorities, and in-line with the National Planning Policy Framework.
The following amendments are advised. There should be reference to avoiding negative impacts upon ' local ecological networks...,'as each site sits within a local environmental and should retain or enhance any existing ecological resources or corridors to and from adjacent sites.
'Compensation will only be considered as a last resort. Development proposals will be expected to evaluate the impact on local biodiversity where appropriate and propose measures to maintain and enhance biodiversity. This approach should follow the principles outlined within BS42020 "Biodiversity - Code of Practice for Planning and Development" or other measures of best practice, including Biodiversity Offsetting where necessary'.
The above wording embraces the mitigation hierarchy as well as defining means to achieve no net loss as sought by NPPF, without being too prescriptive.
It is considered that paragraph 10.40 regarding the biodiversity calculator is not needed if references requiring its specific use are otherwise removed. The County Council remain concerned that some caution needs to be taken regarding the generation of positive scores which indicate a net gain despite losses that may otherwise be considered unacceptable.
Site Allocations
Please refer to Appendix 1.
Landscape
Green Infrastructure, Biodiversity and Recreation, the policy framework for green infrastructure (GI) was significantly strengthened in Feb 2016 with the introduction of detailed Planning Policy Guidance. The guidance states that GI is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water and should be a key consideration in both local plans and planning decisions.
The Herts Landscape and Green Infrastructure Group is currently looking at GI delivery and practice across Hertfordshire with a view to presenting a project proposal to Herts Infrastructure Planning Partnership (HIPP) in November. The key aim of the project is to mainstream the delivery of GI through the local plan and development management processes. The outputs and deliverables of the project are currently being shaped and should help provide local planning authorities with a good practice approach to GI delivery, supported by robust evidence and case studies.
The Landscape Institute Position Statement for Green Infrastructure provides a widely supported definition of GI (assets and functions) and a comprehensive overview of the key benefits it can deliver, supported by case studies http://www.landscapeinstitute.org/policy/GreenInfrastructure.php
There is no reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans. (The strategies provide an opportunity to address cross boundary issues and meet the Duty to Cooperate. (Hertfordshire and GreenArc Area Strategic Highlights Plan (SHiP) and the All London Green Grid.)
There should be greater emphasis on GI in place-making and conserving and enhancing local distinctiveness. There should be reference to any local character assessments and the guidelines for managing change that should help shape proposals, and conserve and enhance local character.
At a national level there is also the National Character Areas produced by Natural England https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making, and at a regional level there is the East of England Landscape Framework http://landscape-east.org.uk/.
Where proposals are likely to result in landscape and visual effects a landscape and visual impact assessment, in line with industry good practice guidance (Landscape and Visual Impact Assessment third edition Landscape Institute and Institute for Environmental Management and Assessment) may be required as part of an application. The mitigation hierarchy should be referenced to ensure that proposals seek to avoid and minimise any negative effects.
The reference to Green Infrastructure under paragraph 10.1, is fully supported, however it is suggested to expand the definition to include reference to blue assets
such as the Grand Union Canal. Also suggest amend reference to 'mitigating climate change' to 'mitigating the effects of climate change.'
Under paragraph 10.3, it should be clear that biodiversity is not the only driver for Green Infrastructure; other key drivers include a single or multiple land-use functions and include waste/water management, recreation, food production, local distinctiveness etc.
Policy GI5, Trees, Woodlands and Hedgerows, the reference to the protection of trees in line with current British Standard Institute code of practice is fully supported, however the full title of the standard does not appear to be referenced and should be 'Trees in relation to design, demolition and construction' (BS5837:2012). In addition it is advised that where required by the planning authority, tree surveys, arboricultural impact assessments and method statements should all be carried out in compliance with this standard.
The policy should be expanded to include reference to the current hedgerow regulations, the provision of a landscape strategy, planting plans and specifications, and the provision of aftercare (long term management plans) and replacement of failures.
Policy GI6, Protecting and Enhancing the Grand Union Canal, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Yours sincerely,
Paul Donovan
Environment Department
Hertfordshire County Council
APPENDIX 1
Please find below a brief ecological assessment of the site allocations. A 'standard' template for each Site has been provided.
Ecosites do not have any form of status of importance, but are merely sites that we have some ecological information on - thus they do support some wildlife interest, at least at a local level. Whilst these sites are often a valuable starting point in identifying the county's wildlife resource, they do not meet the rigorous and quantifiable assessment criteria needed to identify them as non-statutory Local (County) Wildlife Sites.
SPA1 Town Centre
Recognised sites adjacent / close to Site: close to eastern end of Cassiobury Park Local Wildlife Site.
Other features: Little semi natural habitat present, possibly some mature trees.
Protected species: Probably bats, badger records to the west.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road)
Protected species: Unknown - no records
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA3 Health Campus (includes a Borough Council Depot and Waste Transfer Station at Wiggenhall Road)
Recognised nature sites within Site: The Lairage Land Local Wildlife Site (LWS) and Local Nature Reserve (LNR), Croxley Green Junction Sidings LWS, Oxhey Park River & Margins LWS; Riverside Road Waste Ground ecosite (local database site), The Island, off Cardiff Road ecosite, Oxhey Park ecosite
Recognised sites adjacent / close to Site: Horwoods Avenue Playground ecosite, Moor View ecosite, Cardiff Road Embankment ecosite.
Other features: includes village green - "Green situated between Riverside Road & the River Colne"
Protected species: Birds and Water voles.
Opportunities: High. Habitat management to maintain and enhance biodiversity interest, green infrastructure / corridors.
Ecological sensitivity: Medium to high depending on location.
Fundamental ecological constraint: Presumption to avoid development on Local Wildlife Sites, fragmentation of green corridor,
Loss of Farm Terrace allotment site - should be offset elsewhere as open space / community food growing / ecological resource.
SPA4 Lower High Street
Recognised sites adjacent / close to Site: Bushey Hall Farm ecosite, Oxhey Park ecosite.
Other features: "Recreation Allotments" village green.
Protected species: Unknown - no records. Birds in trees.
Opportunities: Limited as previously developed site. Potential green corridors along railways lines.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA5 Dome Roundabout (includes a Waste Transfer Station at Colne Way)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA6 Western Gateway (includes area of search ELAS221 in the Hertfordshire Waste Site Allocations Document)
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite, Ascot Road ecosite.
Recognised sites adjacent / close to Site: close to eastern end of Croxley Common Moor Site of Specific Scienttific Interest (SSSI) and LNR.
Other features: Grassland strip along eastern boundary with bordering trees.
Protected species: Unknown - no records.
Opportunities: Enhance green infrastructure corridor along eastern boundary.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds in trees.
The ecosites have largely been destroyed by development.
MXD1 North Watford library, Lemarie Centre for Charities, and health facilities (within SPA5)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
MXD2 The Brow
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
MXD3 Gas holder site (within SPA4)
Other features: River Colne borders the eastern boundary.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site. Potential to enhance the river margins as a green corridor.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in the trees.
Largely developed but riverside trees most important and scrub on site.
MXD4 Ascot Road
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite.
Other features: As well as the rough ground and bordering trees of the area to the west, the Site includes part of the school playing fields to the east, which is short mown amenity grassland. There are also some mature trees.
Protected species: Unknown - no records.
Opportunities: Potential enhancement of the areas of semi-natural habitat to improve green corridor connectivity.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds. Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R1 Sainsbury's and adjoining land
Other features: The north-eastern part of the Site includes an area of grassland and mature trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R2 Former TJ Hughes and adjoining land
Other features: Small area of amenity grassland on the north-eastern side.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R3 BT Telephone Exchange and adjoining Wellstones
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R4 Church Street Car Park and land fronting Market Street/Market Place
Other features: area of amenity grassland and scattered trees on the southern side.
Protected species: Unknown - no records.
Opportunities: Limited as predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R5 Charter Place centre and adjoining land onto the High Street
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
CF1 Community Facility Tolpits Lane.
Other features: Site appears to be rough grassland with scattered scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to enhance the habitats on site. The northern boundary is a wooded bank bordering the railway line. Maintain / enhance green corridor along railway.
Ecological sensitivity: Low - medium as semi-natural habitats on site.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H1 Land at Pinner Road
Other features: There are small areas of rough (possibly amenity) grassland with scrub and scattered trees.
Protected species: Unknown - no records.
Opportunities: Limited as a predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H2 Skatepark, Lower Derby Road
Other features: There is an area of grassland with trees in the north-west corner.
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a predominantly a previously developed site. Potential to maintain / enhance the semi-natural habitats on site for green corridor links to nearby habitats, river corridor and wooded railway banks.
Ecological sensitivity:
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H3 Vicarage Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H4 Telephone Exchange - First Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H5 Builder's Yard, Queens Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H6 Bill Everett Community Centre
Recognised sites adjacent / close to Site: adjacent to Long Spring and Harebreaks Wood (Watford) Local Wildlife Site and Local Nature Reserve.
Other features: some areas of grassland (probably amenity?) and occasional scattered trees.
Protected species: Bat roost in building nearby.
Opportunities: Potential to link woodland to the south to area to the north - depending on what the latter is like, as it appears to be bare ground on our aerial photographs.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H7 Rickmansworth Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H8 Garages- The Gossamers
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H9 Watford Station, Cassiobury Park Avenue
Recognised nature sites within Site: Cassiobury Park Avenue allotments ecosite.
Recognised sites adjacent / close to Site: close to "Gade Avenue" Local Wildlife Site.
Other features: Includes an area of allotment gardens and mature trees.
Protected species: Unknown - no records. Potential for bats and reptiles.
Opportunities: Maintain and enhance the green corridor link along the railway line.
Ecological sensitivity: Low - medium?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H10 Croxley View
Other features: Area of semi-natural grassland with scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to manage the existing habitats to maintain / improve biodiversity. Maintain as a green infrastructure link from open grasslands to the south towards the River Gade corridor and semi-natural habitats to the north
Ecological sensitivity: Low.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H11 Garages, Bowmans Green
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
GT1 Lands at Tolpits Lane
Other features: Area of rough grassland with bordering trees.
Protected species: Unknown - no records.
Opportunities: Limited, but part of semi-natural grassland complex in the area so potential for linking hedgerows. Any loss of grassland could be compensated for by enhancement elsewhere and landscaping may provide additional buffering habitats locally if this site were to be developed as such.
Ecological sensitivity: Low?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
E1 Watford Business
Recognised sites adjacent / close to Site: adjacent to Croxley Common Moor Site of Special Scientific Interest (SSSI and Local Nature Reserve (LNR) and Commonland; adjacent to Ascot Road Car Park and Waste ecosite, adjacent to Ascot Road ecosite; close to Ascot Road Scrub Local Wildlife Site.
Other features: Some areas with trees.
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
Part of the edge of this currently provides a valuable buffer and boundary edge to Croxley Common Moor SSSI and LNR. We would object to any development which further degraded this boundary habitat, although much of the former area has already been lost to hard surfacing.
E2 Imperial Way / Colonial
Protected species: Limited as a previously developed site.
Opportunities: Low.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E3 Fishers
Recognised nature sites within Site: Cardiff Road Embankment ecosite.
Recognised sites adjacent / close to Site: adjacent to Croxley Green Junction Sidings Local Wildlife Site.
Other features: Disused railway line to the west is bordered by woody vegetation.
Protected species: Unknown - no records.
Opportunities: Potential green corridors east / west across the site and along the western boundary. Maintain a buffer against LWS to the south.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
E4 Greycaine Road / Odhams / Sandown Road
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E5 Clarendon Road / Station Road / Bridle Path Office Area
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E6 Leavesden Studios - the Island site
Recognised nature sites within Site: part of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Recognised sites adjacent / close to Site: adjacent to the rest of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Other features: Semi-improved grassland habitat, part of a much larger complex.
Protected species: Badger setts on site and nearby.
Opportunities: Linking habitats to similar adjacent grasslands.
Ecological sensitivity: Low - medium.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species, with particular attention to badgers

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 857

Received: 03/10/2016

Respondent: Hertfordshire County Council SLU

Representation Summary:

The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.

Full text:

Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
With regard to Policy SPMX1: Special Policy Areas, the council is pleased to see the insertion of reference to the county council's documents. The text should however refer to the' Waste Local Plan' which includes both the Waste Core Strategy and Development Management Policies document and the Waste Site Allocations document.
With regard to Special Policy Area 2: Watford Junction, the council is pleased to see that there is reference to the need to safeguard the rail aggregates depot at Orphanage Road.
Further information on SPA2 is contained in Appendix I: Site Schedules of the Local Plan Part 2. The council is pleased that the rail aggregates depot is included as a
Spatial Planning and the Economy
Environment Department
Hertfordshire County Council
County Hall
Hertford
Hertfordshire
SG13 8DN
paul.donovan@hertfordshire.gov.uk
01992 556289
Planning Policy Team,
Room 65,
Watford Borough Council,
Town Hall,
Watford,
Herts,
WD17 3EX.
development consideration where it states 'This will need to be retained, or a new comparable facility provided within the local area'. However it should be noted that the text should refer to the 'rail aggregates depot' as opposed to the 'waste aggregates depot'.
However, in practice, taken together with the masterplan and accompanying viability report, there appears to be a strong likelihood that the rail aggregates depot is not to be retained on site and the collective impact of the Local Plan is not to safeguard the rail aggregates depot. Given this, the Inspector may well wish to see what evidence exists with regard to securing a replacement facility and currently no such evidence accompanies the Local Plan. As a consequence, there is considerable uncertainty in relation to whether the Local Plan satisfies potentially all soundness tests.
With regard to SPA6 Western Gateway, this includes ELAS221 and it is also worth pointing out that the areas designated as PS2 and PS3 potential in the Croxley View/Ascot Road Masterplanning Study are also located in ELAS221.
It is agreed that it is useful to insert text in relation to the circular economy as part of the waste section under paragraph 3.30, supporting text to Policy SD10: Waste. The second bullet point should state 'drive greater resource productivity.'
The relevant policy basis has been applied in the waste section and the Watford Local Plan with regard to responsibility for waste management. Whilst there appears to no longer be specific reference to Waste Policy 12, there is text to cover the use of this policy along with others within the Waste Core Strategy and Development Management Polices document. One comment to make is that in the wider context of the Watford Local Plan with there also being reference to ELAS221, the text in paragraph 3.30 should refer to the Waste Local Plan, which covers policies within the Waste Core Strategy and Development Management Policies document, adopted November 2012 and the Waste Site Allocations document, adopted July 2014.
Watford Junction Development Brief
As previously stated, most recently in respect of the Infrastructure Delivery Plan, the key matter of concern to the Minerals and Waste Planning Authority is the impact that any proposed development may have upon the safeguarded rail aggregate depot located at Orphanage Road, Watford which is a current operational facility.
The planning policy status, as detailed within the introduction of the brief, refers to consideration being had to national planning policy and the Watford Borough Council Local Plan. To ensure that the Development Plan has been considered as a whole the brief needs to also refer to the Minerals Local Plan and the Waste Local Plan. In terms of national policy, there is the need to ensure that the NPPF is considered in respect of para 143 which states that Mineral Planning Authorities should safeguard existing, planned and potential rail heads, so as to prevent their redevelopment for other uses and loss of the mineral infrastructure. This safeguarding is also applicable to storage, handling and processing facilities associated with them.
It is considered that due to the location of the rail aggregate depot within the development brief area that the county council's Minerals Local Plan 2002-2016, adopted March 2007 is also considered with specific regard to minerals policy 10: Railheads and Wharves. The Minerals Local Plan is being reviewed at present. It is envisaged, due to the requirement of the NPPF, that there will be a policy on Rail heads and Wharves in the Draft Minerals Local Plan.
The siting of the rail aggregate depot is shown within the county council's Mineral Consultation Area Supplementary Planning Document, adopted November 2007. The consultation area covers the majority of the Special Policy Area 2 Watford Junction. In accordance with the NPPF and Minerals Local Plan, in respect of minerals policy 10 the county council seeks to safeguard the rail aggregate depot which continues to serve as a sustainable mode of transporting minerals over long distances and the concrete batching facility which this site also supports. Given that the site is viable for use as a rail aggregate depot, its retention is expected unless the facility can be satisfactorily relocated within the development proposals in terms of operational requirements and environmental criteria or it has been or will be replaced in an alternative location.
The development brief identifies the rail aggregate depot as being a 'weakness' for the redevelopment of Watford junction in the SWOT analysis in paragraph 2.1. Minerals are important to the economy. Aggregate is needed to facilitate development and volumes of construction material being transported by rail in increasing. In light of this it could be considered that a rail aggregate depot in close proximity to the construction project could be considered to be a strength.
The issue of addressing such a 'weakness' is not however further expanded upon. It is clear from the illustrative masterplan that the retention of the rail aggregate depot is not part of the scheme. Whilst it is intended to be flexible enough to accommodate alternative layouts so long as it achieves the guiding principles and core ambitions of the masterplan, there does not appear to be sufficient scope to accommodate the existing or a relocated rail aggregate depot within the redevelopment area. As such this leaves the only option of relocating the rail aggregate depot offsite at another location along the railway line.
There is the need to establish an alternative well positioned strategic location for the rail aggregate depot to ensure its continued operation for imports and exports of minerals and secondary and recycled aggregates. The SWOT analysis in the development brief states that there is a 'weakness' in terms of a lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling. The Borough Council is referred back to paragraph 143 of the NPPF, the adopted Minerals Local Plan and specifically minerals policy 10 and the adopted Minerals Consultation Area SPD as detailed above in terms of the clarity for the safeguarding of the rail aggregates depot at Orphanage Road.
The brief states under the land use and quantum section of Station Quarter East within paragraph 3.4 that the development will be required to relocate the Rail Aggregates Depot within the local area, in consultation with Hertfordshire County Council and the operator of the site. The County Council will continue to work with the Borough Council in respect of this matter. The land use and quantum section in
paragraph 3.4 should also refer to the need to work with Network Rail with regard to the relocation of the Rail Aggregates Depot. The County Council understands that Network Rail Freight Management has been consulted and will provide comments to this consultation. There is however no further detail with regard a precise location having been secured.
To this end the relocation of the rail aggregate depot is fundamental to the delivery of the masterplan. A statement should be made in the delivery section of the brief at paragraph 4.1 specifically in relation to the requirement to ensure that the relocation of the rail aggregates depot forms part of the Watford Junction Delivery Plan.
Croxley View/Ascot Road Masterplanning Study
The Croxley View/Ascot Road Masterplanning Study has been considered by the county council as Waste Planning Authority due to the proximity of redevelopment to the Employment Land Area of Search (ELAS) 221 Watford Business Park.
The masterplan aims to build on the policy foundations of the district Local Plan Core Strategy Policy SPA6 to facilitate redevelopment. The location of potential residential development is shown within the Masterplanning Study to be directly adjacent to ELAS221 as designated within the county council's Waste Site Allocations document 2011-2026, adopted July 2014.
It is considered that ELAS that are predominantly used for general industry (B2) and storage and distribution (B8) are compatible with waste management uses. ELAS221 contains B1 and B2 uses and as such is acceptable in principle for a range of potential waste uses listed in the general waste brief during the 15 year plan period 2011-2026. Further planning guidance into the suitability of waste related development on the identified ELAS is within the ELAS Supplementary Planning Document, adopted November 2015. For this area, the Supplementary Planning Document states 'only enclosed waste transfer stations and materials recovery facilities that handle dry recyclables would be acceptable, along with enclosed inert waste recycling facilities. No other potential uses that may generate a leachate or liquor, which poses a risk to groundwater resources would be appropriate'.
The council does not wish to see the loss of identified ELAS for non-waste uses in order to safeguard it for future potential waste uses that may be sited in this location. Whilst the residential development would not directly encroach onto the ELAS, the council is mindful that the residential development is identified along the eastern boundary of the designated site and as a result there could be the potential for indirect impact upon the siting of waste uses within the ELAS.
The Waste Local Plan does not rely on the need for all land within ELAS across the county for the delivery of waste uses. However the cumulative loss of ELAS to non-waste uses is monitored and the safeguarding of remaining ELAS land is important to ensure there is a sufficient amount of land that could come forward for waste management facilities in the future, particularly with additional growth resulting in an increase in waste produced which needs to be managed.
There are currently no extant planning permissions on land directly adjacent to the masterplanned residential development to be aware of. The nearest waste site is the Household Waste Recycling Centre at Caxton Way in ELAS221. There is sufficient land remaining in ELAS221 to be brought forward for waste management uses.
The County Council does not wish to object to the masterplanning for potential residential development at this stage but reserves its right to object to future planning applications adjacent to the ELAS should a waste site be development in advance of residential. The reason for this would be to safeguard any waste use(s) under waste policy 5: Safeguarding of Sites within the Waste Core Strategy and Development Management Policies document 2011-2026, adopted November 2012. Further discussions would need to take place in the event that negative effects are identified that would restrict the waste operation to continue. A buffer between two land uses or mitigation measures in some cases may be appropriate to allow opposing land uses to exist in harmony adjacent to each other.
The County Council's adopted Waste Core Strategy and Development Management Policies document, does not stipulate a distance whereby other development in close proximity to a safeguarded waste site should be discouraged, the 2004 ODPM document: Planning for Waste Management Facilities: A Research Study states that for waste transfer stations: "sites closer than 250m from residential, commercial or recreational areas should be avoided." This guidance was used in the production of the Waste Site Allocations document. Depending upon the location of any potential future waste management facility within the ELAS, there is the potential that facilities may well be sited closer than the suggested 250m to any future housing.
Transport
Overarching/ general comments
Watford and the surrounding transport network face growing challenges as a result of the desired housing and economic growth in the area and increasing demand for travel. The County Council is developing a countywide transport model that will help all local authorities in the county to plan positively for growth and infrastructure investment in a way that safeguards the health and wellbeing of our communities and the environment. Already the model has identified notably worsening congestion issues in the Watford area as a result of planned growth. The next outputs of the enhanced Watford area version of the model will be available by the end of October 2016. The existing model is already available to Watford Borough Council to test development scenarios and proposals from the Local Plan.
In parallel with this, the County Council is developing a Growth & Transport Plan for South West Hertfordshire, which includes Watford and the surrounding towns and transport networks that make up a coherent area of travel demand. The Growth & Transport Plan will put forward packages of transport interventions to respond to strategic transport challenges and objectives for the area, derived through robust evidence analysis and engagement with stakeholders. Watford Borough Council officers and members have been involved from the early stages in GTP workshops
at key stages. The GTP is about identifying needs, planning for and enabling investment and delivery of a transport network and public realm that will support a healthy economy, environment and communities.
As a result of the current ongoing work being incomplete, at this stage there is insufficient evidence available to assess the implications of Local Plan Part 2 on the transportation network. As a consequence, there is uncertainty in relation to the mitigations that will be required to support the proposals and we remain in doubt that it potentially satisfies all soundness tests.
Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
Contents
'Appendix I - Site Allocations' is referred to later as 'Site Schedule'
'Appendix L' and 'Appendix M' missing from content list
Policy SD10
Refuse collection vehicles must be able to stop within the 'maximum refuse carry distance' specified by the Local Planning Authority or within 25m of any bin storage area, whichever is the lesser distance. Residents should not have to carry their rubbish more than 30m to a storage point. (Sources BS5906:2005 and Schedule 1 Part H Building Regulations)
Policy TLC14
On-street parking continues to need to be managed to manage congestion and avoid hazards, particularly at junctions.
Policy HS7
The subjective "undue pressure" on on-street parking should not lead to increased congestion and / or hazards on the highway network, particularly at junctions.
The siting of bin stores should not adversely impact on the operation of the highway network.
Policy HS8
The Highway Authority recommends that consideration of deliveries is made explicit in this policy.
6.9 and Policy EMP5
The County Council supports urban realm enhancement of Clarendon Road to encourage walking and cycling and improve the key pedestrian route between the town centre and Watford Junction.
Consideration should be given to amending the policy wording to explicitly include an expectation for development along Clarendon Road to contribute towards urban realm enhancements directly through works delivered or through developer contributions to fund such works.
Policy T6
The County Council is supportive of the zonal approach to car parking guidance to encourage lower car ownership and usage in more accessible zones. The principle of 'Car Lite' development in the most accessible areas, within 5 or so minutes' walk of a major transport hub, is also supported as long as the needs of disabled drivers and visitors are considered.
Lower car parking provision must be accompanied by appropriate restrictions in surrounding residential streets and any public car parks to prevent spill-over parking. In order for this approach to lowering car usage to be successful, there needs to be parallel investment in infrastructure (eg significantly better cycle and bus routes) and urban realm improvements to support and actively encourage alternative modes of travel.
The County Council welcomes the requirements for car club spaces in the SPAs and where parking does not meet the guidance.
Policy T8 and Appendix H
The policy on cycle parking provision and the stipulations relating to quality contained in the policy is welcomed. Adequate cycle storage must also be provided for existing and high predicted future levels.
A small change is recommended to allow for cycle parking provision for dwelling houses to be in a private garage as well as within the private garden area - subject to the dimensions of the garage being adequate to accommodate cycles as well as any vehicle.
However, the policy only specifies one long-term space per unit (regardless of size or location) where there is no garage or shed. In some instances such as within SPA2 and SPA6 where housing will be in the form of apartments and where there will be reduced car parking, it may be necessary for additional capacity for cycle storage beyond one space per unit, especially for larger flats or any flats without car parking provided.
Policy UD3
Structures abutting and overhanging the public highway will need the approval of the Highway Authority (HCC) as will illumination visible from the highway.
Policy TB1
From a transport network and user perspective, locations near to major passenger transport hubs, offering good interchange between different services and modes, are the most appropriate for denser development (i.e. taller buildings). However, development proposals should all be subject to Core Strategy policies T2-T5 to ensure that their impacts are understood and mitigated.
In order for such development to be acceptable, there must be adequate and appropriate improvements to transport infrastructure and urban realm within the site and in the wider area, to ensure no significant adverse impact on the highway and passenger transport networks, as a direct, indirect or cumulative result of development at the site and in the Borough as a whole.
Policy TB2
Suggest change to text at 8. Transport, parking and infrastructure:
'The design should detail a transport strategy for the proposed development to include how cycle parking, car parking, cycle permeability and pedestrian permeability have been integrated into the overall design. This should be based on a Transport Assessment and should avoid negative impacts on the public realm. The scheme will also need to demonstrate that the required infrastructure and utility capacity has been fully appraised.'
Appendix G
Parking bay dimensions only seem to consider residential element, parking bay at 2.4 x 4.8m is fine for standard bay but dimensions of other bays should be provided e.g. parallel arrangement. The garage dimensions provided are 3m x 5.5m whereas the industry standards are 3m x 6m (MfS para 8.3.41). Should minimum circulatory space for car parks be covered here (i.e. 6m) or will it be covered elsewhere?
SPA1
The ring road constrains pedestrian and cycle accessibility to the heart of the town centre. nb includes EMP5, R1, R2, R3, R4, R5. See Highway Authority comments in regard to each of these.
SPA2
Any development within the Watford Junction SPA should ensure that connectivity for pedestrians and cyclists is improved across the site, between the site and the town centre and on other key routes to Watford Junction Station.
Development of the station building, forecourt and car parks must address current limitations including capacity, access and circulation issues, for pedestrians, cyclists, buses, bus users, taxis, as well as users of the car parks. Opportunities to make Watford Junction an attractive and functional transport interchange that can accommodate future growth should be maximised.
See Highway Authority comments on Draft Development Brief (below).
SPA3
Good quality cycle and pedestrian links through the site and between the site and surrounding area and key destinations (town centre, Vicarage Road MLX station, local schools etc.) must be provided, or contributions to support infrastructure improvements in the wider area made through developer contributions.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
SPA4
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
Support improvements to green infrastructure and public realm as a complement to improvements to pedestrian and cycle links.
Flooding is a known issue affecting this area. Any development in this area should be designed to avoid and mitigate flood risk. Sustainable drainage approaches and green infrastructure should be used where appropriate to reduce and manage flood risk.
SPA5
Development at this location will need to consider transport impacts on the highway network, including operation of the Dome roundabout and St Albans Road notably at peak times. Also junctions including M25/A405/M1, and M1/A41.
There is a need to improve cycle, pedestrian and passenger transport connectivity to the site, and between the site and the town centre and Watford Junction.
It is recognised that the Abbey Line (North Watford) station is closer to the site, but there are limitations to this service at present which will reduce its attractiveness as an alternative to the car for journeys to Watford Junction or St Albans Abbey stations.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
There is a typo on second bullet point - should read 'improve air quality'.
SPA6
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Cycle improvements on Rickmansworth Road may be required as this is a key corridor between Rickmansworth and Watford.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
Secure, high quality cycle parking is needed at the proposed Cassiobridge station, as well as within the employment premises.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
See Highway Authority comments on Masterplanning Study (below)
MXD3
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
R1
It is agreed that robust pedestrian links with the town centre should form part of the new development at this location.
Good cycle access and high quality cycle parking also needs to be provided, for customers as well as employees.
R2
Agree that clear pedestrian connections between the site and the High Street are needed.
Good cycle access and cycle parking must also be provided.
There is a need to consider access needs to the site by different modes. A planned highway improvement scheme will make Clarendon Road one-way (NE-SW only) from Beechen Grove to High Street, with a contraflow cycle lane. Access to the street will be restricted by a Traffic Regulation Order to buses, taxis, cycles, 'blue badge' vehicles, and other vehicles 'for access only' to premises. All accessing vehicles will need to leave either via High Street or Watford House Lane (private road) for those accessing that area.
Development of this site should complement public realm enhancements proposed or already delivered on Clarendon Road and the High Street.
R3
Good cycle access and storage facilities must be provided, as well as good pedestrian links.
Developments at this location must take into account severance issues caused by the ring road for pedestrians and cyclists. Improvements required such as crossing improvements, new accesses into/through the site, should be delivered as part of the development or through developer contributions.
R4
Strong pedestrian and cycle links between this site and the town centre must be provided.
The quality of cycle routes and access to/from the west needs to be improved - eg. Market Street west of ring road and the Hornets Gyratory.
H1
This site is in close proximity to Bushey Station and includes its car park.
Opportunities to upgrade access to the station by non-car modes should be pursued.
Need to consider quantity and quality of cycle parking and cycle access to station from surrounding area.
Cycle access and cycle parking provision at Bushey station should be improved as part of any car parking replacement/improvement scheme.
Bushey Arches is a known congestion hotspot. Impacts of development on Bushey Arches must be considered and mitigation provided. This should include contributions to needed improvements to key walking and cycling routes and passenger transport infrastructure in the area.
H2
The ring road causes significant severance to people travelling by foot and cycle. Particular issues have been reported for people with visual impairments.
Improved cycle and pedestrian links to town centre and to Watford High Street and Watford Junction stations are needed from the site.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
H3
This site is about half mile from both the proposed Vicarage Road Met Line station and Watford High Street station, which is 10 to 12 minutes walking time.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
Vicarage Road is a busy road without dedicated cycle facilities. As such improvements to this route for cyclists should be considered. Developer contributions to improving cycle routes may be appropriate.
H5
The traffic impact on west Watford's road network needs to be considered and mitigated.
Cycle and pedestrian links into the site from different directions are required.
Adequate cycle storage must also be provided for existing and high predicted future levels.
Cycle infrastructure and the pedestrian environment of the surrounding area needs consideration.
H9
The impact of development at this site on the road network must be considered and mitigated if needed, including Rickmansworth Road and West Watford.
Good cycle links are needed including between the site, the town centre, and Ascot Road.
Bus services and infrastructure, including linking to new Cassiobridge Met Line station.
Bus services in this area may well be subject to change following the loss of the underground station. Development of this site and any forthcoming S106 contributions would provide the opportunity for an assessment to be made of potential improvements to bus services so this site remains connected to key destinations.
E1
High quality, secure cycle provision is needed at business premises.
Although the Ebury Way provides a good cycle route to the site, this will not be suitable for use all year round, at any time of day. As such improvements to the A412 corridor cycle infrastructure should be explored and provided. Developer contributions may be appropriate.
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
E2
Cycle and pedestrian routes through the site need improvement;
Via Watford Junction SPA site, there is a need to reduce severance and improve pedestrian and cycle connectivity to Watford Junction station and Clarendon Road.
WBC also needs to consider the implications of the Colonial Way Link road on development at site E2.
There is a need to consider potential transport implications of this site and the Watford Junction masterplan as a whole, including traffic accessing any new station multi-storey car parks, and the impact on the road network (eg. Colonial Way, Stephenson's Way, Radlett Road, Link Road, A41/M1 junction...).
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions.
E4
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions and on footways.
E5
Needs to link with SPA2 Watford Junction.
Development will need to assess impacts on road network and car parking demand in surrounding area.
Quality of pedestrian and cycle environment and urban realm on Clarendon Road should be considered and opportunities to enhance in consistent, coherent way should be explored to promote sustainable travel and improve route between town and Watford Junction.
Buildings will need to provide adequate, high quality secure cycle parking. If low car parking, may need to increase requirements or leave space to expand provision as required.
G6
Any change in land use/ status/ access provision to the south of Caxton Way and the south and east of Greenhill Crescent should not be permitted until its ability to provide the link for sustainable modes between Tolpits Lane and Caxton Way required by paragraph 10.6.9 of the WBC Core Strategy has been fully explored and ruled out.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF
1.1
The traffic and transport impacts of the masterplan scheme have not been modelled and thereby understood. The Highway Authority is, therefore, unable to fully support the plan until those impacts are assessed and deliverable mitigation measures agreed. HCC is developing traffic and transport models of Watford as part of its work to create a Growth & Transport Plan for the area. These will be used to test the impacts of the Watford Junction and other development proposals on transport infrastructure and services individually and cumulatively.
As part of earlier work on this site the County Council had required the construction of a road and bridge linking Colonial Way and St Albans Road via Penn Road. The scheme to build it received outline DfT funding and included a passenger transport (coach) interchange on the northeast side of the station. If the link road and bridge are no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
1.2
Correct reference to 'Abbey Link' in map to 'Abbey Line'.
2.1
