Havering Local Plan 2016 – 2031 · Havering Local Plan 2016 – 2031 Representations on behalf of...

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_______________________________ Havering Local Plan 2016 – 2031 Hearing Statement Matter 2 –Spatial Strategy and Strategic Development Areas Representations on behalf of Thomas Bates & Son Limited Land to the south of Lillyputts Farm and east of Wingletye Lane, Hornchurch. September 2018 | AM-P Ref: 12026

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Page 1: Havering Local Plan 2016 – 2031 · Havering Local Plan 2016 – 2031 Representations on behalf of Thomas Bates & Son Limited Site and Surroundings and Sustainability . 1.5 Thomas

_______________________________

Havering Local Plan2016 – 2031

Hearing Statement

Matter 2 –Spatial Strategy and Strategic Development Areas

Representations

on behalf of

Thomas Bates & Son Limited

Land to the south of Lillyputts Farm andeast of Wingletye Lane, Hornchurch.

September 2018 | AM-P Ref: 12026

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Havering Local Plan 2016 – 2031Representations on behalf of Thomas Bates & Son Limited

Inspector’s Questions

1.0 Q2. Is it appropriate to consider other areas for development? Have all other options been explored?

1.1 As set out in our response to Matter 5 - Q2 and Q3, we consider that there are ‘exceptional circumstances’ to justify amendment to the green belt boundaries in order to identify additional housing land supply to help meet the development requirements within the LB Havering.

1.2 As shown on the attached Indicative Layout Plan (Appendix 1), we consider that land to the south of Lillyputts Farm and east of Wingletye Lane in Hornchurch, is currently deliverable as it is ‘achievable’, ‘suitable’ and ‘available’ (NPPF para 47), promotes sustainable patterns of development (NPPF para 84), and importantly can contribute to meeting the Council’s five-year land supply. We refer to guidance set out in the revised NPPF (para 68) which shows the direction of government thinking in confirming: “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” Land at Wingletye Lane, adjoins the edge of the existing Emerson Park settlement, to the north east of Hornchurch town centre. As such it offers an opportunity to achieve the type of development envisaged by paragraph 68 of the revised NPPF. Development of this land will also help to increase housing supply in the borough (particularly in the first five years). The site could make an important contribution to the Council’s Spatial Development Strategy.

1.3 As set out in our response to Matter 5 – Q3 we consider that the site makes a very limited contribution to the green belt and is therefore appropriate for ‘release’.

1.4 In order to demonstrate the site’s deliverability, we have undertaken a comprehensive appraisal. The Layout Plan attached at Appendix 1 sets out our initial proposals for the site.

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Havering Local Plan 2016 – 2031Representations on behalf of Thomas Bates & Son Limited

Site and Surroundings and Sustainability

1.5 Thomas Bates & Son Limited represent the owners of some 2.7 hectares of land to the south of Lilliputts Farm and east of Wingletye Lane, in Hornchurch. This land has been promoted for residential development via the emerging Local Plan for Havering. It has also been promoted in response to the GLA’s Strategic Housing Land Availability Assessment (SHLAA) ‘call for sites’.

1.6 The site is a broadly square shaped plot of self generated minor scrubland. It is bounded by existing housing to the south (fronting both sides of Wych Elm Road) and to the west (on the opposite side of Wingletye Lane). Lillyputts Farm lies to the north and agricultural fields to the east. A small group of houses to the north west and the access road to Lillyputts Farm and its complex of farm buildings create wider enclosure of the site. The site was purchased by the Bates family some 64 years ago. The Bates family then built the 16 dwellings fronting Wych Elm Road, including the creation of Wych Elm Road from its former use as a rough cart track. At no stage in the last 64 years has the site ever been farmed.

