Core document: CDEX 05 Planning Policy Direct Line: 020 7525 5471 Email: [email protected] Mr D Smith BA(Hons) DMS MRTPI c/o The Programme Officer 5 August 2014 Dear Mr Smith, REVISED CANADA WATER AAP EXAMINATION IN PUBLIC; COUNCIL’S RESPONSE TO INSPECTOR’S INITIAL QUESTIONS I write with reference to your letter dated 11 July 2014 in which you set out initial questions. The council addresses each question in turn below. Other Plans and Community Infrastructure Levy (CIL) Inspector’s question: Could the Council update me on the progress of the Further Alterations to The London Plan and the New Southwark Plan. In addition, para 6.5.7 of the AAP indicates that the CIL will be brought into effect in 2014 but what is the latest position? I would be grateful if the Council could keep me informed of any further changes in respect of the above matters as the examination progresses. Council’s response: The progress of each of the three documents is described below. The council will keep the examination updated on any further changes. Further Alterations to the London Plan: The Secretary of State has appointed Mr Anthony Thickett BA Hons BTP MRTPI Dip RSA as the independent Inspector for the EIP. The hearings into the FALP are due to commence on Monday 1 September 2014 and are expected to run for 2-3 weeks. Of relevance to Canada Water, session 12 on Thursday 18 September focuses on the alterations affecting opportunity areas. However, there does not appear to be an intention to discuss the changes affecting Canada Water (an extract from the inspector’s list of matters is appended to this letter). Southwark’s response to the consultation on the FALP welcomed the designation of an opportunity area at Canada Water and the council has not been identified as a participant in the session. New Southwark Plan: The council has commenced preparation of the new Southwark Plan. The council is expecting to consult on issues and options between October and December 2014 and preferred options in autumn 2015. The publication version of the plan would be subject to consultation in 2016. These timescales are identified in the current local development scheme (LDS) 2013-2018 (CDS10). CIL: The examination hearings into Southwark’s Revised draft CIL Schedule (CDS19) took place on 29 and 30 July 2014. At the conclusion of the hearings the inspector noted that unless he were to decide that additional evidence was required, he would expect to submit a Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly draft report to the Planning Inspectorate by mid August. Subject to receiving a positive recommendation from the planning inspector, the council anticipates introducing the CIL by the end of 2014. Planning Permissions Inspector’s question: Could the Council please provide an update of any planning permissions affecting allocated sites with the AAP area (including those sites now deleted) and of sites where development has commenced. This should also be kept up-to-date as the examination progresses. Council’s response: Appendix 2 of the Housing background paper (CDLR13) gives an up-todate list of permissions, as of April 2014 when the background paper was prepared. Since CDLR3 was prepared, the following decisions have been taken which affect the allocated sites: • • St Pauls Sports ground (CWAAP1): Permission granted to refurbish the sports ground, including replacement and enlargement of the playing surface, construction of spectator stands, a club house, changing rooms and new fencing. Land adjacent to Surrey Docks Stadium (CWAAP2): The council has resolved to grant permission, subject to the completion of a legal agreement, for the erection of 103 homes on the allocation site and the creation of a new public park on the adjacent playing field (the former Surrey Docks stadium). For the sake of completeness, the list of permissions which was shown in appendix 2 of CDLR13 has been updated and is appended to this document. Permissions for nonresidential uses on allocated sites have also been added to this list. The council is currently undertaking a borough-wide completion survey and any updates which affect smaller, unallocated sites at Canada Water, or permissions on small unallocated sites will be added and the list will be kept up-to-date as the examination progresses. Policies Inspector’s question: 1. Policy 1 refers to Sites A & B but these have been deleted from the Schedule of