The Barriers plan acknowledges the severance created by the presence of the Abbey Line. As part of earlier work on this site the County Council had required the construction of a road over the Abbey Line linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.2
Policy T1 in the borough council's Core Strategy supports conversion of the Abbey Line from heavy to light rail operation.
Correct reference to 'Abbey Flyover' in Objectives to 'Abbey Line'.
2.3
Correct reference to 'Abbey train line' under Transport and Parking to 'Abbey Line'.
As part of earlier work on this site the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.4
Gross External Areas values are different to those in 5.1 Area Schedules.
3D views might benefit from road names for orientation.
2.7
As part of earlier work on this site, the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
It is recommended that all roads are usable by cycles to aid permeability.
The road hierarchy titles have different meanings in the Highway Authority's own existing hierarchy. As the design is refined it is recommended that confusion is avoided by using different names.
2.8
The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.
3.3
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
3.4
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
4.1
The County Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order that they can be considered in the emerging Watford Growth & Transport Plan. Joint working with the County Council will remain key in order to maximise access to appropriate funding streams and delivery programmes.
Special Policy Area 2 is zero-CIL-rated so that all planning obligations will be derived via Section 106 agreements with service providers.
4.2
An overall Travel Plan for the site will be required and one for each subsequent development area should be provided and agreed.
5.1
Total car parking number differs from that given in 2.4 and Station Quarter East breakdown (p 46).
Gross External Areas values are different to those in 2.4.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF VIABILITY APPRAISAL
4.2
The County Council is concerned about the unrealistically low estimates given in figure 4.1 for the costings of infrastructure required to mitigate the impact of the masterplan.
CROXLEY VIEW/ ASCOT ROAD STUDY
Introduction
Mention must be made of the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The need for a link both for Watford and Three Rivers grows as pressure to develop either side of the Ebury Way increases and its delivery should be seen as key to both authorities' Duty to Cooperate.
Plans
All plans refer to Watford County Council.
All plans show Croxley Green Business Park to the southwest of the masterplan area. This is correctly the Wolsey Business Park.
Most plans show the Grand Union Canal badged as the River Gade which runs to the south and east of it.
Some plans do not show the correct alignment of the Watford/ Three Rivers boundary.
Some plans erroneously label the NE corner of Croxley Common as Cassiobury Park Nature Reserve.
Masterplanning Strategy plan - asterisks and other labelling are not described and inconsistently applied.
Potential Development Sites plan
This omits to include the Tech Site (around Woodshots Meadow). This is subject to preapplication discussions now and should be considered with the adjacent sites as it is in Employment Policy Area E1 (Local Plan Part 2 appendix 1).
Proposed Vehicle and Pedestrian Movement plan
This omits the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The route currently being explored follows the cycle track between the Watford Enterprise Centre and number 27 Greenhill Crescent.
Historic environment, landscape and ecology
The County Council supports the overall policy intentions of the Local Plan covering landscape, ecology and the historic and built environment and provides the following comments to help strengthen these policies and their supplementary text.
Historic Environment
Development Management Policies
The County Council welcomes the Borough's consideration of the Historic Environment in Part 9 Urban Design and the Historic Environment. However, the historic environment should be referenced in line with the NPPF definition of heritage assets. In addition to historic buildings (both designated and undesignated), the historic environment of Watford includes archaeological remains, historic landscapes and historic parks. Therefore policies are needed to conserve the historic environment as whole, not just designated buildings, registered gardens and conservation areas as is currently stated.
Under Policy UD4, Archaeology, there appears to be repetition of the NPPF, the policy is unclear and should be re-written.
There is also reference to the conservation of heritage assets being secured by an archaeological Written Scheme of Investigation (WSI). Whilst the County Council welcomes the requirement for these documents and for them to include provision for publication and public dissemination of results where appropriate (NPPF 141), it is not clear if the WSI on its own is considered to be robust enough to secure appropriate conservation of the historic environment. Therefore it is unclear if this part too, is effective.
Watford Junction Draft Development Brief 2016
Paragraph 4.2 notes that a Heritage Statement and Desktop Archaeological Study may need to be submitted with any planning applications. However, it is unclear what is meant by a Heritage Statement. Also archaeological assessment may not be limited to a desktop study.
Site Allocations
An appraisal of the archaeological implications of development for the new areas identified in the Second Consultation document (2016) is summarised below.
1. Archaeology as a Development Constraint
N/A
2. Requirement for Pre-allocation Archaeological Assessment
The sites below have known archaeological remains within them or have significant archaeological potential by reason of their size and situation, such that there is a risk that archaeology could be a constraint on any development. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that archaeological assessments should be included within all development briefs and other proposals for the sites, before they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the sites, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent of archaeological remains that might be a constraint upon the principle of development of these sites.
Allocation numbers: SPA1, SPA4 and H9.
3. Requirement for Pre-application or Pre-determination Archaeological Assessment
The sites below have known archaeological remains within them or have archaeological potential. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that that pre-application or pre-determination archaeological assessments should be included within all development briefs and other proposals for the sites, if they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the proposals, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent
of archaeological remains worthy of preservation in situ, to enable the LPA to determine any specific application for development.
Allocation numbers: SPA 2, SPA3, SPA5, SPA6, MXD1, MXD3, R1, R2, R3, R4, H2, H3, H4, H 10, E1, E2, E3, E4, E5, E6.
4. Mitigation of archaeological impact by condition
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, any archaeological issues can probably be dealt with by condition, should planning permission be granted.
Allocation numbers: R5, CF1, H1, H5, H6, GT1.
5. No archaeological requirements
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, there are unlikely to be any archaeological implications. However this will depend on the details of any proposals and any new archaeological information.
Allocation numbers: MXD2, MXD4, H7, H8, H11.
Ecology
Development Management Policies
Policy SD15, External lighting, the County Council support the provisions set out in this policy and advise that there should be reference to the guidance provided by the Institute of Lighting Engineers which has been instrumental in seeking to reduce the impacts of artificial lighting within the environment.
Green Infrastructure, Biodiversity and Recreation, the County Council supports the reference to Green Infrastructure (GI).In defining GI there should also be reference to the provision of local food production as a key ecosystem service.
Policy G15, Trees, Woodlands and Hedgerows, this policy is supported in respect of highlighting ecological and cultural value of trees, woodlands and hedgerows. However, under paragraph 10.3, the reference to valuable habitats should be extended to include reference to ecological networks and corridors. Under paragraph 10.6 it should be clarified that replacing trees lost to development cannot compensate for the loss of biodiversity or amenity value in the short term.
Policy GI6, Protecting and Enhancing the Grand Union Canal, this policy is supported including the reference to enhancing biodiversity under paragraph 10.11. It is advised that the policy is extended to include a clause that seeks to improve the biodiversity of the canal corridor where possible. Development that would have an
adverse impact on the biodiversity of the canal would not be supported unless it can demonstrate provision of suitable mitigation or compensation.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, this policy is supported however recommend the following clarifications and amendments.
It is advised to make reference to the 'amenity value' of the river, specifically encouraging 'recreation' may increase disturbance to sensitive wildlife within river corridors. The term 'amenity' embraces visual and recreational importance without being too prescriptive or disruptive if more sensitive habitats or locations are affected an important consideration within this largely urban area.
With regards the provision of 'a corridor for wildlife and biodiversity,' the reference to biodiversity should be deleted as wildlife is biodiversity. With regards replacement structures and fish passage, liaison with the Environment Agency is essential if any such works are proposed. With regards access it should be designed in a way that also enables some undisturbed areas to be retained.
Policy GI9, Provision of Open Space and Play Space in Residential Development, aspects of this policy relevant to biodiversity are supported. The reference to green space typologies should be expanded to include allotments and community orchards, in order to reflect the types of functional sites which support both community and biodiversity benefits.
Biodiversity, it is not clear why this section is formatted differently to the preceding and subsequent sections. In particular it does not describe 'Why is this policy needed?' and 'what is it intended to do?' In setting out the need for the policy, it should reference the legislative requirements of statutorily protected sites and species which are a material consideration in planning, as well as the Duty placed on Local Authorities to have regard to conserving biodiversity in all of their functions as set out in the Natural Environment and rural Communities Act 2006. In setting out the intention of the policy there should also be reference to seeking to deliver the aims of the Local Nature Partnership - for which securing ecological resources, functions and services are a consideration when determining planning applications.
Under paragraph 10.37 the reference to the 'Biodiversity Plan' should be amended to reference to the 'Biodiversity Action Plan principles' (BAP). The BAP, nationally and locally, has ceased to be actively supported by National and Local Government, and has essentially been replaced by the Local Nature Partnership. However the principles underpinning it remain valid as statements and the intentions of the various habitat and species action plans are sound in themselves and could be followed if resources or interest permitted.
It is suggested that the statement under paragraph 10.39 should be amended as follows:
'This policy expects that where appropriate, development proposals will demonstrate the relative ecological value of a site before and after development. Proposals should follow the mitigation hierarchy and provide clear evidence of impacts and enhancements where appropriate, consistent with the aims of NPPF, BS42020
"Biodiversity - Code of Practice for Planning and Development'' and guidance provided by CIEEM. This will require sufficient detail and clarity to enable net losses and gains to be identified and monitored, consistent with the Code. Where unavoidable, Biodiversity Offsetting should be considered as a means to ensure there is no net loss of biodiversity resulting from development'.
Highlighting the specific use of Biodiversity Calculators such as the one mentioned in paragraph 10.39 can be a little misleading. BS42020 does not mention the use of biodiversity calculators, and taken out of context the results of such calculations can sometimes show net gains where there should be none (removal of ancient woodland for example cannot reasonably be compensated in the real world). Other wider landscape issues are also not always considered by these calculators; if the land is part of a wider corridor, or a biodiversity network for example. It has taken several years for Warwickshire County Council to incorporate their use in to the planning system and there is still not universal agreement on them.
The County Council would therefore advise caution on their avocation, but rather emphasise the need to prove that biodiversity has not been lost and in the most part enhanced through "appropriate methods in-line with BS42020".
Policy GI10 Managing Biodiversity in new Developments. The County Council supports Watford Borough Council's commitment to increasing biodiversity within the district. The Policy is consistent with other Hertfordshire Local Authorities, and in-line with the National Planning Policy Framework.
The following amendments are advised. There should be reference to avoiding negative impacts upon ' local ecological networks...,'as each site sits within a local environmental and should retain or enhance any existing ecological resources or corridors to and from adjacent sites.
'Compensation will only be considered as a last resort. Development proposals will be expected to evaluate the impact on local biodiversity where appropriate and propose measures to maintain and enhance biodiversity. This approach should follow the principles outlined within BS42020 "Biodiversity - Code of Practice for Planning and Development" or other measures of best practice, including Biodiversity Offsetting where necessary'.
The above wording embraces the mitigation hierarchy as well as defining means to achieve no net loss as sought by NPPF, without being too prescriptive.
It is considered that paragraph 10.40 regarding the biodiversity calculator is not needed if references requiring its specific use are otherwise removed. The County Council remain concerned that some caution needs to be taken regarding the generation of positive scores which indicate a net gain despite losses that may otherwise be considered unacceptable.
Site Allocations
Please refer to Appendix 1.
Landscape
Green Infrastructure, Biodiversity and Recreation, the policy framework for green infrastructure (GI) was significantly strengthened in Feb 2016 with the introduction of detailed Planning Policy Guidance. The guidance states that GI is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water and should be a key consideration in both local plans and planning decisions.
The Herts Landscape and Green Infrastructure Group is currently looking at GI delivery and practice across Hertfordshire with a view to presenting a project proposal to Herts Infrastructure Planning Partnership (HIPP) in November. The key aim of the project is to mainstream the delivery of GI through the local plan and development management processes. The outputs and deliverables of the project are currently being shaped and should help provide local planning authorities with a good practice approach to GI delivery, supported by robust evidence and case studies.
The Landscape Institute Position Statement for Green Infrastructure provides a widely supported definition of GI (assets and functions) and a comprehensive overview of the key benefits it can deliver, supported by case studies http://www.landscapeinstitute.org/policy/GreenInfrastructure.php
There is no reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans. (The strategies provide an opportunity to address cross boundary issues and meet the Duty to Cooperate. (Hertfordshire and GreenArc Area Strategic Highlights Plan (SHiP) and the All London Green Grid.)
There should be greater emphasis on GI in place-making and conserving and enhancing local distinctiveness. There should be reference to any local character assessments and the guidelines for managing change that should help shape proposals, and conserve and enhance local character.
At a national level there is also the National Character Areas produced by Natural England https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making, and at a regional level there is the East of England Landscape Framework http://landscape-east.org.uk/.
Where proposals are likely to result in landscape and visual effects a landscape and visual impact assessment, in line with industry good practice guidance (Landscape and Visual Impact Assessment third edition Landscape Institute and Institute for Environmental Management and Assessment) may be required as part of an application. The mitigation hierarchy should be referenced to ensure that proposals seek to avoid and minimise any negative effects.
The reference to Green Infrastructure under paragraph 10.1, is fully supported, however it is suggested to expand the definition to include reference to blue assets
such as the Grand Union Canal. Also suggest amend reference to 'mitigating climate change' to 'mitigating the effects of climate change.'
Under paragraph 10.3, it should be clear that biodiversity is not the only driver for Green Infrastructure; other key drivers include a single or multiple land-use functions and include waste/water management, recreation, food production, local distinctiveness etc.
Policy GI5, Trees, Woodlands and Hedgerows, the reference to the protection of trees in line with current British Standard Institute code of practice is fully supported, however the full title of the standard does not appear to be referenced and should be 'Trees in relation to design, demolition and construction' (BS5837:2012). In addition it is advised that where required by the planning authority, tree surveys, arboricultural impact assessments and method statements should all be carried out in compliance with this standard.
The policy should be expanded to include reference to the current hedgerow regulations, the provision of a landscape strategy, planting plans and specifications, and the provision of aftercare (long term management plans) and replacement of failures.
Policy GI6, Protecting and Enhancing the Grand Union Canal, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Yours sincerely,
Paul Donovan
Environment Department
Hertfordshire County Council
APPENDIX 1
Please find below a brief ecological assessment of the site allocations. A 'standard' template for each Site has been provided.
Ecosites do not have any form of status of importance, but are merely sites that we have some ecological information on - thus they do support some wildlife interest, at least at a local level. Whilst these sites are often a valuable starting point in identifying the county's wildlife resource, they do not meet the rigorous and quantifiable assessment criteria needed to identify them as non-statutory Local (County) Wildlife Sites.
SPA1 Town Centre
Recognised sites adjacent / close to Site: close to eastern end of Cassiobury Park Local Wildlife Site.
Other features: Little semi natural habitat present, possibly some mature trees.
Protected species: Probably bats, badger records to the west.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road)
Protected species: Unknown - no records
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA3 Health Campus (includes a Borough Council Depot and Waste Transfer Station at Wiggenhall Road)
Recognised nature sites within Site: The Lairage Land Local Wildlife Site (LWS) and Local Nature Reserve (LNR), Croxley Green Junction Sidings LWS, Oxhey Park River & Margins LWS; Riverside Road Waste Ground ecosite (local database site), The Island, off Cardiff Road ecosite, Oxhey Park ecosite
Recognised sites adjacent / close to Site: Horwoods Avenue Playground ecosite, Moor View ecosite, Cardiff Road Embankment ecosite.
Other features: includes village green - "Green situated between Riverside Road & the River Colne"
Protected species: Birds and Water voles.
Opportunities: High. Habitat management to maintain and enhance biodiversity interest, green infrastructure / corridors.
Ecological sensitivity: Medium to high depending on location.
Fundamental ecological constraint: Presumption to avoid development on Local Wildlife Sites, fragmentation of green corridor,
Loss of Farm Terrace allotment site - should be offset elsewhere as open space / community food growing / ecological resource.
SPA4 Lower High Street
Recognised sites adjacent / close to Site: Bushey Hall Farm ecosite, Oxhey Park ecosite.
Other features: "Recreation Allotments" village green.
Protected species: Unknown - no records. Birds in trees.
Opportunities: Limited as previously developed site. Potential green corridors along railways lines.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA5 Dome Roundabout (includes a Waste Transfer Station at Colne Way)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA6 Western Gateway (includes area of search ELAS221 in the Hertfordshire Waste Site Allocations Document)
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite, Ascot Road ecosite.
Recognised sites adjacent / close to Site: close to eastern end of Croxley Common Moor Site of Specific Scienttific Interest (SSSI) and LNR.
Other features: Grassland strip along eastern boundary with bordering trees.
Protected species: Unknown - no records.
Opportunities: Enhance green infrastructure corridor along eastern boundary.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds in trees.
The ecosites have largely been destroyed by development.
MXD1 North Watford library, Lemarie Centre for Charities, and health facilities (within SPA5)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
MXD2 The Brow
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
MXD3 Gas holder site (within SPA4)
Other features: River Colne borders the eastern boundary.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site. Potential to enhance the river margins as a green corridor.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in the trees.
Largely developed but riverside trees most important and scrub on site.
MXD4 Ascot Road
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite.
Other features: As well as the rough ground and bordering trees of the area to the west, the Site includes part of the school playing fields to the east, which is short mown amenity grassland. There are also some mature trees.
Protected species: Unknown - no records.
Opportunities: Potential enhancement of the areas of semi-natural habitat to improve green corridor connectivity.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds. Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R1 Sainsbury's and adjoining land
Other features: The north-eastern part of the Site includes an area of grassland and mature trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R2 Former TJ Hughes and adjoining land
Other features: Small area of amenity grassland on the north-eastern side.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R3 BT Telephone Exchange and adjoining Wellstones
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R4 Church Street Car Park and land fronting Market Street/Market Place
Other features: area of amenity grassland and scattered trees on the southern side.
Protected species: Unknown - no records.
Opportunities: Limited as predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R5 Charter Place centre and adjoining land onto the High Street
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
CF1 Community Facility Tolpits Lane.
Other features: Site appears to be rough grassland with scattered scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to enhance the habitats on site. The northern boundary is a wooded bank bordering the railway line. Maintain / enhance green corridor along railway.
Ecological sensitivity: Low - medium as semi-natural habitats on site.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H1 Land at Pinner Road
Other features: There are small areas of rough (possibly amenity) grassland with scrub and scattered trees.
Protected species: Unknown - no records.
Opportunities: Limited as a predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H2 Skatepark, Lower Derby Road
Other features: There is an area of grassland with trees in the north-west corner.
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a predominantly a previously developed site. Potential to maintain / enhance the semi-natural habitats on site for green corridor links to nearby habitats, river corridor and wooded railway banks.
Ecological sensitivity:
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H3 Vicarage Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H4 Telephone Exchange - First Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H5 Builder's Yard, Queens Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H6 Bill Everett Community Centre
Recognised sites adjacent / close to Site: adjacent to Long Spring and Harebreaks Wood (Watford) Local Wildlife Site and Local Nature Reserve.
Other features: some areas of grassland (probably amenity?) and occasional scattered trees.
Protected species: Bat roost in building nearby.
Opportunities: Potential to link woodland to the south to area to the north - depending on what the latter is like, as it appears to be bare ground on our aerial photographs.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H7 Rickmansworth Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H8 Garages- The Gossamers
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H9 Watford Station, Cassiobury Park Avenue
Recognised nature sites within Site: Cassiobury Park Avenue allotments ecosite.
Recognised sites adjacent / close to Site: close to "Gade Avenue" Local Wildlife Site.
Other features: Includes an area of allotment gardens and mature trees.
Protected species: Unknown - no records. Potential for bats and reptiles.
Opportunities: Maintain and enhance the green corridor link along the railway line.
Ecological sensitivity: Low - medium?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H10 Croxley View
Other features: Area of semi-natural grassland with scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to manage the existing habitats to maintain / improve biodiversity. Maintain as a green infrastructure link from open grasslands to the south towards the River Gade corridor and semi-natural habitats to the north
Ecological sensitivity: Low.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H11 Garages, Bowmans Green
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
GT1 Lands at Tolpits Lane
Other features: Area of rough grassland with bordering trees.
Protected species: Unknown - no records.
Opportunities: Limited, but part of semi-natural grassland complex in the area so potential for linking hedgerows. Any loss of grassland could be compensated for by enhancement elsewhere and landscaping may provide additional buffering habitats locally if this site were to be developed as such.
Ecological sensitivity: Low?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
E1 Watford Business
Recognised sites adjacent / close to Site: adjacent to Croxley Common Moor Site of Special Scientific Interest (SSSI and Local Nature Reserve (LNR) and Commonland; adjacent to Ascot Road Car Park and Waste ecosite, adjacent to Ascot Road ecosite; close to Ascot Road Scrub Local Wildlife Site.
Other features: Some areas with trees.
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
Part of the edge of this currently provides a valuable buffer and boundary edge to Croxley Common Moor SSSI and LNR. We would object to any development which further degraded this boundary habitat, although much of the former area has already been lost to hard surfacing.
E2 Imperial Way / Colonial
Protected species: Limited as a previously developed site.
Opportunities: Low.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E3 Fishers
Recognised nature sites within Site: Cardiff Road Embankment ecosite.
Recognised sites adjacent / close to Site: adjacent to Croxley Green Junction Sidings Local Wildlife Site.
Other features: Disused railway line to the west is bordered by woody vegetation.
Protected species: Unknown - no records.
Opportunities: Potential green corridors east / west across the site and along the western boundary. Maintain a buffer against LWS to the south.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
E4 Greycaine Road / Odhams / Sandown Road
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E5 Clarendon Road / Station Road / Bridle Path Office Area
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E6 Leavesden Studios - the Island site
Recognised nature sites within Site: part of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Recognised sites adjacent / close to Site: adjacent to the rest of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Other features: Semi-improved grassland habitat, part of a much larger complex.
Protected species: Badger setts on site and nearby.
Opportunities: Linking habitats to similar adjacent grasslands.
Ecological sensitivity: Low - medium.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species, with particular attention to badgers

