Core Strategy Examination Statement Obsidian

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    Examination in Public 29th

    September 2011Strategic Site S24 Woodgrange Road WestNewham Core Strategy (March 2011)On behalf of Obsidian FG Ltd

    7995: EiP 23 Sept 111

    Statement of SoundnessStrategic Site S24

    Woodgrange Road West Forest Gate

    1.0 Statement of Soundness

    i) Context

    1.1 This statement relates to land and property controlled by Obsidian FG Limited,coinciding predominantly with the land identified at Woodgrange Road West StrategicSite S24 in the emerging Core Strategy.

    1.2 Obsidian FG Limited first acquired land in Forest Gate in 2007 and has maintained aclose dialogue with all key stakeholders over the last 5 years. More particularly, sinceDecember 2010, Obsidian FG Limited (OFG) has held detailed discussion with theLondon Borough of Newham (LBN) via the mechanism of a Project PlanningPerformance Agreement, to prepare a hybrid planning application for the regenerationof Forest Gate Town Centre. We have held approximately 30 meetings with Newhamsplanning and regeneration teams, 4 meetings with officers of the GLA (including 1meeting with The Mayor and 2 with the Deputy Mayor), we have received agreement inprinciple to our proposals from presentations to Newhams Development ControlForum, we have presented our master plan and now detailed designs to four DesignReview Panels, and we have undertaken two public consultation events in 2011, thelatter in September being attended by around 400 people. In short, we believe that wehave a scheme that is strongly justified:

    Through evidence of participation of the local community and others with astake in Forest Gate; and,

    Extensive research, fact finding and detailed analysis on Forest Gate that goeswell beyond (and is more site specific than) what has been undertaken byNewham for the Core Strategy.

    1.3 A planning application is targeted for submission in October 2011. Obsidian has alsoagreed legal documentation for a partnering approach with LBN as both arelandowners. LBN are prepared to use compulsory purchase powers, if required, toachieve the comprehensive regeneration of Forest Gate.

    1.4 Comprehensive regeneration of Forest Gate has been a key priority for LBN since atleast the publication of the Area Action Plan in 1998 but not much has changed. TheCouncil has adopted supplementary planning guidance for Forest Gate (January 2010),which updated previous guidance and was in line with the adopted Newham UDP.

    1.5 The evidence base highlights that Forest Gate and the London Borough of Newham areone of the most deprived areas of the country. The English Indices of Deprivation 2010

    ranks Newham as the second most deprived local authority district in England.Furthermore, the Ward of Forest Gate South falls entirely within the 20% most deprivedLower Layer Super Output Areas (LSOAs) in England, with large parts of it within the10% most deprived category. Crime in Forest Gate is 40% higher than the Londonaverage and 20% more than the Newham average.

    1.6 The Borough has historically served as a point of arrival for in-migrants from Londonsnew communities. It suffers from a high churn, with over 20% of its households havingmoved within the last 12 months, and the highest net outward migration rate in London.Over the last decade there has been a significant shift in the balance of housing stock,

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    Examination in Public 29th

    September 2011Strategic Site S24 Woodgrange Road WestNewham Core Strategy (March 2011)On behalf of Obsidian FG Ltd

    7995: EiP 23 Sept 112

    with a large number of family dwellings converted to small self contained flats, leavingonly around 40% of the Boroughs housing stock as family sized homes. This hasinfluenced the level of churn, together with the fact that there are currently insufficientopportunities to encourage those with improving incomes that their aspirations for betterhomes, schools and local amenities, and safer more attractive and connectedneighbourhoods, can be met by staying, spending and investing in Newham.

    1.7 A transformation in the nature of the local environment, including town and local centreshas therefore been identified and is required for communities to become more stableand to thrive (paragraph 3.14, Core Strategy Proposed Submission Draft 2011).

    1.8 The below-average economic and labour market performance of the LBN is the causeof much of the concentration of deprivation experienced there; combined with the lackof quality housing to encourage wealth-generating individuals to live and work in theBorough. Deprivation in turn reinforces poor economic and labour market performanceand so creates a situation that requires a concerted policy intervention in order toachieve improvements. A transformational approach is therefore justified and requiredas this is the only way to make progress towards convergence: ie by encouragingstronger, faster growth in Forest Gate than other, average wards across London. TheComparison Table attached at Appendix DWD 1, by London Borough and Ward

    demonstrates this.

    1.9 The London Plan (2011) also identifies Forest Gate as a centre in need of regenerationwith medium growth potential. Furthermore the London Plan specifically targets areaswithin the top 20% most deprived LSOAs such as Forest Gate for regeneration.