Proposals Sites at Appendix 4 (CW AAP5 & CW AAP6). What is the latest position with those sites and what is the rationale for retaining them within Policy 1? Council’s response: Site A (Maple Quays adjacent to the Canada Water tube station) and Site B (Canada Water library, plaza and Toronto and Montreal Houses) have been completed. The reference to them in policy 1 was maintained as they contributed to helping meeting the area-wide aim of securing 35,000sqm of new retail space. Notwithstanding this, if you considered it appropriate, the council would not object to the deletion of the references to sites A and B and does not consider that it would represent a substantive change to the plan. Between them, sites A and B provided 2,000sqm of new retail space. If the reference to sites A and B were deleted, the council would suggest that the figure of 35,000sqm in policy 1 is reduced accordingly. For the sake of consistency, the references to 35,000sqm in the vision, paragraph 4.2.7 and in the monitoring framework should also be updated. Similarly, the council would suggest that the references to Sites A and B are deleted from Policy 2. Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly Inspector’s question: 2. Figure 5 shows an indicative change to the town centre boundary. How is this to be defined in future? What are the implications for either including or excluding land from the town centre? Council’s response: This response supplements the council’s response to representation no. 825 (representor 248) and paragraphs 4.6-4.9 of the Business and Retail background paper, April 2014 (CDLR14). For the reasons set out in paragraphs 4.6-4.9 of CDLR14 the council considers that its approach with regard to the town centre boundary is compliant with the NPPF in that it will allow need for town centre uses to be met in full. The glossary definition of town centres in the NPPF defines town centres as areas including the primary shopping area and predominantly occupied by main town centre uses. While the revisions to the AAP seek to maximise the amount of non-residential use on site allocation CWAAP 24, there is still uncertainty about the quantum that will be delivered and the extent to which non-residential uses will predominate. In the light of this, the AAP seeks to provide flexibility, putting in place criteria in CWAAP 24 that will enable an assessment of the appropriate amount of nonresidential use to be provided and the appropriate distribution of those land uses. The council considers that an approach which is flexible and which allows for detailed and evidence based consideration of these issues at planning application stage will be more effective than pre-determining either the appropriate quantum or distribution of nonresidential use at this stage. In the council’s view, this flexibility is consistent with NPPF paragraph 157 which states that local plans should plan positively for development and allocate sites to promote development and flexible use of land providing details on scale etc where appropriate. Planning permission has been granted for mixed use schemes on Mulberry Business Park and on Site E (refer to appendix 2 of CDLR13). The leaseholder of the Harmsworth Quays site has commenced pre-application consultation on a redevelopment of the site and expects to submit a planning application in 2015. While the appropriate distribution of nonresidential uses will be assessed through the planning application, there will be an opportunity to designate a town centre boundary through the preparation of the New Southwark Plan, preferred options for which will be published in autumn 2015, and which can be informed by the planning application. With regard to implications of either including or excluding land from the town centre, the council’s view would be that if land is included in the town centre, then non-residential uses would be expected to predominate, which would remove the flexibility which the council has sought to embed in the plan through the criteria in CWAAP24. In addition, as is noted in paragraph 4.9 of CDLR14 other implications include: • • • In accordance with the NPPF, the revisions to the AAP seek to focus town centre uses in those areas which are most accessible and which provide opportunities for linked trips. If a greater amount of land were to be included in the town centre, a wider and more dispersed distribution of town centre