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 858

Received: 03/10/2016

Respondent: Hertfordshire County Council SLU

Representation Summary:

The Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order to considered in the Watford Growth and Transport Plan.

Full text:

Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
With regard to Policy SPMX1: Special Policy Areas, the council is pleased to see the insertion of reference to the county council's documents. The text should however refer to the' Waste Local Plan' which includes both the Waste Core Strategy and Development Management Policies document and the Waste Site Allocations document.
With regard to Special Policy Area 2: Watford Junction, the council is pleased to see that there is reference to the need to safeguard the rail aggregates depot at Orphanage Road.
Further information on SPA2 is contained in Appendix I: Site Schedules of the Local Plan Part 2. The council is pleased that the rail aggregates depot is included as a
Spatial Planning and the Economy
Environment Department
Hertfordshire County Council
County Hall
Hertford
Hertfordshire
SG13 8DN
paul.donovan@hertfordshire.gov.uk
01992 556289
Planning Policy Team,
Room 65,
Watford Borough Council,
Town Hall,
Watford,
Herts,
WD17 3EX.
development consideration where it states 'This will need to be retained, or a new comparable facility provided within the local area'. However it should be noted that the text should refer to the 'rail aggregates depot' as opposed to the 'waste aggregates depot'.
However, in practice, taken together with the masterplan and accompanying viability report, there appears to be a strong likelihood that the rail aggregates depot is not to be retained on site and the collective impact of the Local Plan is not to safeguard the rail aggregates depot. Given this, the Inspector may well wish to see what evidence exists with regard to securing a replacement facility and currently no such evidence accompanies the Local Plan. As a consequence, there is considerable uncertainty in relation to whether the Local Plan satisfies potentially all soundness tests.
With regard to SPA6 Western Gateway, this includes ELAS221 and it is also worth pointing out that the areas designated as PS2 and PS3 potential in the Croxley View/Ascot Road Masterplanning Study are also located in ELAS221.
It is agreed that it is useful to insert text in relation to the circular economy as part of the waste section under paragraph 3.30, supporting text to Policy SD10: Waste. The second bullet point should state 'drive greater resource productivity.'
The relevant policy basis has been applied in the waste section and the Watford Local Plan with regard to responsibility for waste management. Whilst there appears to no longer be specific reference to Waste Policy 12, there is text to cover the use of this policy along with others within the Waste Core Strategy and Development Management Polices document. One comment to make is that in the wider context of the Watford Local Plan with there also being reference to ELAS221, the text in paragraph 3.30 should refer to the Waste Local Plan, which covers policies within the Waste Core Strategy and Development Management Policies document, adopted November 2012 and the Waste Site Allocations document, adopted July 2014.
Watford Junction Development Brief
As previously stated, most recently in respect of the Infrastructure Delivery Plan, the key matter of concern to the Minerals and Waste Planning Authority is the impact that any proposed development may have upon the safeguarded rail aggregate depot located at Orphanage Road, Watford which is a current operational facility.
The planning policy status, as detailed within the introduction of the brief, refers to consideration being had to national planning policy and the Watford Borough Council Local Plan. To ensure that the Development Plan has been considered as a whole the brief needs to also refer to the Minerals Local Plan and the Waste Local Plan. In terms of national policy, there is the need to ensure that the NPPF is considered in respect of para 143 which states that Mineral Planning Authorities should safeguard existing, planned and potential rail heads, so as to prevent their redevelopment for other uses and loss of the mineral infrastructure. This safeguarding is also applicable to storage, handling and processing facilities associated with them.
It is considered that due to the location of the rail aggregate depot within the development brief area that the county council's Minerals Local Plan 2002-2016, adopted March 2007 is also considered with specific regard to minerals policy 10: Railheads and Wharves. The Minerals Local Plan is being reviewed at present. It is envisaged, due to the requirement of the NPPF, that there will be a policy on Rail heads and Wharves in the Draft Minerals Local Plan.
The siting of the rail aggregate depot is shown within the county council's Mineral Consultation Area Supplementary Planning Document, adopted November 2007. The consultation area covers the majority of the Special Policy Area 2 Watford Junction. In accordance with the NPPF and Minerals Local Plan, in respect of minerals policy 10 the county council seeks to safeguard the rail aggregate depot which continues to serve as a sustainable mode of transporting minerals over long distances and the concrete batching facility which this site also supports. Given that the site is viable for use as a rail aggregate depot, its retention is expected unless the facility can be satisfactorily relocated within the development proposals in terms of operational requirements and environmental criteria or it has been or will be replaced in an alternative location.
The development brief identifies the rail aggregate depot as being a 'weakness' for the redevelopment of Watford junction in the SWOT analysis in paragraph 2.1. Minerals are important to the economy. Aggregate is needed to facilitate development and volumes of construction material being transported by rail in increasing. In light of this it could be considered that a rail aggregate depot in close proximity to the construction project could be considered to be a strength.
The issue of addressing such a 'weakness' is not however further expanded upon. It is clear from the illustrative masterplan that the retention of the rail aggregate depot is not part of the scheme. Whilst it is intended to be flexible enough to accommodate alternative layouts so long as it achieves the guiding principles and core ambitions of the masterplan, there does not appear to be sufficient scope to accommodate the existing or a relocated rail aggregate depot within the redevelopment area. As such this leaves the only option of relocating the rail aggregate depot offsite at another location along the railway line.
There is the need to establish an alternative well positioned strategic location for the rail aggregate depot to ensure its continued operation for imports and exports of minerals and secondary and recycled aggregates. The SWOT analysis in the development brief states that there is a 'weakness' in terms of a lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling. The Borough Council is referred back to paragraph 143 of the NPPF, the adopted Minerals Local Plan and specifically minerals policy 10 and the adopted Minerals Consultation Area SPD as detailed above in terms of the clarity for the safeguarding of the rail aggregates depot at Orphanage Road.
The brief states under the land use and quantum section of Station Quarter East within paragraph 3.4 that the development will be required to relocate the Rail Aggregates Depot within the local area, in consultation with Hertfordshire County Council and the operator of the site. The County Council will continue to work with the Borough Council in respect of this matter. The land use and quantum section in
paragraph 3.4 should also refer to the need to work with Network Rail with regard to the relocation of the Rail Aggregates Depot. The County Council understands that Network Rail Freight Management has been consulted and will provide comments to this consultation. There is however no further detail with regard a precise location having been secured.
To this end the relocation of the rail aggregate depot is fundamental to the delivery of the masterplan. A statement should be made in the delivery section of the brief at paragraph 4.1 specifically in relation to the requirement to ensure that the relocation of the rail aggregates depot forms part of the Watford Junction Delivery Plan.
Croxley View/Ascot Road Masterplanning Study
The Croxley View/Ascot Road Masterplanning Study has been considered by the county council as Waste Planning Authority due to the proximity of redevelopment to the Employment Land Area of Search (ELAS) 221 Watford Business Park.
The masterplan aims to build on the policy foundations of the district Local Plan Core Strategy Policy SPA6 to facilitate redevelopment. The location of potential residential development is shown within the Masterplanning Study to be directly adjacent to ELAS221 as designated within the county council's Waste Site Allocations document 2011-2026, adopted July 2014.
It is considered that ELAS that are predominantly used for general industry (B2) and storage and distribution (B8) are compatible with waste management uses. ELAS221 contains B1 and B2 uses and as such is acceptable in principle for a range of potential waste uses listed in the general waste brief during the 15 year plan period 2011-2026. Further planning guidance into the suitability of waste related development on the identified ELAS is within the ELAS Supplementary Planning Document, adopted November 2015. For this area, the Supplementary Planning Document states 'only enclosed waste transfer stations and materials recovery facilities that handle dry recyclables would be acceptable, along with enclosed inert waste recycling facilities. No other potential uses that may generate a leachate or liquor, which poses a risk to groundwater resources would be appropriate'.
The council does not wish to see the loss of identified ELAS for non-waste uses in order to safeguard it for future potential waste uses that may be sited in this location. Whilst the residential development would not directly encroach onto the ELAS, the council is mindful that the residential development is identified along the eastern boundary of the designated site and as a result there could be the potential for indirect impact upon the siting of waste uses within the ELAS.
The Waste Local Plan does not rely on the need for all land within ELAS across the county for the delivery of waste uses. However the cumulative loss of ELAS to non-waste uses is monitored and the safeguarding of remaining ELAS land is important to ensure there is a sufficient amount of land that could come forward for waste management facilities in the future, particularly with additional growth resulting in an increase in waste produced which needs to be managed.
There are currently no extant planning permissions on land directly adjacent to the masterplanned residential development to be aware of. The nearest waste site is the Household Waste Recycling Centre at Caxton Way in ELAS221. There is sufficient land remaining in ELAS221 to be brought forward for waste management uses.
The County Council does not wish to object to the masterplanning for potential residential development at this stage but reserves its right to object to future planning applications adjacent to the ELAS should a waste site be development in advance of residential. The reason for this would be to safeguard any waste use(s) under waste policy 5: Safeguarding of Sites within the Waste Core Strategy and Development Management Policies document 2011-2026, adopted November 2012. Further discussions would need to take place in the event that negative effects are identified that would restrict the waste operation to continue. A buffer between two land uses or mitigation measures in some cases may be appropriate to allow opposing land uses to exist in harmony adjacent to each other.
The County Council's adopted Waste Core Strategy and Development Management Policies document, does not stipulate a distance whereby other development in close proximity to a safeguarded waste site should be discouraged, the 2004 ODPM document: Planning for Waste Management Facilities: A Research Study states that for waste transfer stations: "sites closer than 250m from residential, commercial or recreational areas should be avoided." This guidance was used in the production of the Waste Site Allocations document. Depending upon the location of any potential future waste management facility within the ELAS, there is the potential that facilities may well be sited closer than the suggested 250m to any future housing.
Transport
Overarching/ general comments
Watford and the surrounding transport network face growing challenges as a result of the desired housing and economic growth in the area and increasing demand for travel. The County Council is developing a countywide transport model that will help all local authorities in the county to plan positively for growth and infrastructure investment in a way that safeguards the health and wellbeing of our communities and the environment. Already the model has identified notably worsening congestion issues in the Watford area as a result of planned growth. The next outputs of the enhanced Watford area version of the model will be available by the end of October 2016. The existing model is already available to Watford Borough Council to test development scenarios and proposals from the Local Plan.
In parallel with this, the County Council is developing a Growth & Transport Plan for South West Hertfordshire, which includes Watford and the surrounding towns and transport networks that make up a coherent area of travel demand. The Growth & Transport Plan will put forward packages of transport interventions to respond to strategic transport challenges and objectives for the area, derived through robust evidence analysis and engagement with stakeholders. Watford Borough Council officers and members have been involved from the early stages in GTP workshops
at key stages. The GTP is about identifying needs, planning for and enabling investment and delivery of a transport network and public realm that will support a healthy economy, environment and communities.
As a result of the current ongoing work being incomplete, at this stage there is insufficient evidence available to assess the implications of Local Plan Part 2 on the transportation network. As a consequence, there is uncertainty in relation to the mitigations that will be required to support the proposals and we remain in doubt that it potentially satisfies all soundness tests.
Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
Contents
'Appendix I - Site Allocations' is referred to later as 'Site Schedule'
'Appendix L' and 'Appendix M' missing from content list
Policy SD10
Refuse collection vehicles must be able to stop within the 'maximum refuse carry distance' specified by the Local Planning Authority or within 25m of any bin storage area, whichever is the lesser distance. Residents should not have to carry their rubbish more than 30m to a storage point. (Sources BS5906:2005 and Schedule 1 Part H Building Regulations)
Policy TLC14
On-street parking continues to need to be managed to manage congestion and avoid hazards, particularly at junctions.
Policy HS7
The subjective "undue pressure" on on-street parking should not lead to increased congestion and / or hazards on the highway network, particularly at junctions.
The siting of bin stores should not adversely impact on the operation of the highway network.
Policy HS8
The Highway Authority recommends that consideration of deliveries is made explicit in this policy.
6.9 and Policy EMP5
The County Council supports urban realm enhancement of Clarendon Road to encourage walking and cycling and improve the key pedestrian route between the town centre and Watford Junction.
Consideration should be given to amending the policy wording to explicitly include an expectation for development along Clarendon Road to contribute towards urban realm enhancements directly through works delivered or through developer contributions to fund such works.
Policy T6
The County Council is supportive of the zonal approach to car parking guidance to encourage lower car ownership and usage in more accessible zones. The principle of 'Car Lite' development in the most accessible areas, within 5 or so minutes' walk of a major transport hub, is also supported as long as the needs of disabled drivers and visitors are considered.
Lower car parking provision must be accompanied by appropriate restrictions in surrounding residential streets and any public car parks to prevent spill-over parking. In order for this approach to lowering car usage to be successful, there needs to be parallel investment in infrastructure (eg significantly better cycle and bus routes) and urban realm improvements to support and actively encourage alternative modes of travel.
The County Council welcomes the requirements for car club spaces in the SPAs and where parking does not meet the guidance.
Policy T8 and Appendix H
The policy on cycle parking provision and the stipulations relating to quality contained in the policy is welcomed. Adequate cycle storage must also be provided for existing and high predicted future levels.
A small change is recommended to allow for cycle parking provision for dwelling houses to be in a private garage as well as within the private garden area - subject to the dimensions of the garage being adequate to accommodate cycles as well as any vehicle.
However, the policy only specifies one long-term space per unit (regardless of size or location) where there is no garage or shed. In some instances such as within SPA2 and SPA6 where housing will be in the form of apartments and where there will be reduced car parking, it may be necessary for additional capacity for cycle storage beyond one space per unit, especially for larger flats or any flats without car parking provided.
Policy UD3
Structures abutting and overhanging the public highway will need the approval of the Highway Authority (HCC) as will illumination visible from the highway.
Policy TB1
From a transport network and user perspective, locations near to major passenger transport hubs, offering good interchange between different services and modes, are the most appropriate for denser development (i.e. taller buildings). However, development proposals should all be subject to Core Strategy policies T2-T5 to ensure that their impacts are understood and mitigated.
In order for such development to be acceptable, there must be adequate and appropriate improvements to transport infrastructure and urban realm within the site and in the wider area, to ensure no significant adverse impact on the highway and passenger transport networks, as a direct, indirect or cumulative result of development at the site and in the Borough as a whole.
Policy TB2
Suggest change to text at 8. Transport, parking and infrastructure:
'The design should detail a transport strategy for the proposed development to include how cycle parking, car parking, cycle permeability and pedestrian permeability have been integrated into the overall design. This should be based on a Transport Assessment and should avoid negative impacts on the public realm. The scheme will also need to demonstrate that the required infrastructure and utility capacity has been fully appraised.'
Appendix G
Parking bay dimensions only seem to consider residential element, parking bay at 2.4 x 4.8m is fine for standard bay but dimensions of other bays should be provided e.g. parallel arrangement. The garage dimensions provided are 3m x 5.5m whereas the industry standards are 3m x 6m (MfS para 8.3.41). Should minimum circulatory space for car parks be covered here (i.e. 6m) or will it be covered elsewhere?
SPA1
The ring road constrains pedestrian and cycle accessibility to the heart of the town centre. nb includes EMP5, R1, R2, R3, R4, R5. See Highway Authority comments in regard to each of these.
SPA2
Any development within the Watford Junction SPA should ensure that connectivity for pedestrians and cyclists is improved across the site, between the site and the town centre and on other key routes to Watford Junction Station.
Development of the station building, forecourt and car parks must address current limitations including capacity, access and circulation issues, for pedestrians, cyclists, buses, bus users, taxis, as well as users of the car parks. Opportunities to make Watford Junction an attractive and functional transport interchange that can accommodate future growth should be maximised.
See Highway Authority comments on Draft Development Brief (below).
SPA3
Good quality cycle and pedestrian links through the site and between the site and surrounding area and key destinations (town centre, Vicarage Road MLX station, local schools etc.) must be provided, or contributions to support infrastructure improvements in the wider area made through developer contributions.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
SPA4
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
Support improvements to green infrastructure and public realm as a complement to improvements to pedestrian and cycle links.
Flooding is a known issue affecting this area. Any development in this area should be designed to avoid and mitigate flood risk. Sustainable drainage approaches and green infrastructure should be used where appropriate to reduce and manage flood risk.
SPA5
Development at this location will need to consider transport impacts on the highway network, including operation of the Dome roundabout and St Albans Road notably at peak times. Also junctions including M25/A405/M1, and M1/A41.
There is a need to improve cycle, pedestrian and passenger transport connectivity to the site, and between the site and the town centre and Watford Junction.
It is recognised that the Abbey Line (North Watford) station is closer to the site, but there are limitations to this service at present which will reduce its attractiveness as an alternative to the car for journeys to Watford Junction or St Albans Abbey stations.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
There is a typo on second bullet point - should read 'improve air quality'.
SPA6
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Cycle improvements on Rickmansworth Road may be required as this is a key corridor between Rickmansworth and Watford.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
Secure, high quality cycle parking is needed at the proposed Cassiobridge station, as well as within the employment premises.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
See Highway Authority comments on Masterplanning Study (below)
MXD3
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
R1
It is agreed that robust pedestrian links with the town centre should form part of the new development at this location.
Good cycle access and high quality cycle parking also needs to be provided, for customers as well as employees.
R2
Agree that clear pedestrian connections between the site and the High Street are needed.
Good cycle access and cycle parking must also be provided.
There is a need to consider access needs to the site by different modes. A planned highway improvement scheme will make Clarendon Road one-way (NE-SW only) from Beechen Grove to High Street, with a contraflow cycle lane. Access to the street will be restricted by a Traffic Regulation Order to buses, taxis, cycles, 'blue badge' vehicles, and other vehicles 'for access only' to premises. All accessing vehicles will need to leave either via High Street or Watford House Lane (private road) for those accessing that area.
Development of this site should complement public realm enhancements proposed or already delivered on Clarendon Road and the High Street.
R3
Good cycle access and storage facilities must be provided, as well as good pedestrian links.
Developments at this location must take into account severance issues caused by the ring road for pedestrians and cyclists. Improvements required such as crossing improvements, new accesses into/through the site, should be delivered as part of the development or through developer contributions.
R4
Strong pedestrian and cycle links between this site and the town centre must be provided.
The quality of cycle routes and access to/from the west needs to be improved - eg. Market Street west of ring road and the Hornets Gyratory.
H1
This site is in close proximity to Bushey Station and includes its car park.
Opportunities to upgrade access to the station by non-car modes should be pursued.
Need to consider quantity and quality of cycle parking and cycle access to station from surrounding area.
Cycle access and cycle parking provision at Bushey station should be improved as part of any car parking replacement/improvement scheme.
Bushey Arches is a known congestion hotspot. Impacts of development on Bushey Arches must be considered and mitigation provided. This should include contributions to needed improvements to key walking and cycling routes and passenger transport infrastructure in the area.
H2
The ring road causes significant severance to people travelling by foot and cycle. Particular issues have been reported for people with visual impairments.
Improved cycle and pedestrian links to town centre and to Watford High Street and Watford Junction stations are needed from the site.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
H3
This site is about half mile from both the proposed Vicarage Road Met Line station and Watford High Street station, which is 10 to 12 minutes walking time.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
Vicarage Road is a busy road without dedicated cycle facilities. As such improvements to this route for cyclists should be considered. Developer contributions to improving cycle routes may be appropriate.
H5
The traffic impact on west Watford's road network needs to be considered and mitigated.
Cycle and pedestrian links into the site from different directions are required.
Adequate cycle storage must also be provided for existing and high predicted future levels.
Cycle infrastructure and the pedestrian environment of the surrounding area needs consideration.
H9
The impact of development at this site on the road network must be considered and mitigated if needed, including Rickmansworth Road and West Watford.
Good cycle links are needed including between the site, the town centre, and Ascot Road.
Bus services and infrastructure, including linking to new Cassiobridge Met Line station.
Bus services in this area may well be subject to change following the loss of the underground station. Development of this site and any forthcoming S106 contributions would provide the opportunity for an assessment to be made of potential improvements to bus services so this site remains connected to key destinations.
E1
High quality, secure cycle provision is needed at business premises.
Although the Ebury Way provides a good cycle route to the site, this will not be suitable for use all year round, at any time of day. As such improvements to the A412 corridor cycle infrastructure should be explored and provided. Developer contributions may be appropriate.
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
E2
Cycle and pedestrian routes through the site need improvement;
Via Watford Junction SPA site, there is a need to reduce severance and improve pedestrian and cycle connectivity to Watford Junction station and Clarendon Road.
WBC also needs to consider the implications of the Colonial Way Link road on development at site E2.
There is a need to consider potential transport implications of this site and the Watford Junction masterplan as a whole, including traffic accessing any new station multi-storey car parks, and the impact on the road network (eg. Colonial Way, Stephenson's Way, Radlett Road, Link Road, A41/M1 junction...).
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions.
E4
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions and on footways.
E5
Needs to link with SPA2 Watford Junction.
Development will need to assess impacts on road network and car parking demand in surrounding area.
Quality of pedestrian and cycle environment and urban realm on Clarendon Road should be considered and opportunities to enhance in consistent, coherent way should be explored to promote sustainable travel and improve route between town and Watford Junction.
Buildings will need to provide adequate, high quality secure cycle parking. If low car parking, may need to increase requirements or leave space to expand provision as required.
G6
Any change in land use/ status/ access provision to the south of Caxton Way and the south and east of Greenhill Crescent should not be permitted until its ability to provide the link for sustainable modes between Tolpits Lane and Caxton Way required by paragraph 10.6.9 of the WBC Core Strategy has been fully explored and ruled out.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF
1.1
The traffic and transport impacts of the masterplan scheme have not been modelled and thereby understood. The Highway Authority is, therefore, unable to fully support the plan until those impacts are assessed and deliverable mitigation measures agreed. HCC is developing traffic and transport models of Watford as part of its work to create a Growth & Transport Plan for the area. These will be used to test the impacts of the Watford Junction and other development proposals on transport infrastructure and services individually and cumulatively.
As part of earlier work on this site the County Council had required the construction of a road and bridge linking Colonial Way and St Albans Road via Penn Road. The scheme to build it received outline DfT funding and included a passenger transport (coach) interchange on the northeast side of the station. If the link road and bridge are no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
1.2