1.7 Located on the outskirts of the existing Emerson Park settlement to the north east of Hornchurch town centre, the site is well linked to community infrastructure, services and facilities. The site is located within a 20 minute walk of a range of educational establishments catering for all age groups (primary through to secondary). The Emerson Park Academy lies only 100m to the southeast of the site along Wych Elm Road. Well established transportation links would allow access to other educational establishments further afield.

1.8 In addition to its close proximity to existing bus routes (see plan at Appendix 1), Emerson Park train station is a 20 minute walk from the site or, for a direct route into central London, Hornchurch Station is a short bus ride away and is served by the District line. The site therefore provides a sustainable development opportunity with good access to central London as well as employment and retail uses in Hornchurch, Romford and Upminster town centres. Highway access to the strategic road network (A127 / M25) is via Wingletye Lane.

1.9 The site lies on the western fringe of the Green Belt and Countryside Conservation Area and adjoins the existing urban area. Mature tree lined field boundaries to the north and east of the site where it adjoins the open countryside, ensure that it is well

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Havering Local Plan 2016 – 2031Representations on behalf of Thomas Bates & Son Limited

contained. It is submitted that this land could be developed for housing without compromising the five purposes of the Green Belt as set out in paragraph 134 of the National Planning Policy Framework (NPPF).

1.10 The site is demarcated by strong, mature vegetation around its outer boundaries. The existing field boundaries could be reinforced by further planting to create a permanent edge to the urban area and prevent unrestricted sprawl. Existing housing along Wych Elm Road extends further into the gap between Hornchurch and Upminster than the proposed development site. Its release from the Green Belt and development for housing would not therefore cause these neighbouring towns to merge into one another.

1.11 As stated above, existing housing along this urban edge already extends further into the countryside than the proposed development site. Added to this, strong field boundaries would safeguard against encroachment into the countryside. There is no particular historic setting or character to maintain in this area. Finally, the proposed development could assist in urban regeneration by increasing local expenditure.

1.12 With sensitive design and screening a proposed housing development on this site would not detract from the character or appearance of the wider Countryside Conservation Area, to the east. In particular, the on-site density of development could be designed to provide a gradual transition from urban to rural.

1.13 The LBH is not able to meet its objectively assessed housing needs. Even on the basis of a low target for growth the Council cannot show a five year housing land supply. In this context the Council should be looking at its Green Belt boundaries very seriously to find land to release for development. This site represents a sustainable development opportunity. It is available and deliverable within the early years of the plan. Even at modest density levels the site could deliver at least 60 much needed dwellings.

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Havering Local Plan 2016 – 2031Representations on behalf of Thomas Bates & Son Limited

2.0 Q5. What evidence demonstrates that these areas [Strategic Development Areas] will be viable and developable within the timescales envisaged?

2.1 The proposed spatial approach set out in the Submission Local Plan is to direct the major growth to two Strategic Development Areas in the Borough’s main town centre at Romford, and a new neighbourhood on former industrial land at Rainham and Beam Park. Havering’s land supply is therefore predominantly made up of large brownfield sites that have long lead-in times and major constraints to delivery. As a result, even when set against its unrealistically low target for growth, the Council has previously acknowledged that it cannot meet its five year requirement for housing in the borough. Our representations to the Submission Local Plan set out a detailed critique of the two SDAs and individual sites expected to deliver the housing set out in the Council’s Housing Trajectory.

2.2 Over the plan period the Council propose to the deliver over 5,300 homes (at least 4949 homes in the first 10 years of the plan period) in residential and mixed use schemes in Romford Strategic Development Area. Specific opportunity sites will be identified in the Site Specific Allocations Location Plan. The arrival of Crossrail in 2018/9 is a key driver for that growth. The area is recognised as an Opportunity Area in the new London Plan. However, some of the sites within this SDA have already been rolled forward from the Core Strategy and Site Allocations Development Plan Documents for LB Havering, adopted in 2008. A decade later proposals for these sites have not come forward. This must call into question the likelihood of these now delivering as part of the Local Plan.