uses could hinder that policy objective. In showing an indicative expansion of the town centre in Figure 5, the council is recognising the dynamism of the town centre, signalling its capacity to expand and putting in place a framework to plan for this. In the council’s view, maintaining the existing town centre boundary and excluding most the land to the east of Surrey Quays Road would not recognise the capacity for change. The AAP vision is seeking to create a town centre and neighbourhood with a strong sense of place. Creating an identifiable town centre in which town centre uses predominate will be reinforced by creating a hierarchy of streets and spaces which Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly • reflects the importance of the town centre as a destination. An alternative approach which allowed a wider distribution of uses over a larger area could undermine this objective. This is also linked to the AAP tall buildings strategy (policy 17). As is set out in paragraph 4.5.12b of the Revised Canada Water AAP, part of the rational for promoting tall buildings is that such buildings can accommodate uses which animate and contribute to the vibrancy of the centre. Accordingly, policy 17 states that tall buildings will be appropriate in important locations in the town centre, where they reinforce the character and function of this centre. In the council’s view, there is a danger that an alternative approach which sought to pre-determine the town centre boundaries, would undermine the council’s objective and strategy for creating a town centre with a distinguishable identity and strong sense of place. Inspector’s question: 3. Is the intention to extend the cycle hire scheme a matter that ‘belongs’ in a policy bearing in mind the principle set out above in the third paragraph? Council’s response: Paragraph 154 of the NPPF is noted. In this case the council considered it useful and appropriate to include the reference to the cycle hire scheme in the policy to raise its profile and help ensure that it remains a consideration by developers. The matter was a consideration in the determination of the recently consented scheme (application 12-AP-4126) on the Decathlon site (part of CWAAP7) and Site E (part of CWAAP 24) and provision was made in the s106 planning obligation for the safeguarding of land for a cycle hire docking station. Notwithstanding that, if you consider that it is not appropriate to include within the policy, it could be moved into the justificatory text e.g. at paragraph 4.3.5 (see text in red): TfL has proposed that Cycle Superhighway number 4 (Woolwich to London Bridge) is created along Evelyn Street, Lower Road and Jamaica Road. It is expected that this will be introduced by April 2015 in the 2013/14 financial year at the earliest. CSH4 will follow the Lower Road Gyratory until the scheme to remove the gyratory is delivered. The Lower Road scheme will be designed to incorporate the CSH principles. In addition, the council will work with the Mayor to extend the Cycle Hire Scheme to Canada Water. The council does not consider that this would represent a substantive change to the plan. Inspector’s question: 4. For consistency should Figure 8 remove reference to signalising the roundabout at the entrance to the Rotherhithe Tunnel? Council’s response: The council agrees. This has been proposed in the Table of proposed minor modifications to the publication/submission draft Revised Canada Water Area Action Plan (CDLR3) – see MOD13. Inspector’s question: 5. Should the minimum figure of new homes in Policy 21 be adjusted to more fully reflect the information in paragraph 4.6.4? Council’s response: The council maintained the figure of 2,500 homes as this is the target in the London Plan (2011) and is also referenced in the vision for the AAP. Moreover, the figure is expressed as a minimum and therefore, while the current estimated capacity of the core area is higher (4241 homes – refer to MOD18 in CDLR3), it is still compatible with target of providing at least 2,500 homes. It also maintains consistency with the affordable homes target in policy 22. The 875 homes cited in policy 22 represents 35% of 2,500. Notwithstanding that, if you considered it appropriate to relate the target in policy 21 to the up-to-date estimate of capacity, the council would not object to substituting the figure of Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly 2,500 for a figure of 4,200. Given that 4,200 is simply an aggregate of capacities of sites in the core area, the council does not consider that this would represent a substantive change to the plan and further consultation would not be required. For the sake of consistency, if this change were recommended, other parts of the plan would also need to be amended. The references to the figure of 2,500 homes in the vision and in the monitoring framework would need to be updated. Also, because of the relationship between the overall target and the affordable housing target, the latter should also be amended. Southwark would suggest using the figure of 900 units. Appendix 2 of the Housing background paper (CDLR13) shows the number of affordable units in the core area which have been granted permission as well as the number which would be expected on sites without permission, assuming that 35% was provided on these sites. Again, the vision and monitoring framework would need to be updated accordingly. To reiterate, given that these figures are simply an aggregate of capacities of sites in the core area, the council does not consider that these changes would represent a substantive change to the plan Plans Inspector’s question: Could I be provided with a larger version of the plan of the Proposals Sites referred to in the AAP on page 2? Council’s response: Using the site numbering listed on page 2, sites 1 (CWAAP1), 2, (CWAAP2), 3 (CWAAP3), 4 (CWAAP4), 10 (CWAAP10), 11 (CWAAP11), 14 (CWAAP4), 15 (CWAAP15), 16 (CWAAP16), 18 (CWAAP18), 10 (CWAAP19), 20 (CWAAP20), 21 (CWAAP21), 22 (CWAAP22) and 23 (CWAAP23) are all shown on the adopted policies map, 2012 (CDS6) which was submitted to the Planning Inspectorate. The site allocations which are affected by the revisions to the Canada Water AAP are shown in the document Revised Canada Water AAP Proposed changes to the adopted policies map (CDLR5). These show site boundaries on A4 sized paper for sites 7 (CWAAP7), 24 (CWAAP24) and 25 (CWAAP25). Procedural Matters Inspector’s question: 1. The Local Development Scheme (CDS10) should be updated to reflect the submission of the AAP in May 2014 rather than Jan 2014 as shown. Council’s response: The council is in the process of updating the LDS. The council anticipates publishing a revised LDS in August 2014. Once published, the new LDS will be made available for the examination. Inspector’s question: 2. What are the strategic matters, as defined in section 33 (4) of the Planning and Compulsory Purchase Act 20004, within the AAP that would have a significant impact on at least two planning areas? Council’s response: This answer supplements the information set out in the Duty to Cooperate Statement (CDLR10). Paragraph 2.2 of CDLR10 explains that the Localism Act 2011 introduced new legislation that requires the duty to cooperate in relation to the planning of sustainable development. A new section, 33A, was added to the Planning and Compulsory Purchase Act 2004 which requires ongoing co-operation between local authorities and a range of Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly prescribed bodies. Section 33A (3) requires such cooperation to take place in the preparation of development plan documents in so far as these documents relate to strategic matters. Section 33A (4) defines strategic development as sustainable development or a use of land that would have a significant impact on at least two planning areas. Paragraph 2.5 of CDLR10 explains that the NPPF provides guidance on how local authorities should interpret the Localism Act. NPPF Paragraph 178 states: “Public bodies have a duty to cooperate on planning issues that cross administrative boundaries, particularly those which relate to the strategic priorities set out in paragraph 156”. CDLR10 paragraph 2.7 summarises the strategic priorities referred to in NPPF paragraph 156. It is important to note that the revisions to the Canada Water AAP have been prepared in the context of Southwark’s development plan, which includes the London Plan 2011, the Core Strategy 2011 and the adopted Canada Water AAP. It is the council’s view that the revisions to the AAP do not raise strategic issues which have not previously been addressed through these documents. The London Plan identifies Canada Water as an area for intensification with capacity to accommodate at least 2,500 new homes. The Core Strategy establishes