Correct reference to 'Abbey Link' in map to 'Abbey Line'.
2.1
The Barriers plan acknowledges the severance created by the presence of the Abbey Line. As part of earlier work on this site the County Council had required the construction of a road over the Abbey Line linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.2
Policy T1 in the borough council's Core Strategy supports conversion of the Abbey Line from heavy to light rail operation.
Correct reference to 'Abbey Flyover' in Objectives to 'Abbey Line'.
2.3
Correct reference to 'Abbey train line' under Transport and Parking to 'Abbey Line'.
As part of earlier work on this site the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.4
Gross External Areas values are different to those in 5.1 Area Schedules.
3D views might benefit from road names for orientation.
2.7
As part of earlier work on this site, the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
It is recommended that all roads are usable by cycles to aid permeability.
The road hierarchy titles have different meanings in the Highway Authority's own existing hierarchy. As the design is refined it is recommended that confusion is avoided by using different names.
2.8
The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.
3.3
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
3.4
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
4.1
The County Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order that they can be considered in the emerging Watford Growth & Transport Plan. Joint working with the County Council will remain key in order to maximise access to appropriate funding streams and delivery programmes.
Special Policy Area 2 is zero-CIL-rated so that all planning obligations will be derived via Section 106 agreements with service providers.
4.2
An overall Travel Plan for the site will be required and one for each subsequent development area should be provided and agreed.
5.1
Total car parking number differs from that given in 2.4 and Station Quarter East breakdown (p 46).
Gross External Areas values are different to those in 2.4.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF VIABILITY APPRAISAL
4.2
The County Council is concerned about the unrealistically low estimates given in figure 4.1 for the costings of infrastructure required to mitigate the impact of the masterplan.
CROXLEY VIEW/ ASCOT ROAD STUDY
Introduction
Mention must be made of the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The need for a link both for Watford and Three Rivers grows as pressure to develop either side of the Ebury Way increases and its delivery should be seen as key to both authorities' Duty to Cooperate.
Plans
All plans refer to Watford County Council.
All plans show Croxley Green Business Park to the southwest of the masterplan area. This is correctly the Wolsey Business Park.
Most plans show the Grand Union Canal badged as the River Gade which runs to the south and east of it.
Some plans do not show the correct alignment of the Watford/ Three Rivers boundary.
Some plans erroneously label the NE corner of Croxley Common as Cassiobury Park Nature Reserve.
Masterplanning Strategy plan - asterisks and other labelling are not described and inconsistently applied.
Potential Development Sites plan
This omits to include the Tech Site (around Woodshots Meadow). This is subject to preapplication discussions now and should be considered with the adjacent sites as it is in Employment Policy Area E1 (Local Plan Part 2 appendix 1).
Proposed Vehicle and Pedestrian Movement plan
This omits the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The route currently being explored follows the cycle track between the Watford Enterprise Centre and number 27 Greenhill Crescent.
Historic environment, landscape and ecology
The County Council supports the overall policy intentions of the Local Plan covering landscape, ecology and the historic and built environment and provides the following comments to help strengthen these policies and their supplementary text.
Historic Environment
Development Management Policies
The County Council welcomes the Borough's consideration of the Historic Environment in Part 9 Urban Design and the Historic Environment. However, the historic environment should be referenced in line with the NPPF definition of heritage assets. In addition to historic buildings (both designated and undesignated), the historic environment of Watford includes archaeological remains, historic landscapes and historic parks. Therefore policies are needed to conserve the historic environment as whole, not just designated buildings, registered gardens and conservation areas as is currently stated.
Under Policy UD4, Archaeology, there appears to be repetition of the NPPF, the policy is unclear and should be re-written.
There is also reference to the conservation of heritage assets being secured by an archaeological Written Scheme of Investigation (WSI). Whilst the County Council welcomes the requirement for these documents and for them to include provision for publication and public dissemination of results where appropriate (NPPF 141), it is not clear if the WSI on its own is considered to be robust enough to secure appropriate conservation of the historic environment. Therefore it is unclear if this part too, is effective.
Watford Junction Draft Development Brief 2016
Paragraph 4.2 notes that a Heritage Statement and Desktop Archaeological Study may need to be submitted with any planning applications. However, it is unclear what is meant by a Heritage Statement. Also archaeological assessment may not be limited to a desktop study.
Site Allocations
An appraisal of the archaeological implications of development for the new areas identified in the Second Consultation document (2016) is summarised below.
1. Archaeology as a Development Constraint
N/A
2. Requirement for Pre-allocation Archaeological Assessment
The sites below have known archaeological remains within them or have significant archaeological potential by reason of their size and situation, such that there is a risk that archaeology could be a constraint on any development. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that archaeological assessments should be included within all development briefs and other proposals for the sites, before they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the sites, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent of archaeological remains that might be a constraint upon the principle of development of these sites.
Allocation numbers: SPA1, SPA4 and H9.
3. Requirement for Pre-application or Pre-determination Archaeological Assessment
The sites below have known archaeological remains within them or have archaeological potential. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that that pre-application or pre-determination archaeological assessments should be included within all development briefs and other proposals for the sites, if they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the proposals, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent
of archaeological remains worthy of preservation in situ, to enable the LPA to determine any specific application for development.
Allocation numbers: SPA 2, SPA3, SPA5, SPA6, MXD1, MXD3, R1, R2, R3, R4, H2, H3, H4, H 10, E1, E2, E3, E4, E5, E6.
4. Mitigation of archaeological impact by condition
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, any archaeological issues can probably be dealt with by condition, should planning permission be granted.
Allocation numbers: R5, CF1, H1, H5, H6, GT1.
5. No archaeological requirements
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, there are unlikely to be any archaeological implications. However this will depend on the details of any proposals and any new archaeological information.
Allocation numbers: MXD2, MXD4, H7, H8, H11.
Ecology
Development Management Policies
Policy SD15, External lighting, the County Council support the provisions set out in this policy and advise that there should be reference to the guidance provided by the Institute of Lighting Engineers which has been instrumental in seeking to reduce the impacts of artificial lighting within the environment.
Green Infrastructure, Biodiversity and Recreation, the County Council supports the reference to Green Infrastructure (GI).In defining GI there should also be reference to the provision of local food production as a key ecosystem service.
Policy G15, Trees, Woodlands and Hedgerows, this policy is supported in respect of highlighting ecological and cultural value of trees, woodlands and hedgerows. However, under paragraph 10.3, the reference to valuable habitats should be extended to include reference to ecological networks and corridors. Under paragraph 10.6 it should be clarified that replacing trees lost to development cannot compensate for the loss of biodiversity or amenity value in the short term.
Policy GI6, Protecting and Enhancing the Grand Union Canal, this policy is supported including the reference to enhancing biodiversity under paragraph 10.11. It is advised that the policy is extended to include a clause that seeks to improve the biodiversity of the canal corridor where possible. Development that would have an
adverse impact on the biodiversity of the canal would not be supported unless it can demonstrate provision of suitable mitigation or compensation.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, this policy is supported however recommend the following clarifications and amendments.
It is advised to make reference to the 'amenity value' of the river, specifically encouraging 'recreation' may increase disturbance to sensitive wildlife within river corridors. The term 'amenity' embraces visual and recreational importance without being too prescriptive or disruptive if more sensitive habitats or locations are affected an important consideration within this largely urban area.
With regards the provision of 'a corridor for wildlife and biodiversity,' the reference to biodiversity should be deleted as wildlife is biodiversity. With regards replacement structures and fish passage, liaison with the Environment Agency is essential if any such works are proposed. With regards access it should be designed in a way that also enables some undisturbed areas to be retained.
Policy GI9, Provision of Open Space and Play Space in Residential Development, aspects of this policy relevant to biodiversity are supported. The reference to green space typologies should be expanded to include allotments and community orchards, in order to reflect the types of functional sites which support both community and biodiversity benefits.
Biodiversity, it is not clear why this section is formatted differently to the preceding and subsequent sections. In particular it does not describe 'Why is this policy needed?' and 'what is it intended to do?' In setting out the need for the policy, it should reference the legislative requirements of statutorily protected sites and species which are a material consideration in planning, as well as the Duty placed on Local Authorities to have regard to conserving biodiversity in all of their functions as set out in the Natural Environment and rural Communities Act 2006. In setting out the intention of the policy there should also be reference to seeking to deliver the aims of the Local Nature Partnership - for which securing ecological resources, functions and services are a consideration when determining planning applications.
Under paragraph 10.37 the reference to the 'Biodiversity Plan' should be amended to reference to the 'Biodiversity Action Plan principles' (BAP). The BAP, nationally and locally, has ceased to be actively supported by National and Local Government, and has essentially been replaced by the Local Nature Partnership. However the principles underpinning it remain valid as statements and the intentions of the various habitat and species action plans are sound in themselves and could be followed if resources or interest permitted.
It is suggested that the statement under paragraph 10.39 should be amended as follows:
'This policy expects that where appropriate, development proposals will demonstrate the relative ecological value of a site before and after development. Proposals should follow the mitigation hierarchy and provide clear evidence of impacts and enhancements where appropriate, consistent with the aims of NPPF, BS42020
"Biodiversity - Code of Practice for Planning and Development'' and guidance provided by CIEEM. This will require sufficient detail and clarity to enable net losses and gains to be identified and monitored, consistent with the Code. Where unavoidable, Biodiversity Offsetting should be considered as a means to ensure there is no net loss of biodiversity resulting from development'.
Highlighting the specific use of Biodiversity Calculators such as the one mentioned in paragraph 10.39 can be a little misleading. BS42020 does not mention the use of biodiversity calculators, and taken out of context the results of such calculations can sometimes show net gains where there should be none (removal of ancient woodland for example cannot reasonably be compensated in the real world). Other wider landscape issues are also not always considered by these calculators; if the land is part of a wider corridor, or a biodiversity network for example. It has taken several years for Warwickshire County Council to incorporate their use in to the planning system and there is still not universal agreement on them.
The County Council would therefore advise caution on their avocation, but rather emphasise the need to prove that biodiversity has not been lost and in the most part enhanced through "appropriate methods in-line with BS42020".
Policy GI10 Managing Biodiversity in new Developments. The County Council supports Watford Borough Council's commitment to increasing biodiversity within the district. The Policy is consistent with other Hertfordshire Local Authorities, and in-line with the National Planning Policy Framework.
The following amendments are advised. There should be reference to avoiding negative impacts upon ' local ecological networks...,'as each site sits within a local environmental and should retain or enhance any existing ecological resources or corridors to and from adjacent sites.
'Compensation will only be considered as a last resort. Development proposals will be expected to evaluate the impact on local biodiversity where appropriate and propose measures to maintain and enhance biodiversity. This approach should follow the principles outlined within BS42020 "Biodiversity - Code of Practice for Planning and Development" or other measures of best practice, including Biodiversity Offsetting where necessary'.
The above wording embraces the mitigation hierarchy as well as defining means to achieve no net loss as sought by NPPF, without being too prescriptive.
It is considered that paragraph 10.40 regarding the biodiversity calculator is not needed if references requiring its specific use are otherwise removed. The County Council remain concerned that some caution needs to be taken regarding the generation of positive scores which indicate a net gain despite losses that may otherwise be considered unacceptable.
Site Allocations
Please refer to Appendix 1.
Landscape
Green Infrastructure, Biodiversity and Recreation, the policy framework for green infrastructure (GI) was significantly strengthened in Feb 2016 with the introduction of detailed Planning Policy Guidance. The guidance states that GI is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water and should be a key consideration in both local plans and planning decisions.
The Herts Landscape and Green Infrastructure Group is currently looking at GI delivery and practice across Hertfordshire with a view to presenting a project proposal to Herts Infrastructure Planning Partnership (HIPP) in November. The key aim of the project is to mainstream the delivery of GI through the local plan and development management processes. The outputs and deliverables of the project are currently being shaped and should help provide local planning authorities with a good practice approach to GI delivery, supported by robust evidence and case studies.
The Landscape Institute Position Statement for Green Infrastructure provides a widely supported definition of GI (assets and functions) and a comprehensive overview of the key benefits it can deliver, supported by case studies http://www.landscapeinstitute.org/policy/GreenInfrastructure.php
There is no reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans. (The strategies provide an opportunity to address cross boundary issues and meet the Duty to Cooperate. (Hertfordshire and GreenArc Area Strategic Highlights Plan (SHiP) and the All London Green Grid.)
There should be greater emphasis on GI in place-making and conserving and enhancing local distinctiveness. There should be reference to any local character assessments and the guidelines for managing change that should help shape proposals, and conserve and enhance local character.
At a national level there is also the National Character Areas produced by Natural England https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making, and at a regional level there is the East of England Landscape Framework http://landscape-east.org.uk/.
Where proposals are likely to result in landscape and visual effects a landscape and visual impact assessment, in line with industry good practice guidance (Landscape and Visual Impact Assessment third edition Landscape Institute and Institute for Environmental Management and Assessment) may be required as part of an application. The mitigation hierarchy should be referenced to ensure that proposals seek to avoid and minimise any negative effects.
The reference to Green Infrastructure under paragraph 10.1, is fully supported, however it is suggested to expand the definition to include reference to blue assets
such as the Grand Union Canal. Also suggest amend reference to 'mitigating climate change' to 'mitigating the effects of climate change.'
Under paragraph 10.3, it should be clear that biodiversity is not the only driver for Green Infrastructure; other key drivers include a single or multiple land-use functions and include waste/water management, recreation, food production, local distinctiveness etc.
Policy GI5, Trees, Woodlands and Hedgerows, the reference to the protection of trees in line with current British Standard Institute code of practice is fully supported, however the full title of the standard does not appear to be referenced and should be 'Trees in relation to design, demolition and construction' (BS5837:2012). In addition it is advised that where required by the planning authority, tree surveys, arboricultural impact assessments and method statements should all be carried out in compliance with this standard.
The policy should be expanded to include reference to the current hedgerow regulations, the provision of a landscape strategy, planting plans and specifications, and the provision of aftercare (long term management plans) and replacement of failures.
Policy GI6, Protecting and Enhancing the Grand Union Canal, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Yours sincerely,
Paul Donovan
Environment Department
Hertfordshire County Council
APPENDIX 1
Please find below a brief ecological assessment of the site allocations. A 'standard' template for each Site has been provided.
Ecosites do not have any form of status of importance, but are merely sites that we have some ecological information on - thus they do support some wildlife interest, at least at a local level. Whilst these sites are often a valuable starting point in identifying the county's wildlife resource, they do not meet the rigorous and quantifiable assessment criteria needed to identify them as non-statutory Local (County) Wildlife Sites.
SPA1 Town Centre
Recognised sites adjacent / close to Site: close to eastern end of Cassiobury Park Local Wildlife Site.
Other features: Little semi natural habitat present, possibly some mature trees.
Protected species: Probably bats, badger records to the west.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road)
Protected species: Unknown - no records
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA3 Health Campus (includes a Borough Council Depot and Waste Transfer Station at Wiggenhall Road)
Recognised nature sites within Site: The Lairage Land Local Wildlife Site (LWS) and Local Nature Reserve (LNR), Croxley Green Junction Sidings LWS, Oxhey Park River & Margins LWS; Riverside Road Waste Ground ecosite (local database site), The Island, off Cardiff Road ecosite, Oxhey Park ecosite
Recognised sites adjacent / close to Site: Horwoods Avenue Playground ecosite, Moor View ecosite, Cardiff Road Embankment ecosite.
Other features: includes village green - "Green situated between Riverside Road & the River Colne"
Protected species: Birds and Water voles.
Opportunities: High. Habitat management to maintain and enhance biodiversity interest, green infrastructure / corridors.
Ecological sensitivity: Medium to high depending on location.
Fundamental ecological constraint: Presumption to avoid development on Local Wildlife Sites, fragmentation of green corridor,
Loss of Farm Terrace allotment site - should be offset elsewhere as open space / community food growing / ecological resource.
SPA4 Lower High Street
Recognised sites adjacent / close to Site: Bushey Hall Farm ecosite, Oxhey Park ecosite.
Other features: "Recreation Allotments" village green.
Protected species: Unknown - no records. Birds in trees.
Opportunities: Limited as previously developed site. Potential green corridors along railways lines.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA5 Dome Roundabout (includes a Waste Transfer Station at Colne Way)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA6 Western Gateway (includes area of search ELAS221 in the Hertfordshire Waste Site Allocations Document)
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite, Ascot Road ecosite.
Recognised sites adjacent / close to Site: close to eastern end of Croxley Common Moor Site of Specific Scienttific Interest (SSSI) and LNR.
Other features: Grassland strip along eastern boundary with bordering trees.
Protected species: Unknown - no records.
Opportunities: Enhance green infrastructure corridor along eastern boundary.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds in trees.
The ecosites have largely been destroyed by development.
MXD1 North Watford library, Lemarie Centre for Charities, and health facilities (within SPA5)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
MXD2 The Brow
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
MXD3 Gas holder site (within SPA4)
Other features: River Colne borders the eastern boundary.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site. Potential to enhance the river margins as a green corridor.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in the trees.
Largely developed but riverside trees most important and scrub on site.
MXD4 Ascot Road
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite.
Other features: As well as the rough ground and bordering trees of the area to the west, the Site includes part of the school playing fields to the east, which is short mown amenity grassland. There are also some mature trees.
Protected species: Unknown - no records.
Opportunities: Potential enhancement of the areas of semi-natural habitat to improve green corridor connectivity.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds. Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R1 Sainsbury's and adjoining land
Other features: The north-eastern part of the Site includes an area of grassland and mature trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R2 Former TJ Hughes and adjoining land
Other features: Small area of amenity grassland on the north-eastern side.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R3 BT Telephone Exchange and adjoining Wellstones
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R4 Church Street Car Park and land fronting Market Street/Market Place
Other features: area of amenity grassland and scattered trees on the southern side.
Protected species: Unknown - no records.
Opportunities: Limited as predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R5 Charter Place centre and adjoining land onto the High Street
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
CF1 Community Facility Tolpits Lane.
Other features: Site appears to be rough grassland with scattered scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to enhance the habitats on site. The northern boundary is a wooded bank bordering the railway line. Maintain / enhance green corridor along railway.
Ecological sensitivity: Low - medium as semi-natural habitats on site.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H1 Land at Pinner Road
Other features: There are small areas of rough (possibly amenity) grassland with scrub and scattered trees.
Protected species: Unknown - no records.
Opportunities: Limited as a predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H2 Skatepark, Lower Derby Road
Other features: There is an area of grassland with trees in the north-west corner.
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a predominantly a previously developed site. Potential to maintain / enhance the semi-natural habitats on site for green corridor links to nearby habitats, river corridor and wooded railway banks.
Ecological sensitivity:
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H3 Vicarage Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H4 Telephone Exchange - First Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H5 Builder's Yard, Queens Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H6 Bill Everett Community Centre
Recognised sites adjacent / close to Site: adjacent to Long Spring and Harebreaks Wood (Watford) Local Wildlife Site and Local Nature Reserve.
Other features: some areas of grassland (probably amenity?) and occasional scattered trees.
Protected species: Bat roost in building nearby.
Opportunities: Potential to link woodland to the south to area to the north - depending on what the latter is like, as it appears to be bare ground on our aerial photographs.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H7 Rickmansworth Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H8 Garages- The Gossamers
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H9 Watford Station, Cassiobury Park Avenue
Recognised nature sites within Site: Cassiobury Park Avenue allotments ecosite.
Recognised sites adjacent / close to Site: close to "Gade Avenue" Local Wildlife Site.
Other features: Includes an area of allotment gardens and mature trees.
Protected species: Unknown - no records. Potential for bats and reptiles.
Opportunities: Maintain and enhance the green corridor link along the railway line.
Ecological sensitivity: Low - medium?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H10 Croxley View
Other features: Area of semi-natural grassland with scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to manage the existing habitats to maintain / improve biodiversity. Maintain as a green infrastructure link from open grasslands to the south towards the River Gade corridor and semi-natural habitats to the north
Ecological sensitivity: Low.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H11 Garages, Bowmans Green
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
GT1 Lands at Tolpits Lane
Other features: Area of rough grassland with bordering trees.
Protected species: Unknown - no records.
Opportunities: Limited, but part of semi-natural grassland complex in the area so potential for linking hedgerows. Any loss of grassland could be compensated for by enhancement elsewhere and landscaping may provide additional buffering habitats locally if this site were to be developed as such.
Ecological sensitivity: Low?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
E1 Watford Business
Recognised sites adjacent / close to Site: adjacent to Croxley Common Moor Site of Special Scientific Interest (SSSI and Local Nature Reserve (LNR) and Commonland; adjacent to Ascot Road Car Park and Waste ecosite, adjacent to Ascot Road ecosite; close to Ascot Road Scrub Local Wildlife Site.
Other features: Some areas with trees.
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
Part of the edge of this currently provides a valuable buffer and boundary edge to Croxley Common Moor SSSI and LNR. We would object to any development which further degraded this boundary habitat, although much of the former area has already been lost to hard surfacing.
E2 Imperial Way / Colonial
Protected species: Limited as a previously developed site.
Opportunities: Low.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E3 Fishers
Recognised nature sites within Site: Cardiff Road Embankment ecosite.
Recognised sites adjacent / close to Site: adjacent to Croxley Green Junction Sidings Local Wildlife Site.
Other features: Disused railway line to the west is bordered by woody vegetation.
Protected species: Unknown - no records.
Opportunities: Potential green corridors east / west across the site and along the western boundary. Maintain a buffer against LWS to the south.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
E4 Greycaine Road / Odhams / Sandown Road
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E5 Clarendon Road / Station Road / Bridle Path Office Area
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E6 Leavesden Studios - the Island site
Recognised nature sites within Site: part of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Recognised sites adjacent / close to Site: adjacent to the rest of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Other features: Semi-improved grassland habitat, part of a much larger complex.
Protected species: Badger setts on site and nearby.
Opportunities: Linking habitats to similar adjacent grasslands.
Ecological sensitivity: Low - medium.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species, with particular attention to badgers

