Waltham Forest Council is consulting again on the 'Site Allocation' part of the new Local Plan (LP2).
You can read the revised proposals and comment here (link is https://www.walthamforest.gov.uk/planning-and-building-control/planning-policy/local-plan-consultations)
The Waltham Forest Conservative Councillors submitted the response below and if you would like support what we said, you can sign our petition by clicking through using the button below.
This submission is made on behalf of the Waltham Forest Conservative Councillors Group. In response to "SHAPING THE BOROUGH Waltham Forest local plan (LP2) Draft Site Allocations Document September 2020 (Regulation 19).
We are sorry to say that this is, largely, a repeat of what we submitted at the Regulation 18 stage because few of the concerns highlighted have been addressed in the revised documents. We are grateful for the removal of certain sites from the document, but the remaining designations remain of significant concern, because in large part, we do not believe them to be “effective”, because to deliver development in the form suggested would be contrary to the NPPF requirement that development should be in keeping with the character and appearance of an area. The designation is also not “effective” because, in certain cases which we will highlight below, the proposed developments are simply not financially viable.
We have significant concerns over the consultation process in addition to the specific concerns about the designations. There has been a real effort made by local people and Councillors to raise the profile of the consultation but the Council has made it very difficult for those who are not “online” to engage with it. We know that several residents have raised this and we will let their comments stand for us also.
We have separated our response into two sections; a general response on the process as set out in the Introduction and Methodology sections at the beginning of the document and then responses on specific sites based on our own knowledge and experience and on discussions we have had with local residents and community groups.
General Response
The Site Allocations Document ( "SAD” ) is vital to the "soundness" of the Local Plan as without sufficient land being identified, there is no way the Council can demonstrate that it can meet its housing target. Accordingly, we believe taking the LP1 policies part of the plan to Public Inquiry prior to the conclusion of the Regulation 19 stage pf the LP2 site allocations part of the plan is a flawed approach.
We note that the Council have included 65 potential sites within the SAD, but that this document fails to include sites which have been included in the Regulation 19 version of the LP1 document. (See Figure 4.1 Page 25 of that document).
We note that the SAD includes only what the Council describes as "Strategic” or "Key”sites, but it is less than transparent, some might say misleading, to consult on a document purporting to show where development will happen and what form that development might take, when in a later version of a separate document in the suite of Plan documents is suggesting a greater number of sites for development.
We also believe it is misleading to fail to include sites which the Council intends to include on the Brownfield Land Register.
The cumulative effect of this approach is to seek to accommodate a higher number of homes within the sites identified in the SAD, leading to a need for higher densities and taller buildings on that smaller number of sites than might in fact be necessary.
We are disappointed that the SAD pays only scant attention to the need to identify opportunities for development of land for uses other than residential. The LP1 document makes much of its aim to grow employment and provide cultural and leisure opportunities in the Borough, yet very few sites in the SAD focus on these important other uses.
We also note that with the exception of the Avenue Road estate and Priory Court estate, both of which are already being progressed as Estate Regeneration projects, the council has not included its own housing estates. Examples of potential estates which could be included are Aldriche Way in Highams Park and the Stocksfield Road estate in Wood Street, but a comprehensive planned approach is more likely to deliver improved, replacement and new homes over time than piecemeal redevelopment.
The Council retains ownership of circa 12,000 homes with approximately 3,500 homes on those estates having been bought under the Right to Buy schemes. A 50% uplift in the number of homes, which is a low estimate of the potential based on other schemes around London (but comparable to Marlowe Road) would allow almost 7,500 additional homes to be delivered in addition to the identified sites, allowing the target number of homes on the identified sites to be lowered.
We are specifically opposed to the document referring to supporting development based on a "minimum” number of homes on the identified sites. In certain locations, the minimum number will require development that is significantly denser and taller than the established character of the area and as such contrary to the policies set out in the National Planning Policy Framework.
Specifically, in the North of the Borough, the established character is suburban and the recent adoption of the Highams Park Neighbourhood Plan with overwhelming majority support, supports the view that this character should be preserved and enhanced, not changed.
We do not believe that the Council has justified its designation of sites in the North of the Borough as "Transformational” against the very clear opposition to taller, denser development that has been expressed in the responses to the Regulation 18 consultation on the LP1 document, in response to which over 700 people signed a petition asking for inter alia height limits to be included. We will comment on these further below.
We believe the proposals contained in the Planning Policy White Paper for design codes should be embraced by the Council, with Neighbourhood Forums established to develop these. Through this process, acceptable forms of development can be established and the number of homes and spaces for new business premises, cultural and leisure opportunities can be ascertained. We do not believe the current approach is consistent with the aims of Government policy in this regard.