    1.10 In short, there is a very strong and urgent case for regeneration. Obsidian is the onlydeveloper committed to Forest Gate (there are no others registered to speak on ForestGate at the EIP) and is on the verge of submitting a planning application. It would bewrong to see this well-considered application delayed or even refused owing to a policyobjection based on inconsistency with the Core Strategy. In particular, we areconcerned that the policy approach to Site 24 is too prescriptive and lacks flexibility;precluding reasonable, well-researched and deliverable alternatives.

    ii) Crossrail

    1.11 Forest Gate is one of only three inner London District Town Centres designated by theLondon Plan 2011 with a Crossrail Station. The other two being Paddington inWestminster and Whitechapel in Tower Hamlets. The London Plan states that Crossrailis crucial to the realisation of regeneration and intensification opportunities around keyinterchanges within the Central Activities Zone and to its east and west.

    1.12 Crossrail provides a unique transport opportunity where land use must be optimised toincrease the profile and greatly improve the image of Forest Gate. The Socio-EconomicTechnical Report for the Crossrail Environmental Statement produced by ColinBuchanan (2005) anticipates that 50% of jobs accommodated and new homescompleted in Forest Gate up to 2021 will be attributable to Crossrail; that is 1,000 jobsand 800 residential units. Obsidians site, immediately to the south of Forest Gate

    station, is the most obvious location to accommodate this regeneration stimulus.

    1.13 Crossrail is scheduled to start running services from Forest Gate by 2018.

    iii) The Forest Gate Masterplan

    1.14 It is fully recognised that the Core Strategy is not the appropriate forum to consider sitespecific proposals for development of Strategic Sites. Also at this time there is nocomprehensive planning permission in place for the emerging Forest Gate scheme andthis section therefore does not infer that LBN has formally approved a scheme forForest Gate However, the detailed assessment of site S24 by the masterplan team for

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    September 2011Strategic Site S24 Woodgrange Road WestNewham Core Strategy (March 2011)On behalf of Obsidian FG Ltd

    7995: EiP 23 Sept 113

    Obsidian, in detailed consultation with LBN, does assist in considering the appropriatehousing typology for Forest Gate. A masterplan document is attached at AppendixDWD 2 to illustrate this and assist the Inspector.

    1.15 The rigour of the preparation of a part detailed and part outline planning application hasthe benefit of assessing the site specific circumstances, appropriate scale, height and

    massing for the delivery of the Forest Gate strategic site objectives, as set out in thedraft Core Strategy. The proposed application also addresses viability, deliverabilityand ongoing retail and public realm management issues.

    1.16 All of the area of land identified as Strategic Site S24 Woodgrange Road West, even atits extremities, is less than 200 metres from Forest Gate and the Crossrail Station. Theagreed PTAL rating assessed with LBN is PTAL5. It is an area of land that musttherefore optimise development opportunities in line with The London Plan policies, theinvestment in Crossrail infrastructure and the transformational change required toaddress the deprivation issues pertinent to Forest Gate as evidenced.

    1.17 In assessing the site characteristics to determine the appropriate housing typologiesObsidian consider that the broad principles apply to the masterplan area (and which willbe finally determined in detail by appropriate design considerations) are as follows:

    Area 1 Fronting Woodgrange Road Living Above the Shop predominantly oneand two bed units in recognition of town centre conditions/location. High to mediumdensity less than 100 metres from Station.

    Area 2 - Land north of Earlham Grove adjacent to Station and Crossrail predominantly one and two bed units. High density adjacent to Station.

    Area 3 Family Housing A large number of family housing units with privategardens and access to public open space. High to medium density 100 to 200metres from Station.

    1.18 The overall density is in line with The Mayors Plan Policy 3.4 and the density matrixguidance provided in Table 3.2, which identifies that for Urban sites with a PTAL of 4 to6 that a guide to the appropriate density is 200-700 hr/ha. The masterplan densityequates to approximately 765 hr/ha. The number of units proposed are approximately

    800 units. The appropriateness of the masterplan will be subject to detailed designconsiderations to be subsequently assessed by LBN.