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 859

Received: 03/10/2016

Respondent: Hertfordshire County Council SLU

Representation Summary:

An overall travel plan for the site will be required and one for each subsequent area to be aggreed.

Full text:

Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
With regard to Policy SPMX1: Special Policy Areas, the council is pleased to see the insertion of reference to the county council's documents. The text should however refer to the' Waste Local Plan' which includes both the Waste Core Strategy and Development Management Policies document and the Waste Site Allocations document.
With regard to Special Policy Area 2: Watford Junction, the council is pleased to see that there is reference to the need to safeguard the rail aggregates depot at Orphanage Road.
Further information on SPA2 is contained in Appendix I: Site Schedules of the Local Plan Part 2. The council is pleased that the rail aggregates depot is included as a
Spatial Planning and the Economy
Environment Department
Hertfordshire County Council
County Hall
Hertford
Hertfordshire
SG13 8DN
paul.donovan@hertfordshire.gov.uk
01992 556289
Planning Policy Team,
Room 65,
Watford Borough Council,
Town Hall,
Watford,
Herts,
WD17 3EX.
development consideration where it states 'This will need to be retained, or a new comparable facility provided within the local area'. However it should be noted that the text should refer to the 'rail aggregates depot' as opposed to the 'waste aggregates depot'.
However, in practice, taken together with the masterplan and accompanying viability report, there appears to be a strong likelihood that the rail aggregates depot is not to be retained on site and the collective impact of the Local Plan is not to safeguard the rail aggregates depot. Given this, the Inspector may well wish to see what evidence exists with regard to securing a replacement facility and currently no such evidence accompanies the Local Plan. As a consequence, there is considerable uncertainty in relation to whether the Local Plan satisfies potentially all soundness tests.
With regard to SPA6 Western Gateway, this includes ELAS221 and it is also worth pointing out that the areas designated as PS2 and PS3 potential in the Croxley View/Ascot Road Masterplanning Study are also located in ELAS221.
It is agreed that it is useful to insert text in relation to the circular economy as part of the waste section under paragraph 3.30, supporting text to Policy SD10: Waste. The second bullet point should state 'drive greater resource productivity.'
The relevant policy basis has been applied in the waste section and the Watford Local Plan with regard to responsibility for waste management. Whilst there appears to no longer be specific reference to Waste Policy 12, there is text to cover the use of this policy along with others within the Waste Core Strategy and Development Management Polices document. One comment to make is that in the wider context of the Watford Local Plan with there also being reference to ELAS221, the text in paragraph 3.30 should refer to the Waste Local Plan, which covers policies within the Waste Core Strategy and Development Management Policies document, adopted November 2012 and the Waste Site Allocations document, adopted July 2014.
Watford Junction Development Brief
As previously stated, most recently in respect of the Infrastructure Delivery Plan, the key matter of concern to the Minerals and Waste Planning Authority is the impact that any proposed development may have upon the safeguarded rail aggregate depot located at Orphanage Road, Watford which is a current operational facility.
The planning policy status, as detailed within the introduction of the brief, refers to consideration being had to national planning policy and the Watford Borough Council Local Plan. To ensure that the Development Plan has been considered as a whole the brief needs to also refer to the Minerals Local Plan and the Waste Local Plan. In terms of national policy, there is the need to ensure that the NPPF is considered in respect of para 143 which states that Mineral Planning Authorities should safeguard existing, planned and potential rail heads, so as to prevent their redevelopment for other uses and loss of the mineral infrastructure. This safeguarding is also applicable to storage, handling and processing facilities associated with them.
It is considered that due to the location of the rail aggregate depot within the development brief area that the county council's Minerals Local Plan 2002-2016, adopted March 2007 is also considered with specific regard to minerals policy 10: Railheads and Wharves. The Minerals Local Plan is being reviewed at present. It is envisaged, due to the requirement of the NPPF, that there will be a policy on Rail heads and Wharves in the Draft Minerals Local Plan.
The siting of the rail aggregate depot is shown within the county council's Mineral Consultation Area Supplementary Planning Document, adopted November 2007. The consultation area covers the majority of the Special Policy Area 2 Watford Junction. In accordance with the NPPF and Minerals Local Plan, in respect of minerals policy 10 the county council seeks to safeguard the rail aggregate depot which continues to serve as a sustainable mode of transporting minerals over long distances and the concrete batching facility which this site also supports. Given that the site is viable for use as a rail aggregate depot, its retention is expected unless the facility can be satisfactorily relocated within the development proposals in terms of operational requirements and environmental criteria or it has been or will be replaced in an alternative location.
The development brief identifies the rail aggregate depot as being a 'weakness' for the redevelopment of Watford junction in the SWOT analysis in paragraph 2.1. Minerals are important to the economy. Aggregate is needed to facilitate development and volumes of construction material being transported by rail in increasing. In light of this it could be considered that a rail aggregate depot in close proximity to the construction project could be considered to be a strength.
The issue of addressing such a 'weakness' is not however further expanded upon. It is clear from the illustrative masterplan that the retention of the rail aggregate depot is not part of the scheme. Whilst it is intended to be flexible enough to accommodate alternative layouts so long as it achieves the guiding principles and core ambitions of the masterplan, there does not appear to be sufficient scope to accommodate the existing or a relocated rail aggregate depot within the redevelopment area. As such this leaves the only option of relocating the rail aggregate depot offsite at another location along the railway line.
There is the need to establish an alternative well positioned strategic location for the rail aggregate depot to ensure its continued operation for imports and exports of minerals and secondary and recycled aggregates. The SWOT analysis in the development brief states that there is a 'weakness' in terms of a lack of clarity around the safeguarding of lands for future infrastructure requirements and aggregates handling. The Borough Council is referred back to paragraph 143 of the NPPF, the adopted Minerals Local Plan and specifically minerals policy 10 and the adopted Minerals Consultation Area SPD as detailed above in terms of the clarity for the safeguarding of the rail aggregates depot at Orphanage Road.
The brief states under the land use and quantum section of Station Quarter East within paragraph 3.4 that the development will be required to relocate the Rail Aggregates Depot within the local area, in consultation with Hertfordshire County Council and the operator of the site. The County Council will continue to work with the Borough Council in respect of this matter. The land use and quantum section in
paragraph 3.4 should also refer to the need to work with Network Rail with regard to the relocation of the Rail Aggregates Depot. The County Council understands that Network Rail Freight Management has been consulted and will provide comments to this consultation. There is however no further detail with regard a precise location having been secured.
To this end the relocation of the rail aggregate depot is fundamental to the delivery of the masterplan. A statement should be made in the delivery section of the brief at paragraph 4.1 specifically in relation to the requirement to ensure that the relocation of the rail aggregates depot forms part of the Watford Junction Delivery Plan.
Croxley View/Ascot Road Masterplanning Study
The Croxley View/Ascot Road Masterplanning Study has been considered by the county council as Waste Planning Authority due to the proximity of redevelopment to the Employment Land Area of Search (ELAS) 221 Watford Business Park.
The masterplan aims to build on the policy foundations of the district Local Plan Core Strategy Policy SPA6 to facilitate redevelopment. The location of potential residential development is shown within the Masterplanning Study to be directly adjacent to ELAS221 as designated within the county council's Waste Site Allocations document 2011-2026, adopted July 2014.
It is considered that ELAS that are predominantly used for general industry (B2) and storage and distribution (B8) are compatible with waste management uses. ELAS221 contains B1 and B2 uses and as such is acceptable in principle for a range of potential waste uses listed in the general waste brief during the 15 year plan period 2011-2026. Further planning guidance into the suitability of waste related development on the identified ELAS is within the ELAS Supplementary Planning Document, adopted November 2015. For this area, the Supplementary Planning Document states 'only enclosed waste transfer stations and materials recovery facilities that handle dry recyclables would be acceptable, along with enclosed inert waste recycling facilities. No other potential uses that may generate a leachate or liquor, which poses a risk to groundwater resources would be appropriate'.
The council does not wish to see the loss of identified ELAS for non-waste uses in order to safeguard it for future potential waste uses that may be sited in this location. Whilst the residential development would not directly encroach onto the ELAS, the council is mindful that the residential development is identified along the eastern boundary of the designated site and as a result there could be the potential for indirect impact upon the siting of waste uses within the ELAS.
The Waste Local Plan does not rely on the need for all land within ELAS across the county for the delivery of waste uses. However the cumulative loss of ELAS to non-waste uses is monitored and the safeguarding of remaining ELAS land is important to ensure there is a sufficient amount of land that could come forward for waste management facilities in the future, particularly with additional growth resulting in an increase in waste produced which needs to be managed.
There are currently no extant planning permissions on land directly adjacent to the masterplanned residential development to be aware of. The nearest waste site is the Household Waste Recycling Centre at Caxton Way in ELAS221. There is sufficient land remaining in ELAS221 to be brought forward for waste management uses.
The County Council does not wish to object to the masterplanning for potential residential development at this stage but reserves its right to object to future planning applications adjacent to the ELAS should a waste site be development in advance of residential. The reason for this would be to safeguard any waste use(s) under waste policy 5: Safeguarding of Sites within the Waste Core Strategy and Development Management Policies document 2011-2026, adopted November 2012. Further discussions would need to take place in the event that negative effects are identified that would restrict the waste operation to continue. A buffer between two land uses or mitigation measures in some cases may be appropriate to allow opposing land uses to exist in harmony adjacent to each other.
The County Council's adopted Waste Core Strategy and Development Management Policies document, does not stipulate a distance whereby other development in close proximity to a safeguarded waste site should be discouraged, the 2004 ODPM document: Planning for Waste Management Facilities: A Research Study states that for waste transfer stations: "sites closer than 250m from residential, commercial or recreational areas should be avoided." This guidance was used in the production of the Waste Site Allocations document. Depending upon the location of any potential future waste management facility within the ELAS, there is the potential that facilities may well be sited closer than the suggested 250m to any future housing.
Transport
Overarching/ general comments
Watford and the surrounding transport network face growing challenges as a result of the desired housing and economic growth in the area and increasing demand for travel. The County Council is developing a countywide transport model that will help all local authorities in the county to plan positively for growth and infrastructure investment in a way that safeguards the health and wellbeing of our communities and the environment. Already the model has identified notably worsening congestion issues in the Watford area as a result of planned growth. The next outputs of the enhanced Watford area version of the model will be available by the end of October 2016. The existing model is already available to Watford Borough Council to test development scenarios and proposals from the Local Plan.
In parallel with this, the County Council is developing a Growth & Transport Plan for South West Hertfordshire, which includes Watford and the surrounding towns and transport networks that make up a coherent area of travel demand. The Growth & Transport Plan will put forward packages of transport interventions to respond to strategic transport challenges and objectives for the area, derived through robust evidence analysis and engagement with stakeholders. Watford Borough Council officers and members have been involved from the early stages in GTP workshops
at key stages. The GTP is about identifying needs, planning for and enabling investment and delivery of a transport network and public realm that will support a healthy economy, environment and communities.
As a result of the current ongoing work being incomplete, at this stage there is insufficient evidence available to assess the implications of Local Plan Part 2 on the transportation network. As a consequence, there is uncertainty in relation to the mitigations that will be required to support the proposals and we remain in doubt that it potentially satisfies all soundness tests.
Local Plan Part 2 - Site Allocations and Development Management Policies Publication 2016
Contents
'Appendix I - Site Allocations' is referred to later as 'Site Schedule'
'Appendix L' and 'Appendix M' missing from content list
Policy SD10
Refuse collection vehicles must be able to stop within the 'maximum refuse carry distance' specified by the Local Planning Authority or within 25m of any bin storage area, whichever is the lesser distance. Residents should not have to carry their rubbish more than 30m to a storage point. (Sources BS5906:2005 and Schedule 1 Part H Building Regulations)
Policy TLC14
On-street parking continues to need to be managed to manage congestion and avoid hazards, particularly at junctions.
Policy HS7
The subjective "undue pressure" on on-street parking should not lead to increased congestion and / or hazards on the highway network, particularly at junctions.
The siting of bin stores should not adversely impact on the operation of the highway network.
Policy HS8
The Highway Authority recommends that consideration of deliveries is made explicit in this policy.
6.9 and Policy EMP5
The County Council supports urban realm enhancement of Clarendon Road to encourage walking and cycling and improve the key pedestrian route between the town centre and Watford Junction.
Consideration should be given to amending the policy wording to explicitly include an expectation for development along Clarendon Road to contribute towards urban realm enhancements directly through works delivered or through developer contributions to fund such works.
Policy T6
The County Council is supportive of the zonal approach to car parking guidance to encourage lower car ownership and usage in more accessible zones. The principle of 'Car Lite' development in the most accessible areas, within 5 or so minutes' walk of a major transport hub, is also supported as long as the needs of disabled drivers and visitors are considered.
Lower car parking provision must be accompanied by appropriate restrictions in surrounding residential streets and any public car parks to prevent spill-over parking. In order for this approach to lowering car usage to be successful, there needs to be parallel investment in infrastructure (eg significantly better cycle and bus routes) and urban realm improvements to support and actively encourage alternative modes of travel.
The County Council welcomes the requirements for car club spaces in the SPAs and where parking does not meet the guidance.
Policy T8 and Appendix H
The policy on cycle parking provision and the stipulations relating to quality contained in the policy is welcomed. Adequate cycle storage must also be provided for existing and high predicted future levels.
A small change is recommended to allow for cycle parking provision for dwelling houses to be in a private garage as well as within the private garden area - subject to the dimensions of the garage being adequate to accommodate cycles as well as any vehicle.
However, the policy only specifies one long-term space per unit (regardless of size or location) where there is no garage or shed. In some instances such as within SPA2 and SPA6 where housing will be in the form of apartments and where there will be reduced car parking, it may be necessary for additional capacity for cycle storage beyond one space per unit, especially for larger flats or any flats without car parking provided.
Policy UD3
Structures abutting and overhanging the public highway will need the approval of the Highway Authority (HCC) as will illumination visible from the highway.
Policy TB1
From a transport network and user perspective, locations near to major passenger transport hubs, offering good interchange between different services and modes, are the most appropriate for denser development (i.e. taller buildings). However, development proposals should all be subject to Core Strategy policies T2-T5 to ensure that their impacts are understood and mitigated.
In order for such development to be acceptable, there must be adequate and appropriate improvements to transport infrastructure and urban realm within the site and in the wider area, to ensure no significant adverse impact on the highway and passenger transport networks, as a direct, indirect or cumulative result of development at the site and in the Borough as a whole.
Policy TB2
Suggest change to text at 8. Transport, parking and infrastructure:
'The design should detail a transport strategy for the proposed development to include how cycle parking, car parking, cycle permeability and pedestrian permeability have been integrated into the overall design. This should be based on a Transport Assessment and should avoid negative impacts on the public realm. The scheme will also need to demonstrate that the required infrastructure and utility capacity has been fully appraised.'
Appendix G
Parking bay dimensions only seem to consider residential element, parking bay at 2.4 x 4.8m is fine for standard bay but dimensions of other bays should be provided e.g. parallel arrangement. The garage dimensions provided are 3m x 5.5m whereas the industry standards are 3m x 6m (MfS para 8.3.41). Should minimum circulatory space for car parks be covered here (i.e. 6m) or will it be covered elsewhere?
SPA1
The ring road constrains pedestrian and cycle accessibility to the heart of the town centre. nb includes EMP5, R1, R2, R3, R4, R5. See Highway Authority comments in regard to each of these.
SPA2
Any development within the Watford Junction SPA should ensure that connectivity for pedestrians and cyclists is improved across the site, between the site and the town centre and on other key routes to Watford Junction Station.
Development of the station building, forecourt and car parks must address current limitations including capacity, access and circulation issues, for pedestrians, cyclists, buses, bus users, taxis, as well as users of the car parks. Opportunities to make Watford Junction an attractive and functional transport interchange that can accommodate future growth should be maximised.
See Highway Authority comments on Draft Development Brief (below).
SPA3
Good quality cycle and pedestrian links through the site and between the site and surrounding area and key destinations (town centre, Vicarage Road MLX station, local schools etc.) must be provided, or contributions to support infrastructure improvements in the wider area made through developer contributions.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
SPA4
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
Support improvements to green infrastructure and public realm as a complement to improvements to pedestrian and cycle links.
Flooding is a known issue affecting this area. Any development in this area should be designed to avoid and mitigate flood risk. Sustainable drainage approaches and green infrastructure should be used where appropriate to reduce and manage flood risk.
SPA5
Development at this location will need to consider transport impacts on the highway network, including operation of the Dome roundabout and St Albans Road notably at peak times. Also junctions including M25/A405/M1, and M1/A41.
There is a need to improve cycle, pedestrian and passenger transport connectivity to the site, and between the site and the town centre and Watford Junction.
It is recognised that the Abbey Line (North Watford) station is closer to the site, but there are limitations to this service at present which will reduce its attractiveness as an alternative to the car for journeys to Watford Junction or St Albans Abbey stations.
Car parking must be effectively managed to avoid adverse impacts on the streets and communities in surrounding areas.
There is a typo on second bullet point - should read 'improve air quality'.
SPA6
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Cycle improvements on Rickmansworth Road may be required as this is a key corridor between Rickmansworth and Watford.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
Secure, high quality cycle parking is needed at the proposed Cassiobridge station, as well as within the employment premises.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
See Highway Authority comments on Masterplanning Study (below)
MXD3
Lower High Street is key movement corridor to and from the south of the borough. With the imminent opening of Thomas Sawyer Way from Dalton Way it will also carry Health Campus (SPA3) traffic. Developments along the corridor will be required to make contributions towards improving that corridor for all travel modes.
R1
It is agreed that robust pedestrian links with the town centre should form part of the new development at this location.
Good cycle access and high quality cycle parking also needs to be provided, for customers as well as employees.
R2
Agree that clear pedestrian connections between the site and the High Street are needed.
Good cycle access and cycle parking must also be provided.
There is a need to consider access needs to the site by different modes. A planned highway improvement scheme will make Clarendon Road one-way (NE-SW only) from Beechen Grove to High Street, with a contraflow cycle lane. Access to the street will be restricted by a Traffic Regulation Order to buses, taxis, cycles, 'blue badge' vehicles, and other vehicles 'for access only' to premises. All accessing vehicles will need to leave either via High Street or Watford House Lane (private road) for those accessing that area.
Development of this site should complement public realm enhancements proposed or already delivered on Clarendon Road and the High Street.
R3
Good cycle access and storage facilities must be provided, as well as good pedestrian links.
Developments at this location must take into account severance issues caused by the ring road for pedestrians and cyclists. Improvements required such as crossing improvements, new accesses into/through the site, should be delivered as part of the development or through developer contributions.
R4
Strong pedestrian and cycle links between this site and the town centre must be provided.
The quality of cycle routes and access to/from the west needs to be improved - eg. Market Street west of ring road and the Hornets Gyratory.
H1
This site is in close proximity to Bushey Station and includes its car park.
Opportunities to upgrade access to the station by non-car modes should be pursued.
Need to consider quantity and quality of cycle parking and cycle access to station from surrounding area.
Cycle access and cycle parking provision at Bushey station should be improved as part of any car parking replacement/improvement scheme.
Bushey Arches is a known congestion hotspot. Impacts of development on Bushey Arches must be considered and mitigation provided. This should include contributions to needed improvements to key walking and cycling routes and passenger transport infrastructure in the area.
H2
The ring road causes significant severance to people travelling by foot and cycle. Particular issues have been reported for people with visual impairments.
Improved cycle and pedestrian links to town centre and to Watford High Street and Watford Junction stations are needed from the site.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
H3
This site is about half mile from both the proposed Vicarage Road Met Line station and Watford High Street station, which is 10 to 12 minutes walking time.
Cycle parking provision must be to a suitable level and quality, in particular if a 'car lite' development is proposed.
Vicarage Road is a busy road without dedicated cycle facilities. As such improvements to this route for cyclists should be considered. Developer contributions to improving cycle routes may be appropriate.
H5
The traffic impact on west Watford's road network needs to be considered and mitigated.
Cycle and pedestrian links into the site from different directions are required.
Adequate cycle storage must also be provided for existing and high predicted future levels.
Cycle infrastructure and the pedestrian environment of the surrounding area needs consideration.
H9
The impact of development at this site on the road network must be considered and mitigated if needed, including Rickmansworth Road and West Watford.
Good cycle links are needed including between the site, the town centre, and Ascot Road.
Bus services and infrastructure, including linking to new Cassiobridge Met Line station.
Bus services in this area may well be subject to change following the loss of the underground station. Development of this site and any forthcoming S106 contributions would provide the opportunity for an assessment to be made of potential improvements to bus services so this site remains connected to key destinations.
E1
High quality, secure cycle provision is needed at business premises.
Although the Ebury Way provides a good cycle route to the site, this will not be suitable for use all year round, at any time of day. As such improvements to the A412 corridor cycle infrastructure should be explored and provided. Developer contributions may be appropriate.
Improved pedestrian and cycle linkages are needed through the site, and also between the site, surrounding area and key destinations.
Although the MLX line assists connectivity to and from the site by passenger transport, there is also a need for bus services that are complementary and adequate passenger interchange facilities at Ascot Road to maximise use of Met Line services.
A bus and cycle link from Tolpits Lane through to Watford Business Park should be provided to better connect the employment areas as required by paragraph 10.6.9 in the WBC Core Strategy.
E2
Cycle and pedestrian routes through the site need improvement;
Via Watford Junction SPA site, there is a need to reduce severance and improve pedestrian and cycle connectivity to Watford Junction station and Clarendon Road.
WBC also needs to consider the implications of the Colonial Way Link road on development at site E2.
There is a need to consider potential transport implications of this site and the Watford Junction masterplan as a whole, including traffic accessing any new station multi-storey car parks, and the impact on the road network (eg. Colonial Way, Stephenson's Way, Radlett Road, Link Road, A41/M1 junction...).
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions.
E4
On-street parking in this area will need to be managed to minimise encroachment into neighbouring residential areas and avoid dangerous parking around junctions and on footways.
E5
Needs to link with SPA2 Watford Junction.
Development will need to assess impacts on road network and car parking demand in surrounding area.
Quality of pedestrian and cycle environment and urban realm on Clarendon Road should be considered and opportunities to enhance in consistent, coherent way should be explored to promote sustainable travel and improve route between town and Watford Junction.
Buildings will need to provide adequate, high quality secure cycle parking. If low car parking, may need to increase requirements or leave space to expand provision as required.
G6
Any change in land use/ status/ access provision to the south of Caxton Way and the south and east of Greenhill Crescent should not be permitted until its ability to provide the link for sustainable modes between Tolpits Lane and Caxton Way required by paragraph 10.6.9 of the WBC Core Strategy has been fully explored and ruled out.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF
1.1
The traffic and transport impacts of the masterplan scheme have not been modelled and thereby understood. The Highway Authority is, therefore, unable to fully support the plan until those impacts are assessed and deliverable mitigation measures agreed. HCC is developing traffic and transport models of Watford as part of its work to create a Growth & Transport Plan for the area. These will be used to test the impacts of the Watford Junction and other development proposals on transport infrastructure and services individually and cumulatively.
As part of earlier work on this site the County Council had required the construction of a road and bridge linking Colonial Way and St Albans Road via Penn Road. The scheme to build it received outline DfT funding and included a passenger transport (coach) interchange on the northeast side of the station. If the link road and bridge are no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
1.2
Correct reference to 'Abbey Link' in map to 'Abbey Line'.
2.1
The Barriers plan acknowledges the severance created by the presence of the Abbey Line. As part of earlier work on this site the County Council had required the construction of a road over the Abbey Line linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.2
Policy T1 in the borough council's Core Strategy supports conversion of the Abbey Line from heavy to light rail operation.
