Draft Local Plan Representations 126 to 146...Draft Local Plan Representations 126 to 146 Note: You can jump to specific representations by clicking on their respective labels in the

Draft Local Plan Representations 126 to 146 Note: You can jump to specific representations by clicking on their respective labels in the expanding column to the left hand side of the frame

DLP Representation

N.

Full Name of Respondent Organisation/Title/Representing Plan Item Reference (Chapter Section/Policy/Site N. etc.) Page

N.

DLP126_1 Daniel Miller Shortlands Residents Association Draft Policy 56 - Local Green Space

DLP127_1 to DLP127_3

John Tiley Education Site 33 - St Hugh’s Playing Field Draft Policy 29 - Education Site Allocations Draft Policy 56 - Local Green Space

DLP128_1 Davina Misroch Housing mixed use allocation Site 10 - West of Bromley

High Street and land at Bromley South

DLP129_1 Maria Martinez Education allocation Site 36 Land at Bushell Way,

Chislehurst DLP130_1 Andrew Pope Education allocation - Site 36


Gillian Bailey Draft Policy 27 - Education Education allocation Site 33 – St.Hugh’s Playing Fields Draft Policy 28 – Educational facilities Draft Policy 55 – Urban Open Space

DLP132_1 Andrew Howcroft Housing mixed use Site 2 – Land adjacent to Bromley North DLP133_1 Philippa Loades Draft Policy 29 – Education Site Allocations


Chris Francis West and Partners for Dylon 2 Ltd Section 1.2 – About the Local Plan Section 1.3 – Visions and Objectives DLP134_3 Section 1.4 – Spatial Strategy Draft Policy 1 – Housing Supply Draft Policy 13 – Renewal Areas Draft Policy 30 – Parking Draft Policy 50 – Metropolitan Open Land Draft Policy 35 – Transport Investment Priorities


Chris Francis West and Partners for Relta Ltd Section 1.2 – About the Local Plan Section 1.3 – Visions and Objectives DLP135_3 Section 1.4 – Spatial Strategy Draft Policy 1 – Housing Supply Draft Policy 13 – Renewal Areas Draft Policy 30 – Parking Draft Policy 35 – Transport Investment Priorities Draft Policy 50 – Metropolitan Open Land

1

3

7

9

10

11

12

1415

16

34

Draft Local Plan Representations 126 to 146

DLP136_1 Matt Walker Housing mixed use allocation Site 2 – Land adjacent to

Bromley North Station

DLP137_1 and DLP137_2

Anthony Johnson Bushell Way Residents Association

Housing Mixed-Use Site 13 – Banbury House, Chislehurst Education Allocation Site 36 – Land at Bushell Way, Chislehurst


Andy Black PRP for CALA Homes Draft Policy 1 – Housing Supply Draft Policy 2 – Affordable Housing Draft Policy 11 – Specialist and Older Peoples Accommodation

DLP139_1to DLP139_3

Susan Savage Education Allocation Site 33 – St. Hugh’s Playing Field Draft Policy 29 – Education Site Allocations Draft Policy 56 – Local Green Space

DLP140_1 Morag Hughes Housing Allocations Site 2 – Land adjacent to Bromley North

Station

DLP141_1 Joanne Smith Education Allocation Site 36 – Land at Bushell Way,

Chislehurst

DLP142_1 Andrew and Kate Brown Education Allocation Site 36


Bob Neill MP Draft Policy 1 – Housing Supply Draft Policy 29 – Education Site Allocations Draft Policy 56 – Local Green Space Draft Policy 49 – The Green Belt Section 4 – Getting Around (Transport and Accessibility) Section 5.3 – Nature Conservation and Development Draft Policy 24 – Allotments and Leisure Gardens

DLP144 Alan and Linda Howes Education Allocation Site 33 – St. Hugh’s Playing Field DLP145_1 to

DLP145_2 Joan and Graeme Shankland

Education Allocation Site 33 /Draft Policy 56 – Local Green Space

DLP146_1 David Sterling Housing Allocation Site 2 – Land adjacent to Bromley North

Station

2

52

53

57

63

65

67

69

70

72

74

76

Representation no.

DLP126_1

Part of document, Section, Policy or Site

Draft Policy 56 - Local Green Space

Format Email Full Name Daniel Miller Organisation Shortlands Residents Association