    1.19 A selection of other masterplan drawings attached for information at Appendix DWD 3include the proposed storey heights, ground and first floor plans and a typical floorlayout plan. A phasing plan is also enclosed and it is intended that Blocks G, D & H willbe the first phase of development, followed by phase 2 comprising Blocks E, F & M andfinally phase 3 comprising Blocks A, B, C, L & T to coincide with the arrival of Crossrailservices broadly as follows:

    Phase 1 2012 2014

    Phase 2 2014 2017

    Phase 3 2017 2020

    iv) Soundness

    1.20 The Inspector is familiar with the requirements for soundness set out in PPS12, whichwill therefore not be repeated. Obsidians considers that that S24 is not sound as it isnot justified or effective.

    1.21 Justified - In addressing whether Strategic Site S24 is justified, it is considered byObsidian that the evidence and circumstances pertinent to S24 are not justified inrespect of the housing typologies identified for the site and reference to limitedintensification for the reasons set out below including:

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    Examination in Public 29th

    September 2011Strategic Site S24 Woodgrange Road WestNewham Core Strategy (March 2011)On behalf of Obsidian FG Ltd

    7995: EiP 23 Sept 114

    - the high PTAL rating of 5 and Crossrail investment (see paragraphs 1.11-1.13 and1.16 above);

    - the sustainability of the site due to its location, accessibility and brownfield status(see Appendix DWD 2)

    - the appropriately defined typologies which have been considered in detail by themaster planning team as per paragraph 1.17 above;

    - the evidence of the urgent need for transformational change to address the highlevels of deprivation, unemployment and high levels of churn establishedhistorically by the population base of Newham and Forest Gate particularly (seeAppendix DWD 1 and paragraphs 1.2-1.10 above); and

    - the need for other town centres in Newham to regenerate to cater for the localcatchment of their neighbourhoods (see the Councils evidence base Town Centresand Retail Study (prepared by GVA March 2010)).

    1.22 Effective - Strategic Site S24 is not considered to be effective as the housing typologydoes not reflect the site circumstances and constraints and it therefore raises doubtsabout the deliverability of the housing proposed for Forest Gate. The appropriatehousing typologies, have been thoroughly tested by Obsidian in accordance with thesite circumstances and sustainability considerations and are set out in paragraph 1.14above.

    v) Proposed Amendments to Satisfy Soundness

    1.23 The question of soundness to satisfy Obsidians representations could be readilyaddressed with minor modifications to the housing typology reference and wording toStrategic Site S24. This would address the evidence now available for the site, provideflexibility to respond to the site specific circumstances and ensure that the housingpotential of the site is optimised in line with its superior sustainable location. Theamendments sought are as follows (the text in italics is the proposed insertionand textstruck though shows the proposed deletion):

    Mixed use comprising retail, residential (high density/low family and mediumdensity/medium family), community and business; limited intensification totake advantage of opportunities afforded by Crossrail. ..

    1.24 Without these changes the delivery of Spatial Policy S6 will be in doubt in terms of thecontribution that Forest Gate makes to the delivery of 3,000 additional dwellings inUrban Newham and the ability to harness the opportunities afforded by the investmentin Crossrail and its arrival in Forest Gate. The spatial objectives to address the highlevels of deprivation, unemployment, crime and weak town centre performance couldbe lost if Strategic Site S24 fails to embrace the need for transformational change andintensification at appropriate densities in Forest Gate. The Councils objectives are tosee regeneration in Urban Newham given the same priority as within the Arc ofOpportunity, which Policy S6 states as a strategic objective.

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    APPENDIX DWD 1

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    London, Borough and Ward Comparison Table

    IMD 2010 Rank of AverageRank of English Local

    Authorities (Where 1 is mostdeprived and 326 is least

    deprived)*Index of MultipleDeprivation 2010*

    Unemployment(2001)***

    Skills (NVQ2 andabove)**

    Gross weeklypay**

    Crime(Offences per

    1000population

    July 2011)***

    London N/A N/A6.4%

    (Feb 01-Apr 01) 67.30% 606.80 112.6

    Newham 2 N/A 13.5% 50.70% 506.80 134.7

    Forest GateSouth N/A 0 - 20% 14.8% N/A N/A 158.9

    Wandsworth 102 N/A 5.9% 78.30% 689.30 89.2

    Balham N/A 31% to 90% 4.8% N/A N/A 103.3

    Ealing 61 N/A 6.5% 65.10% 567.70 110.7Ealing

    Broadway N/A 31% to 80% 4.7% N/A N/A 178.3

    Source:* Department for Communities and Local Government, Indices of Deprivation 2010** Office for National Statistics, http://www.nomisweb.co.uk/*** Metropolitan Police Statistics, http://www.met.police.uk/crimefigures/

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    APPENDIX DWD 2

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    Town Centre Regeneration

    A R C H I T E C T S

    I

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    HELLO

    AND

    WELCOME...