Correct reference to 'Abbey Flyover' in Objectives to 'Abbey Line'.
2.3
Correct reference to 'Abbey train line' under Transport and Parking to 'Abbey Line'.
As part of earlier work on this site the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
2.4
Gross External Areas values are different to those in 5.1 Area Schedules.
3D views might benefit from road names for orientation.
2.7
As part of earlier work on this site, the County Council had required the construction of a road linking Colonial Way and St Albans Road via Penn Road. If this is no longer to be provided, the impacts on the wider network will have to be assessed and accepted by the County Council.
It is recommended that all roads are usable by cycles to aid permeability.
The road hierarchy titles have different meanings in the Highway Authority's own existing hierarchy. As the design is refined it is recommended that confusion is avoided by using different names.
2.8
The impacts on the wider network of the proposed car parking arrangements will have to be assessed and accepted by the County Council.
3.3
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
3.4
The connection of the southern end of the proposed public pedestrian concourse bridge with the public highway at ground level is critical to its usability and hence success.
4.1
The County Council will require a full understanding of the overall infrastructure requirements of the masterplan area in order that they can be considered in the emerging Watford Growth & Transport Plan. Joint working with the County Council will remain key in order to maximise access to appropriate funding streams and delivery programmes.
Special Policy Area 2 is zero-CIL-rated so that all planning obligations will be derived via Section 106 agreements with service providers.
4.2
An overall Travel Plan for the site will be required and one for each subsequent development area should be provided and agreed.
5.1
Total car parking number differs from that given in 2.4 and Station Quarter East breakdown (p 46).
Gross External Areas values are different to those in 2.4.
WATFORD JUNCTION DRAFT DEVELOPMENT BRIEF VIABILITY APPRAISAL
4.2
The County Council is concerned about the unrealistically low estimates given in figure 4.1 for the costings of infrastructure required to mitigate the impact of the masterplan.
CROXLEY VIEW/ ASCOT ROAD STUDY
Introduction
Mention must be made of the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The need for a link both for Watford and Three Rivers grows as pressure to develop either side of the Ebury Way increases and its delivery should be seen as key to both authorities' Duty to Cooperate.
Plans
All plans refer to Watford County Council.
All plans show Croxley Green Business Park to the southwest of the masterplan area. This is correctly the Wolsey Business Park.
Most plans show the Grand Union Canal badged as the River Gade which runs to the south and east of it.
Some plans do not show the correct alignment of the Watford/ Three Rivers boundary.
Some plans erroneously label the NE corner of Croxley Common as Cassiobury Park Nature Reserve.
Masterplanning Strategy plan - asterisks and other labelling are not described and inconsistently applied.
Potential Development Sites plan
This omits to include the Tech Site (around Woodshots Meadow). This is subject to preapplication discussions now and should be considered with the adjacent sites as it is in Employment Policy Area E1 (Local Plan Part 2 appendix 1).
Proposed Vehicle and Pedestrian Movement plan
This omits the policy aspiration to create a link for sustainable modes between Tolpits Lane and Caxton Way as set out in paragraph 10.6.9 of the WBC Core Strategy. The route currently being explored follows the cycle track between the Watford Enterprise Centre and number 27 Greenhill Crescent.
Historic environment, landscape and ecology
The County Council supports the overall policy intentions of the Local Plan covering landscape, ecology and the historic and built environment and provides the following comments to help strengthen these policies and their supplementary text.
Historic Environment
Development Management Policies
The County Council welcomes the Borough's consideration of the Historic Environment in Part 9 Urban Design and the Historic Environment. However, the historic environment should be referenced in line with the NPPF definition of heritage assets. In addition to historic buildings (both designated and undesignated), the historic environment of Watford includes archaeological remains, historic landscapes and historic parks. Therefore policies are needed to conserve the historic environment as whole, not just designated buildings, registered gardens and conservation areas as is currently stated.
Under Policy UD4, Archaeology, there appears to be repetition of the NPPF, the policy is unclear and should be re-written.
There is also reference to the conservation of heritage assets being secured by an archaeological Written Scheme of Investigation (WSI). Whilst the County Council welcomes the requirement for these documents and for them to include provision for publication and public dissemination of results where appropriate (NPPF 141), it is not clear if the WSI on its own is considered to be robust enough to secure appropriate conservation of the historic environment. Therefore it is unclear if this part too, is effective.
Watford Junction Draft Development Brief 2016
Paragraph 4.2 notes that a Heritage Statement and Desktop Archaeological Study may need to be submitted with any planning applications. However, it is unclear what is meant by a Heritage Statement. Also archaeological assessment may not be limited to a desktop study.
Site Allocations
An appraisal of the archaeological implications of development for the new areas identified in the Second Consultation document (2016) is summarised below.
1. Archaeology as a Development Constraint
N/A
2. Requirement for Pre-allocation Archaeological Assessment
The sites below have known archaeological remains within them or have significant archaeological potential by reason of their size and situation, such that there is a risk that archaeology could be a constraint on any development. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that archaeological assessments should be included within all development briefs and other proposals for the sites, before they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the sites, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent of archaeological remains that might be a constraint upon the principle of development of these sites.
Allocation numbers: SPA1, SPA4 and H9.
3. Requirement for Pre-application or Pre-determination Archaeological Assessment
The sites below have known archaeological remains within them or have archaeological potential. The County Council would therefore wish that - in accordance with Government policy contained within the NPPF (for example paragraphs 156, 157) - the LPA requests that that pre-application or pre-determination archaeological assessments should be included within all development briefs and other proposals for the sites, if they are formally adopted as development sites in the local development plan. Such assessment would, depending upon the size and location of the proposals, range in scope from additional desk-based research to more extensive archaeological field survey and evaluation. The purpose of the archaeological assessment would be to provide sufficient information about the archaeological resource and in particular the extent
of archaeological remains worthy of preservation in situ, to enable the LPA to determine any specific application for development.
Allocation numbers: SPA 2, SPA3, SPA5, SPA6, MXD1, MXD3, R1, R2, R3, R4, H2, H3, H4, H 10, E1, E2, E3, E4, E5, E6.
4. Mitigation of archaeological impact by condition
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, any archaeological issues can probably be dealt with by condition, should planning permission be granted.
Allocation numbers: R5, CF1, H1, H5, H6, GT1.
5. No archaeological requirements
At this stage, (without prejudice to any future advice) it is advised that for the sites listed below, there are unlikely to be any archaeological implications. However this will depend on the details of any proposals and any new archaeological information.
Allocation numbers: MXD2, MXD4, H7, H8, H11.
Ecology
Development Management Policies
Policy SD15, External lighting, the County Council support the provisions set out in this policy and advise that there should be reference to the guidance provided by the Institute of Lighting Engineers which has been instrumental in seeking to reduce the impacts of artificial lighting within the environment.
Green Infrastructure, Biodiversity and Recreation, the County Council supports the reference to Green Infrastructure (GI).In defining GI there should also be reference to the provision of local food production as a key ecosystem service.
Policy G15, Trees, Woodlands and Hedgerows, this policy is supported in respect of highlighting ecological and cultural value of trees, woodlands and hedgerows. However, under paragraph 10.3, the reference to valuable habitats should be extended to include reference to ecological networks and corridors. Under paragraph 10.6 it should be clarified that replacing trees lost to development cannot compensate for the loss of biodiversity or amenity value in the short term.
Policy GI6, Protecting and Enhancing the Grand Union Canal, this policy is supported including the reference to enhancing biodiversity under paragraph 10.11. It is advised that the policy is extended to include a clause that seeks to improve the biodiversity of the canal corridor where possible. Development that would have an
adverse impact on the biodiversity of the canal would not be supported unless it can demonstrate provision of suitable mitigation or compensation.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, this policy is supported however recommend the following clarifications and amendments.
It is advised to make reference to the 'amenity value' of the river, specifically encouraging 'recreation' may increase disturbance to sensitive wildlife within river corridors. The term 'amenity' embraces visual and recreational importance without being too prescriptive or disruptive if more sensitive habitats or locations are affected an important consideration within this largely urban area.
With regards the provision of 'a corridor for wildlife and biodiversity,' the reference to biodiversity should be deleted as wildlife is biodiversity. With regards replacement structures and fish passage, liaison with the Environment Agency is essential if any such works are proposed. With regards access it should be designed in a way that also enables some undisturbed areas to be retained.
Policy GI9, Provision of Open Space and Play Space in Residential Development, aspects of this policy relevant to biodiversity are supported. The reference to green space typologies should be expanded to include allotments and community orchards, in order to reflect the types of functional sites which support both community and biodiversity benefits.
Biodiversity, it is not clear why this section is formatted differently to the preceding and subsequent sections. In particular it does not describe 'Why is this policy needed?' and 'what is it intended to do?' In setting out the need for the policy, it should reference the legislative requirements of statutorily protected sites and species which are a material consideration in planning, as well as the Duty placed on Local Authorities to have regard to conserving biodiversity in all of their functions as set out in the Natural Environment and rural Communities Act 2006. In setting out the intention of the policy there should also be reference to seeking to deliver the aims of the Local Nature Partnership - for which securing ecological resources, functions and services are a consideration when determining planning applications.
Under paragraph 10.37 the reference to the 'Biodiversity Plan' should be amended to reference to the 'Biodiversity Action Plan principles' (BAP). The BAP, nationally and locally, has ceased to be actively supported by National and Local Government, and has essentially been replaced by the Local Nature Partnership. However the principles underpinning it remain valid as statements and the intentions of the various habitat and species action plans are sound in themselves and could be followed if resources or interest permitted.
It is suggested that the statement under paragraph 10.39 should be amended as follows:
'This policy expects that where appropriate, development proposals will demonstrate the relative ecological value of a site before and after development. Proposals should follow the mitigation hierarchy and provide clear evidence of impacts and enhancements where appropriate, consistent with the aims of NPPF, BS42020
"Biodiversity - Code of Practice for Planning and Development'' and guidance provided by CIEEM. This will require sufficient detail and clarity to enable net losses and gains to be identified and monitored, consistent with the Code. Where unavoidable, Biodiversity Offsetting should be considered as a means to ensure there is no net loss of biodiversity resulting from development'.
Highlighting the specific use of Biodiversity Calculators such as the one mentioned in paragraph 10.39 can be a little misleading. BS42020 does not mention the use of biodiversity calculators, and taken out of context the results of such calculations can sometimes show net gains where there should be none (removal of ancient woodland for example cannot reasonably be compensated in the real world). Other wider landscape issues are also not always considered by these calculators; if the land is part of a wider corridor, or a biodiversity network for example. It has taken several years for Warwickshire County Council to incorporate their use in to the planning system and there is still not universal agreement on them.
The County Council would therefore advise caution on their avocation, but rather emphasise the need to prove that biodiversity has not been lost and in the most part enhanced through "appropriate methods in-line with BS42020".
Policy GI10 Managing Biodiversity in new Developments. The County Council supports Watford Borough Council's commitment to increasing biodiversity within the district. The Policy is consistent with other Hertfordshire Local Authorities, and in-line with the National Planning Policy Framework.
The following amendments are advised. There should be reference to avoiding negative impacts upon ' local ecological networks...,'as each site sits within a local environmental and should retain or enhance any existing ecological resources or corridors to and from adjacent sites.
'Compensation will only be considered as a last resort. Development proposals will be expected to evaluate the impact on local biodiversity where appropriate and propose measures to maintain and enhance biodiversity. This approach should follow the principles outlined within BS42020 "Biodiversity - Code of Practice for Planning and Development" or other measures of best practice, including Biodiversity Offsetting where necessary'.
The above wording embraces the mitigation hierarchy as well as defining means to achieve no net loss as sought by NPPF, without being too prescriptive.
It is considered that paragraph 10.40 regarding the biodiversity calculator is not needed if references requiring its specific use are otherwise removed. The County Council remain concerned that some caution needs to be taken regarding the generation of positive scores which indicate a net gain despite losses that may otherwise be considered unacceptable.
Site Allocations
Please refer to Appendix 1.
Landscape
Green Infrastructure, Biodiversity and Recreation, the policy framework for green infrastructure (GI) was significantly strengthened in Feb 2016 with the introduction of detailed Planning Policy Guidance. The guidance states that GI is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water and should be a key consideration in both local plans and planning decisions.
The Herts Landscape and Green Infrastructure Group is currently looking at GI delivery and practice across Hertfordshire with a view to presenting a project proposal to Herts Infrastructure Planning Partnership (HIPP) in November. The key aim of the project is to mainstream the delivery of GI through the local plan and development management processes. The outputs and deliverables of the project are currently being shaped and should help provide local planning authorities with a good practice approach to GI delivery, supported by robust evidence and case studies.
The Landscape Institute Position Statement for Green Infrastructure provides a widely supported definition of GI (assets and functions) and a comprehensive overview of the key benefits it can deliver, supported by case studies http://www.landscapeinstitute.org/policy/GreenInfrastructure.php
There is no reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans. (The strategies provide an opportunity to address cross boundary issues and meet the Duty to Cooperate. (Hertfordshire and GreenArc Area Strategic Highlights Plan (SHiP) and the All London Green Grid.)
There should be greater emphasis on GI in place-making and conserving and enhancing local distinctiveness. There should be reference to any local character assessments and the guidelines for managing change that should help shape proposals, and conserve and enhance local character.
At a national level there is also the National Character Areas produced by Natural England https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making, and at a regional level there is the East of England Landscape Framework http://landscape-east.org.uk/.
Where proposals are likely to result in landscape and visual effects a landscape and visual impact assessment, in line with industry good practice guidance (Landscape and Visual Impact Assessment third edition Landscape Institute and Institute for Environmental Management and Assessment) may be required as part of an application. The mitigation hierarchy should be referenced to ensure that proposals seek to avoid and minimise any negative effects.
The reference to Green Infrastructure under paragraph 10.1, is fully supported, however it is suggested to expand the definition to include reference to blue assets
such as the Grand Union Canal. Also suggest amend reference to 'mitigating climate change' to 'mitigating the effects of climate change.'
Under paragraph 10.3, it should be clear that biodiversity is not the only driver for Green Infrastructure; other key drivers include a single or multiple land-use functions and include waste/water management, recreation, food production, local distinctiveness etc.
Policy GI5, Trees, Woodlands and Hedgerows, the reference to the protection of trees in line with current British Standard Institute code of practice is fully supported, however the full title of the standard does not appear to be referenced and should be 'Trees in relation to design, demolition and construction' (BS5837:2012). In addition it is advised that where required by the planning authority, tree surveys, arboricultural impact assessments and method statements should all be carried out in compliance with this standard.
The policy should be expanded to include reference to the current hedgerow regulations, the provision of a landscape strategy, planting plans and specifications, and the provision of aftercare (long term management plans) and replacement of failures.
Policy GI6, Protecting and Enhancing the Grand Union Canal, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Policy GI7, Protection and Restoration of River Corridors and Watercourses, include reference to the Hertfordshire or Watford Strategic Green Infrastructure Plans.
Yours sincerely,
Paul Donovan
Environment Department
Hertfordshire County Council
APPENDIX 1
Please find below a brief ecological assessment of the site allocations. A 'standard' template for each Site has been provided.
Ecosites do not have any form of status of importance, but are merely sites that we have some ecological information on - thus they do support some wildlife interest, at least at a local level. Whilst these sites are often a valuable starting point in identifying the county's wildlife resource, they do not meet the rigorous and quantifiable assessment criteria needed to identify them as non-statutory Local (County) Wildlife Sites.
SPA1 Town Centre
Recognised sites adjacent / close to Site: close to eastern end of Cassiobury Park Local Wildlife Site.
Other features: Little semi natural habitat present, possibly some mature trees.
Protected species: Probably bats, badger records to the west.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA2 Watford Junction (includes a safeguarded rail aggregates depot at Orphanage Road)
Protected species: Unknown - no records
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA3 Health Campus (includes a Borough Council Depot and Waste Transfer Station at Wiggenhall Road)
Recognised nature sites within Site: The Lairage Land Local Wildlife Site (LWS) and Local Nature Reserve (LNR), Croxley Green Junction Sidings LWS, Oxhey Park River & Margins LWS; Riverside Road Waste Ground ecosite (local database site), The Island, off Cardiff Road ecosite, Oxhey Park ecosite
Recognised sites adjacent / close to Site: Horwoods Avenue Playground ecosite, Moor View ecosite, Cardiff Road Embankment ecosite.
Other features: includes village green - "Green situated between Riverside Road & the River Colne"
Protected species: Birds and Water voles.
Opportunities: High. Habitat management to maintain and enhance biodiversity interest, green infrastructure / corridors.
Ecological sensitivity: Medium to high depending on location.
Fundamental ecological constraint: Presumption to avoid development on Local Wildlife Sites, fragmentation of green corridor,
Loss of Farm Terrace allotment site - should be offset elsewhere as open space / community food growing / ecological resource.
SPA4 Lower High Street
Recognised sites adjacent / close to Site: Bushey Hall Farm ecosite, Oxhey Park ecosite.
Other features: "Recreation Allotments" village green.
Protected species: Unknown - no records. Birds in trees.
Opportunities: Limited as previously developed site. Potential green corridors along railways lines.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for reptiles close to the railway line so possibility of reptile survey if suitable habitat will be lost.
SPA5 Dome Roundabout (includes a Waste Transfer Station at Colne Way)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
SPA6 Western Gateway (includes area of search ELAS221 in the Hertfordshire Waste Site Allocations Document)
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite, Ascot Road ecosite.
Recognised sites adjacent / close to Site: close to eastern end of Croxley Common Moor Site of Specific Scienttific Interest (SSSI) and LNR.
Other features: Grassland strip along eastern boundary with bordering trees.
Protected species: Unknown - no records.
Opportunities: Enhance green infrastructure corridor along eastern boundary.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds in trees.
The ecosites have largely been destroyed by development.
MXD1 North Watford library, Lemarie Centre for Charities, and health facilities (within SPA5)
Other features: Some trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
MXD2 The Brow
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
MXD3 Gas holder site (within SPA4)
Other features: River Colne borders the eastern boundary.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site. Potential to enhance the river margins as a green corridor.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in the trees.
Largely developed but riverside trees most important and scrub on site.
MXD4 Ascot Road
Recognised nature sites within Site: Ascot Road Car Park and Waste ecosite.
Other features: As well as the rough ground and bordering trees of the area to the west, the Site includes part of the school playing fields to the east, which is short mown amenity grassland. There are also some mature trees.
Protected species: Unknown - no records.
Opportunities: Potential enhancement of the areas of semi-natural habitat to improve green corridor connectivity.
Ecological sensitivity: Low.
Fundamental ecological constraint: Potential for nesting birds. Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R1 Sainsbury's and adjoining land
Other features: The north-eastern part of the Site includes an area of grassland and mature trees.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R2 Former TJ Hughes and adjoining land
Other features: Small area of amenity grassland on the north-eastern side.
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R3 BT Telephone Exchange and adjoining Wellstones
Protected species: Unknown - no records.
Opportunities: Limited as previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
R4 Church Street Car Park and land fronting Market Street/Market Place
Other features: area of amenity grassland and scattered trees on the southern side.
Protected species: Unknown - no records.
Opportunities: Limited as predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
R5 Charter Place centre and adjoining land onto the High Street
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
CF1 Community Facility Tolpits Lane.
Other features: Site appears to be rough grassland with scattered scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to enhance the habitats on site. The northern boundary is a wooded bank bordering the railway line. Maintain / enhance green corridor along railway.
Ecological sensitivity: Low - medium as semi-natural habitats on site.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H1 Land at Pinner Road
Other features: There are small areas of rough (possibly amenity) grassland with scrub and scattered trees.
Protected species: Unknown - no records.
Opportunities: Limited as a predominantly a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H2 Skatepark, Lower Derby Road
Other features: There is an area of grassland with trees in the north-west corner.
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a predominantly a previously developed site. Potential to maintain / enhance the semi-natural habitats on site for green corridor links to nearby habitats, river corridor and wooded railway banks.
Ecological sensitivity:
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds.
H3 Vicarage Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H4 Telephone Exchange - First Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H5 Builder's Yard, Queens Avenue
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H6 Bill Everett Community Centre
Recognised sites adjacent / close to Site: adjacent to Long Spring and Harebreaks Wood (Watford) Local Wildlife Site and Local Nature Reserve.
Other features: some areas of grassland (probably amenity?) and occasional scattered trees.
Protected species: Bat roost in building nearby.
Opportunities: Potential to link woodland to the south to area to the north - depending on what the latter is like, as it appears to be bare ground on our aerial photographs.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
H7 Rickmansworth Road
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H8 Garages- The Gossamers
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
H9 Watford Station, Cassiobury Park Avenue
Recognised nature sites within Site: Cassiobury Park Avenue allotments ecosite.
Recognised sites adjacent / close to Site: close to "Gade Avenue" Local Wildlife Site.
Other features: Includes an area of allotment gardens and mature trees.
Protected species: Unknown - no records. Potential for bats and reptiles.
Opportunities: Maintain and enhance the green corridor link along the railway line.
Ecological sensitivity: Low - medium?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H10 Croxley View
Other features: Area of semi-natural grassland with scrub and trees.
Protected species: Unknown - no records.
Opportunities: Potential to manage the existing habitats to maintain / improve biodiversity. Maintain as a green infrastructure link from open grasslands to the south towards the River Gade corridor and semi-natural habitats to the north
Ecological sensitivity: Low.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
H11 Garages, Bowmans Green
Protected species: Unknown - no records. Unlikely.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: None.
GT1 Lands at Tolpits Lane
Other features: Area of rough grassland with bordering trees.
Protected species: Unknown - no records.
Opportunities: Limited, but part of semi-natural grassland complex in the area so potential for linking hedgerows. Any loss of grassland could be compensated for by enhancement elsewhere and landscaping may provide additional buffering habitats locally if this site were to be developed as such.
Ecological sensitivity: Low?
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species.
E1 Watford Business
Recognised sites adjacent / close to Site: adjacent to Croxley Common Moor Site of Special Scientific Interest (SSSI and Local Nature Reserve (LNR) and Commonland; adjacent to Ascot Road Car Park and Waste ecosite, adjacent to Ascot Road ecosite; close to Ascot Road Scrub Local Wildlife Site.
Other features: Some areas with trees.
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
Part of the edge of this currently provides a valuable buffer and boundary edge to Croxley Common Moor SSSI and LNR. We would object to any development which further degraded this boundary habitat, although much of the former area has already been lost to hard surfacing.
E2 Imperial Way / Colonial
Protected species: Limited as a previously developed site.
Opportunities: Low.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E3 Fishers
Recognised nature sites within Site: Cardiff Road Embankment ecosite.
Recognised sites adjacent / close to Site: adjacent to Croxley Green Junction Sidings Local Wildlife Site.
Other features: Disused railway line to the west is bordered by woody vegetation.
Protected species: Unknown - no records.
Opportunities: Potential green corridors east / west across the site and along the western boundary. Maintain a buffer against LWS to the south.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building. Potential for nesting birds in trees.
E4 Greycaine Road / Odhams / Sandown Road
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E5 Clarendon Road / Station Road / Bridle Path Office Area
Protected species: Unknown - no records.
Opportunities: Limited as a previously developed site.
Ecological sensitivity: Low.
Fundamental ecological constraint: Possible bat assessment of buildings advised if proposed for demolition or conversion, depending on age and structure of specific building.
E6 Leavesden Studios - the Island site
Recognised nature sites within Site: part of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Recognised sites adjacent / close to Site: adjacent to the rest of the extensive 65 ha "Leavesden Aerodrome Central" ecosite.
Other features: Semi-improved grassland habitat, part of a much larger complex.
Protected species: Badger setts on site and nearby.
Opportunities: Linking habitats to similar adjacent grasslands.
Ecological sensitivity: Low - medium.
Fundamental ecological constraint: Advise Preliminary Ecological Assessment to determine the ecological interest of the habitats and the potential for protected species, with particular attention to badgers