a vision for Canada Water, which includes targets for growth in homes and jobs and also the infrastructure that is required to support this growth, which includes a new secondary school, health facilities, energy infrastructure, improvements to Lower Road and Jamaica Road roundabout, the East London line extension and public realm improvements (see Table 2, Section 6, pages 171-175 of the Core Strategy). The adopted Canada Water area action plan provides more detailed policies to guide and manage growth, within the parameters established in the London Plan and Core Strategy. While neither the Core Strategy not the adopted Canada Water AAP were subject to the Duty to Cooperate, the council consulted extensively with neighbouring boroughs and prescribed bodies during the preparation of these documents. The consultation that took place is described in section 3 of CDLR10. The need to revise the area action plan has been generated by the fact that the Harmsworth Quays printworks has become available for development and the need to put in place planning policies to guide a redevelopment of that site. The revisions to the plan relate mainly to: • • • • • Site guidance for the adjacent sites (Mulberry Business Park, Site E and the Surrey Quays Leisure Park). The number of homes and quantum and distribution of non-residential uses. Urban design and tall buildings. Cycle and pedestrian links through Harmsworth Quays and the adjacent sites. Infrastructure impacted by additional homes. The review of the AAP has taken place within the context of the vision and objectives for Canada Water which are established in the adopted AAP and Core Strategy and which remain largely unchanged. The revisions to the AAP put in place site specific policies which seek to manage the impacts of growth locally and which are consistent with the AAP vision and objectives and higher level policy. While the revisions to the AAP will result in provision of a higher number of homes than was anticipated in the adopted AAP, this would not be of a scale that would have a significant impact on neighbouring local authorities or other prescribed bodies. Notwithstanding this, the council has consulted extensively with all neighbouring authorities and prescribed bodies in revising the AAP. This consultation is described in CDLR10 and included consultation with the GLA, the GLA/HCA, TfL, the EA, English Heritage, NE, NHS Southwark, the Highways Agency, the local nature partnership and the LEP (paragraphs 3.10-3.31 of CDLR10). There was also consultation with neighbouring boroughs which is described in paragraphs 3.33-3.54 of CDLR10. No strategic issues in relation to the revised Canada Water Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly AAP have been received from any local authority or other prescribed body and no objections on soundness grounds from any of these bodies have been received. Yours sincerely Juliet Seymour, Planning Policy Manager Enc. Updated list of planning permissions in the Canada Water action area Extract from inspector’s list of matters for the FALP EIP Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly Updated list of planning permissions in the Canada Water action area Class A1/A2/A3: 958sqm Community use (Class D1): 268sqm 20092015 Core Area - Site B (CWAAP6) * X 243 243 Class A1: 1,158sqm Class B1: 248sqm Library (Class D1): 2,197sqm 20062011 1030 1030 Class A1: 12,300.9sqm Class A1/A2/A3/A4: 4,352.3sqm Class B1: 2,800sqm Health centre (Class D1): 658sqm Cinema (Class D2): 698.2sqm 20152025 231 799 Included in Site C figures 20152025 0 0 Core Area - Site C (Decathalon) (CWAAP7) Core Area - Site E (CWAAP8)* 47 Private Intermediate Total units Student bedrooms Social rented 123 Status 668 Affordable Phasing 668 Dwellings Core Area - Site A (CWAAP5)* Site name Non residential use with planning permission on allocated sites This table updates the information set out in appendix 2 of the Canada Water Housing background paper, April 2014 (CDLR13). The figures in red show the figures that have been amended since CDLR13 was published. 