    This is the second public consultation Obsidian

    have held this year on the emerging Forest Gate

    Masterplan.

    as part of the Forest Gate Festival. This proved to

    informative. Public attendance today is based

    and businesses. We also published notices in

    Recorder.

    be especially useful if you could please completeand return our feedback form.

    any of the Obsidian team members present today.

    Town Centre Regeneration

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    W O OD GR A N G E R OA D

    SP ROW STON ROAD

    ROMF

    ORD

    RO

    AD

    EA

    RLH

    AM

    G

    R

    O

    V

    E

    CLOVA

    ROAD

    OS

    B

    OR

    NE

    R

    OA

    D

    H

    A

    MP

    TON

    R

    O

    A

    D

    METHODIST

    CHURCH

    FORESTGATE

    STATION

    SPROWS

    TON

    MEWS

    ORE SITE

    OTENTIAL ENHANCEMENT AREAS

    THE

    MASTERPLAN

    SITE

    N Obsidian is currently

    progressing a masterplan

    for the regeneration of

    Forest Gate Town Centre.

    The area includes parts

    of Woodgrange Road,

    Earlham Grove and

    Sprowston Road.T.E

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    THE STORYSO FAR...

    The regeneration of Forest Gate has been a key priority for

    Newham for many years. The latest guidance is set out in the

    Forest Gate Supplementary Planning Document adopted by

    the Council in January 2010 and the draft Core Strategy (March

    2011), with retail issues reviewed in the Town Centre and Retail

    Study (March 2010).

    (1998 to 2008). In fact, the evidence suggests that the area

    has continued to decline, remaining in the lowest 10% basedon a wide range of deprivation measures. This decline is set

    comprehensive development, can be secured.

    development of the backlands between Woodgrange Road

    and Sprowston Road. We have listened to the council and local

    stakeholders throughout.

    It is clear that only a comprehensive development will deliver

    the improvements to retailing and the public realm along

    Woodgrange Road, together with new, larger community facilities.The related housing development needs to be of a scale to

    We would like to start on site in 2012. The development will be

    the regeneration package delivered within the next 2/3 years .

    Town Centre Regeneration

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    WHY IS

    REGENERATION

    NEEDED?

    since at least 1998, but not much has changed.

    Newham is the second most deprived Borough in England.

    The English Indices of Deprivation 2010 ranks the Ward ofForest Gate South as within the 20% most deprived with largeparts categorised as within the 10% most deprived in England.

    Too much of the existing residential accommodation comprises

    Hot food takeaways, betting shops and a limited retail offercurrently dominate Woodgrange Road.

    much of the area.

    Crime offences per 1000 population in Forest Gate arecurrently 20% higher than in Newham and 40% higher than theLondon average.

    Most expenditure is lost to competing larger retail centresand, according to Newhams SPD, the town does not meet theneeds of local residents.

    Few signs of an established evening leisure economy.

    Centre represents an opportunity to address

    Town Centre Regeneration

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    ' '

    THE

    BENEFITS OF

    REGENERATION

    Revitalised town centre creating a relaxed, safe and secureenvironment.

    the best of the existing and adding cafs and restaurants toestablish night time leisure activity.

    New community and healthcare facilities, comprising

    and comprises a 25% increase on current communityprovision.

    Affordable workspace and contributions to local traininginitiatives to stimulate local opportunities for local people.

    Public realm works substantially enhancing Woodgrange Roadand the Conservation Area.

    Car club, CPZ and Travel Plan to help manage the c220 cars

    parked on site.

    management of the development.

    Financial contributions to local education in accordance withNewhams planning policies.

    ....Delivering change

    Town Centre Regeneration

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    WHAT

    YOU HAVE

    TOLD US SO

    FAR...

    Some of Forest Gates residents and businesses will have seenObsidians initial proposals presented at the Forest Gate Festival

    All respondents were keen to see the centre of Forest Gateregenerated

    There is a great community here in Forest Gate and it

    and restaurants

    More independent shops are wanted rather than high street

    Need for community facilities as a focal point to the towncentre including a community centre, large green space orperforming arts venue and space for physical activities.

    Forest Gates heritage and the Victorian character areimportant to residents

    High rise apartments are of concern as these are associated

    behaviour

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    MORE,

    QUALITY

    HOUSING

    Town Centre Regeneration

    Housing | The conceptual character...

    1

    32

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    APPENDIX DWD 3

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    Town Centre Regeneration

    N

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