Object

Watford Junction Draft Development Brief 2016

Representation ID: 860

Received: 27/09/2016

Respondent: Mr Jamie Thompson

Representation Summary:

The track alignments required for this mean that some of the buildings in the plan need to be altered or removed. Annotations have been provided.

Full text:

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

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

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

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

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

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

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 861

Received: 27/09/2016

Respondent: Mr Jamie Thompson

Representation Summary:

Plans make no mentioned of the Abbey Line Realignment

Full text:

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

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

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

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

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

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

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 862

Received: 27/09/2016

Respondent: Mr Jamie Thompson

Representation Summary:

Would like to know if consideration been made to replacing the link that Orphanage Road provides with a new route through the development. Failing that however, new underground platforms at Watford Junction could be located far closer to the mainline platforms, greatly improving the passenger experience and promoting use of the line

Full text:

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

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

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

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

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

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

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 863

Received: 27/09/2016

Respondent: Mr Jamie Thompson

Representation Summary:

Would like to ensure that consideration has been made to investigate whether burying the line underground in a shallow tunnel through the development during construction has been investigated

Full text:

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

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

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

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

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

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

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 864

Received: 27/09/2016

Respondent: Mr Jamie Thompson

Representation Summary:

Essential that the Abbey Line is retained as a heavy rail link as its potential uses in that regard are far higher than is widely considered

Full text:

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

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

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

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

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

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

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

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

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

Comment

Watford Junction Draft Development Brief 2016

Representation ID: 865

Received: 27/09/2016

Respondent: Mr Jamie Thompson

Representation Summary:

There is a need to provide more platforms and a number of reasons are identified.

Full text:

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

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

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

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

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

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

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

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

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