2.3 Rainham and Beam Park Strategic Development Area is identified as a major growth and regeneration area to provide a new residential neighbourhood accommodating over 3,000 homes and linked to the delivery of a new railway station on the existing Essex Thameside line at Beam Park.

2.4 Like the Romford SDA the Strategic Development Area centred on Rainham and Beam Park relies on sites that are subject to overriding problems in terms of numerous landowners and piecemeal development, existing industrial uses and problems of contamination and flooding. Previous representations contined advice from the development industry on the prospects for land along the A1309, New Road between Dovers Corner and the Marsh Way junction. This advice stated that the two end sites known as ‘The Bookends’ are potentially developable at some point, but that the

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areas in the middle are beset with problems such as disparate interests, multiple ownerships, existing landlords and tenants, underlying commercial value, need for relocation if the subject of a Compulsory Purchase Order, etc. The Council’s objective set out in the emerging Local Plan is to encourage development in a comprehensive manner, avoiding piecemeal ownership but it is difficult to see how this will ever be achieved. Our research shows that the ‘bookend’ sites have been delayed and that proposals by Countryside Properties for housing linked to a new railway station, and seen as a catalyst to regeneration at this location, were refused permission earlier this year.

2.5 Previous representations submitted in response to the Proposed Submission Plan on behalf of Thomas Bates & Son Ltd argued that the Strategic Development Areas are made up of largely brownfield sites that have long lead-in times and major constraints to delivery. There is insufficient evidence to demonstrate that these areas are viable or developable within the timescales envisaged. There remains considerable doubt over the sources of supply which are listed in the Councils Housing Position Statement. Our previous investigations have been updated. By way of example we have looked again at some of the key sites within the SDAs and find that the chance of these being delivered in the first five years of the plan is as little as 15%. By way of example:

• Angel Way Retail Park, Romford (350 units proposed, of which 200 in the first five years of the Plan) has been vacant with little change now for five years. The owners – Regency Homes – have yet to decide whether to sell the site or develop themselves.

• Former Somerfield Depot, Rainham – a ‘Bookend’ site (497 units proposed, of which 200 in the first five years of the Plan), requires considerable site preparation works that will delay development.

• St Georges Hospital, Hornchurch (290 units proposed to be delivered in the first five years of the Plan) was sold to Bellway Homes in 2017. Bellway have held talks with the Council to alter the application. The site has numerous preparation works to be undertaken prior to development and any revised proposals may still be subject to intervention by the Mayor of London.

• Dovers Corner, Rainham – a ‘Bookend’ site (394 units proposed, of which 218 in the first five years of the plan) requires significant site preparation and clean up prior to a development start.

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• Bridge Close, Romford (1070 units proposed, of which 155 in the first five years of the Plan) is a regeneration project in the town centre which is the subject of complicated land ownership that requires CPO powers.

• Angel Way and High Street Area (300 units proposed of which 75 in the first five years of the Plan) is subject to complicated site assembly and with numerous tenancies in place.

• Beam Park, Rainham (754 units proposed as part of a 2,900 home development with Dagenham, of which 282 units proposed in Havering in the first five years of the Plan) was refused planning in April 2018 due to the proposed height of development.

2.6 This updated evidence demonstrates that key sites in the SDAs remain complicated by obstacles to development and if they do come forward this will be towards the end of the plan period or beyond. This reinforces the importance in the overall spatial strategy for growth for small to medium sites such as that at Wingletye Lane, which the Government recognises in its revised NPPF have an important contribution to make in meeting the housing requirement of an area. In particular the availability of such sites can assist the Council in its very difficult task of providing new homes in the first five years of the Plan.

2.7 For the reasons set out above, it is submitted that a substantial revisiting of the plan strategy is required, based on full and up to date assessment of objectively assessed need for housing.

Appendix 1 – Indicative Layout Plan (drawing reference 12026-03, revision b).

© Andrew Martin – Planning, 2018. Ref 12026

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