Site Specific comments
SA46 - Sainsbury's and adjacent sites. We do not believe the designation of this site to be “effective” given the embedded value of the existing uses far exceeding the likely residential development value of the site when the Council’s policies of seeking 50% affordable housing are taken into account. This is a well-established retail store, hotel, car dealership and community transport hub, with playing fields adjacent to it. The car dealership opened less than five years ago. We do not believe this site to be viable because the value of the proposed 800 residential units is unlikely to be able to bear the cost of either buying out the existing uses or replacing them with adequate compensation to the occupiers for their loss of business during the period of redevelopment. The designation as a "Transformation” site suggests very tall buildings, which will be situated adjacent to an urban motorway and downwind of a waste incinerator. Neither factor would appear to have been properly considered in assessing the likely higher cost of development and the impact of that on viability. The Chingford Hall estate, which lies about 500m west of this site was redeveloped in the 1980s/90s and tower blocks were demolished. The resulting homes, a mix of two and three story terraced houses and three and four storey flats, have established a character for the area which has proved popular and less prone to negative outcomes such as anti-social behaviour and crime. Such factors should be considered when land is designated, but does not appear to have been. We believe this site should be designated as a "Transition” site with an FAR no greater than 2.0.
SA48 - Morrison's and adjacent sites. We do not believe the designation of this site to be “effective” given the embedded value of the existing uses far exceeding the likely residential development value of the site when the Council’s policies of seeking 50% affordable housing are taken into account. This is a well-established retail store and adjacent gym. The designation of this site as a "Transformation” site suggests very tall buildings which would be out of keeping with the suburban character of the area and over-dominant in an area of two storey terraced and semi-detached housing. It would also be downwind of the waste incinerator and the additional cost of construction to ameliorate this would not appear to have been considered in assessing the potential viability. We do not believe this site should be considered for any greater level of development than would be supported by a "reinforcement” designation with an FAR no greater than 1.4.
SA49 – Sainsburys and Hall Lane Car Park – We do not support the designation of this site as “Transformational”. It does not meet the criteria for this designation in the LP1 policies. The parallel masterplan exercise has raised immense local concerns, especially from adjacent residents who fear a significant loss of privacy. We also do not believe that the designation is effective as it is unlikely to be viable taking account of the need to protect existing residents amenity, replace a well-used town centre car park and meet the Council’s policy of providing 50% affordable housing, alongside buying out the embedded value of the existing supermarket.
SA50 - Former South Chingford Library We do not believe the designation of this site to be effective, against a requirement for the replacement of the community use and the open space, which are likely to make any development unviable, without imposing a form of development on the site totally out of keeping with the character of the homes adjacent to it.
SA51 – Albert Corner. The designation of this site has changed from “Reinforcement” to “Transition” between the R18 and R19 versions of the LP2 consultation. We oppose this. The parallel masterplanning exercise showed a building of nine storeys on the Old Church Road frontage and six storeys on the New Road frontage. We do not believe the designation of this site to therefore be “effective” as development in this form would be contrary to the NPPF requirement for development to be in keeping with the character and appearance of an area. It would also cause significant harm to adjoining homes, particularly those in Brook Crescent whose rear gardens would be both over-shadowed and overlooked.
SA59/60/68 We are aware of a response from the Highams Park Planning Group which addresses these sites and other opportunities in the Highams Park Neighbourhood Plan area. We support those comments in full.
SA61 - In our previous response, we supported the local campaign to designate part of the site as Local Green Space and we are pleased that this has been accepted. A petition in support of that and asking that any development of the site replaced the leisure facilities and that houses for families were built rather than flats, and that the height of the existing buildings was not exceeded was submitted as part of the earlier submission. In order to gather more fine-grained responses on these issues, we asked local residents to complete a survey asking individual questions. A report on the responses to that survey is attached. In summary 93% of the 597 respondents did not want this site included in the Site Allocations; there was an even spread of responses as to which of the existing leisure facilities people wanted to see replaced; support for the inclusion of more non-residential uses on the site; 90% (544) of respondents said the proposed allocation of 280 was too many; 80% of respondents wanted to see large family houses or smaller houses, not flats, built on the site; almost no respondents wanted to see buildings taller than four storeys and most wanted a maximum of two storeys; It is our view that the designation of this site is therefore not “effective” because it is not possible to replace the leisure facilities and provide policy compliant affordable housing with any form of development which would be remotely acceptable or policy compliant. We do not believe the parallel masterplanning exercise has demonstrated viability, even with a form of development which is deeply unpopular and wholly out of keeping with the character of the area. Again, there is no CPZ in this area and poor public transport, so it is likely developers would seek “exceptional” consent to include parking, further damaging the viability of the scheme.