170 498 Completed 2013 Completed 2010 Site has permission 0 0 0 Core Area -Surrey Quays Leisure Park (CWAAP7)* 509 123 632 Leisure uses (Class D2): 11,105sqm Class A1-A3: 2,695sqm Class B1: 2,500sqm 20152025 64 63 127 382 Site has permission Core Area - Shopping Centre & Overspill carpark (CWAAP7) 600 600 Class A1-A5: 10,564sqm 20152025 147 63 210 390 Retail proposal has permission; No permission for residential units Core Area - Mulberry Business Park (CWAAP9)* 33 803 Class A1-A3: 685sqm Health centre (Class D1): 322sqm Class B1: 4,490sqm 20152020 33 0 Site has permission Core area - 23 Rotherhithe Old Rd (CWAAP15) 14 14 0 Site has permission 770 14 Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly 20152020 14 0 See Site C Core area - 41 -55 Rotherhithe Old Road (CWAAP16) 16 16 20152020 4 26 Rotherhithe New Road 1 1 Core area - 247-251 Lower Road (CWAAP18) 15 15 20092015 20152020 Core area - 77 Albion Street 3 3 20152020 Core area - The Norwegian Church Seamen's Mission 1 1 20092015 Core area -158 Lower Road 1 1 20092015 0 Core area -162-164 Lower Road 2 2 20152020 0 Core area - 160 Lower Road 1 1 Core area - 186 Lower Road 1 Core area - 30 Rotherhithe New Road Core area - The Lodge, 122 Lower Road 2 6 10 Site has permission 0 1 Completed 4 2 6 9 No permission 0 0 0 3 Site has permission 0 1 Under construction 0 0 1 Completed 0 0 2 Site has permission 20152020 0 1 Site has permission 1 20152020 0 1 Site has permission 1 1 20092015 0 1 Completed 8 8 20152020 0 8 Site has permission 366 366 Core area - 24-28 Quebec Way (CWAAP10) 50 Core area - Land at Roberts Close (RCWAAP25) Core area - Quebec Industrial Estate (CWAAP11) Class A1/A3: 535sqm Nursery (Class D1): 469sqm Community use (Class D2): 122sqm 0 0 20152020 90 38 89 277 50 20152020 12 5 18 33 No permission 28 28 20152020 10 18 No permission Wider area - Surrey Docks Stadium (CWAAP2) 103 103 Resolution to grant permission Wide area - St Paul's Sports Ground (CWAAP1) 0 0 New park on adjacent land Refurbishment of sports ground Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly 20152020 22 12 34 69 0 0 0 0 Site has permission and is under construction Site has permission Wider area - Odessa Street Youth Club (CWAAP22) 25 25 20152020 6 Wider area - Docklands Settlement (CWAAP21) 28 28 Wider area - Tavern Quay (CWAAP19) 112 112 Wider area - St George's Wharf (CWAAP23) 60 60 Wider area - Downtown (CWAAP3) 212 212 Wider area -Prince of Wales, 19 Plough Way 1 1 20152020 Wider area-193 Plough Way 2 2 20152020 0 Wider area- Carinthia Court, 93 Plough Way 4 4 20092015 Wider area - 210 Rotherhithe Street 1 1 Wider area- The Ship York, 375 Rotherhithe Street 6 Wider area - 49 Brunel Road 3 9 16 No permission 9 19 Under construction Multi -purpose sports halll; gym; club room; general purpose hall; changing facilities (Class D2) 20092015 Class B1: 1,311sqm 20152020 28 12 40 72 Site has permission 20152020 15 6 21 39 No permission 20152020 38 13 51 161 0 1 Site has permission 0 0 2 Site has permission 0 0 0 4 Under construction 20092015 0 0 0 1 Under Construction 6 20152020 0 0 0 6 Site has permission 1 1 20092015 0 0 0 1 Under construction Wider area - 39-47 Brunel Road 4 4 20152020 0 0 0 4 Site has permission Wider area - 4 Onega Gate 3 3 20152020 0 3 Site has permission Wider area - 42 Ann Moss Way 1 1 20092015 0 1 Completed Wider area - 210 Rotherhithe Street 1 1 20092015 0 1 Under construction Wider area - Pacific Wharf, 165 Rotherhithe Street 6 6 20152020 0 6 Site has permission Wider area - 357 Rope Street 1 1 20152020 0 1 Site has permission Health centre (Class D1): 1,535sqm Community centre (Class D2): 124sqm Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly Under construction Wider area -119 Rotherhithe Street 6 6 20152020 0 6 Site has permission Wider area - 48-50 Trident Street 1 1 20152020 0 1 Site has permission Wider area - Lawrence Wharf 1 1 20152020 0 1 Site has permission 17 17 20092015 3 14 Under construction Wider area - Southwark Park Club, 386 Southwark Park Road 0 3 Total units 3944 893 4837 1080 2864 Total units in the core area 3348 893 4241 914 2435 Total units in the wider area 596 0 596 167 429 Total units with planning permission 3063 893 3956 773 2290 Total units in core area with planning permission 2655 893 3548 670 1985 Total units in wider area with planning permission 408 0 408 103 305 2676 893 3569 744 1933 Total units in the core area measured against FALP target (2015-2031) * Site numbering refers to adopted CW AAP x Not included in totals as completion pre-dates 2011 London Plan target Planning Policy – Deputy Chief Executive, PO Box 64529, London SE1P 5LX Switchboard: 020 7525 5000 Website: www.southwark.gov.uk Chief executive: Eleanor Kelly
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