3

SHORTLANDS RESIDENTS’ ASSOCIATION Development Officer: Daniel Miller

16 Hildenlea Place, Bromley BR2 0YH 020 8460 3247 [email protected]

Ms Mary Manuel Head of Planning Strategy and Projects London Borough of Bromley Civic Centre Stockwell Close Bromley BR1 3UH 30 December 2016 By email and first class post Dear Ms Manuel Re: Shortlands Golf Course Designation as Local Green Space This is a letter of objection submitted on behalf of the committee and the members of the Shortlands Residents' Association. We have very recently been made aware of the decision of LBB not to designate Shortlands Golf Course as a Local Green Space (LGS). Our submission is that the Golf Course is vital, not only to its members, but to the local community as a whole and should be provided with the additional protection of LGS status. We therefore request that you revoke the decision not to recognise for designation. The original decision justified the refusal to recommend for designation on the basis that the site did not meet criteria 1, 4, 6 and 7 and it was unknown whether the site met criterion 8. Criterion 1: Support of the Local Community The grounds of rejection state that there was no further support from other more representative community groups in order to make a stronger case for designation. No evidence had been provided of support from local organisations or how members of those organisations would specifically enjoy the site's special qualities. The Local Plan Background Paper dealing with Local Green Space and dated September 2016 identifies the methodology for assessment against each criterion. We are a legally constituted local Residents' Association representing some 1000 households who are members of our Association. The committee is authorised by its members and its rules to make policy decisions on behalf of its members for the benefit of the community. Our committee has taken the decision that representation should be made by the Shortlands Residents' Association in support of the original proposal to have the Golf Course recognised as an LGS. All our members and, indeed, all residents of Shortlands and Bromley benefit from the retention of Shortlands Golf Course in its present form with a maximum protection possible against future development. Clearly, not all of our members will also be members of the Golf

4



Club but everybody in the community enjoys the benefit generated by having a green space virtually adjacent to Bromley Town Centre and the centre of Shortlands. This is not just a question of being able to walk through the Golf Course and to enjoy its trees, its shrubs, its woods and the wildlife in this special open space, but the healthy environment created for the community by having green space so close to a town centre. We know that Bromley is a polluted area. One wonders what the situation would be if we did not have the benefit of this green space? It would be a fair presumption that we would have a dangerously polluted area were it not for such green spaces as we now enjoy and protect. While we cannot deny that the members of the Golf Club would specifically enjoy the immediate benefits, in our view the space is of great benefit to the whole community in limiting the extent of development and adding to the healthiest environment which we might enjoy. To run any risk of damaging that environment is unacceptable so, in our view, this green space is vital to the whole community in order to avoid overdevelopment and damage to health. Criterion 4: the site proposed for designation is local in character and is not an extensive tract of land The Local Plan Background Paper referring to the site assessment against this criterion and the National Planning Policy Framework does not seek to define too rigidly how big a Local Green Space can be except to say that the blanket designation of open countryside adjacent to settlement will not be appropriate. ‘This should not be a new area of Green Belt by another name’. Paragraph 46 identifies some criteria for sites considered to meet criterion 4. These include that where facilities are not publicly accessible they are still considered to be local in character where they are, for example, demonstrably historically significant. This is most certainly the case for this Golf Course, believed to be established in the late 19th century as a women’s only golf course, something no doubt unique at that time. A further criterion is whether this provides a visible and important break in the urban form. The spread of the suburbs in the 1920s and 1930s were protected against excessive development because of the existence of this golf course. That remains the case today as development has surrounded this green space. As Bromley Town continues to develop and expand, perhaps upwards, then there needs to be a visible balance, as happens throughout London, between the developed and the protected for the benefit of all who live nearby. The fact that this is not an open park does not detract from its importance as a ‘lung’ for the community as a whole, local in character and a visible break between in the urban form. In the grounds of rejection there is reference to local residential properties. There are probably some 150 properties and therefore perhaps 300 people who immediately enjoy the benefits of views onto the golf course which we suggest they greatly appreciate, whether or not they are actually golfers. It would be a fundamental reason for living nearby, the fact that their gardens do overlook the course. Criterion 6: this space is demonstrably special to a local community and holds a particular local significance because of a special qualities relating to, for example, beauty, historic significance, recreational value, tranquillity or richness of wildlife.

5



The main ground of rejection is that no details have been provided how the case for beauty and quietness and the site’s function as a link are being enjoyed and how they are special. The Local Plan Background Paper refers to paragraph 77 of the National Planning Policy Framework. A number of categories such as beauty, historical significance, recreational value and tranquillity must be shown to be demonstrably special for the local community in at least one of these categories. The detail inevitably overlaps with other criteria. For example in dealing with beauty there must be a significant enhancement to the built environment. An open space alone would not be sufficient. There can be no doubt, as mentioned above in respect of criterion 4, that all immediate local residents living adjacent to the golf course would regard the tranquillity, trees and sculpted open space as being something of beauty in an otherwise urban or suburban environment. We have already mentioned above the historical importance of this golf course. While it is accepted that this is not a recreational area for everybody in the community, the demise or proposed demise of the golf course in Beckenham Place Park suggests that a nearby golfing facility must grow in importance. For those who, like the writer, frequently walk around the area of the golf course can be no doubt that this is a place of particular tranquility. Criterion 7: the special characteristics would not be protected through any other reasonable or more effective means As is stated in paragraph 76 of the Local Plan Background Paper, most of the borough is covered by planning designations and most of the sites nominated for LGS designation are to various degrees already protected by planning designations. It is acknowledged that the grounds of rejection refer to the existing levels of protection but given the importance of the Golf Club land the maximum protection should be provided consistent with the approach to green belt. Criterion 8: managing the site beyond the local plan period As is already stated it is not possible to know what the future will hold because of the private ownership of the club. This is a very strong reason for arguing that the maximum protection and therefore LGS status should be applied now. Yours faithfully Daniel Miller

6

Representation no.

DLP127


DLP127_1 Education Site 33 - St Hugh’s Playing Field DLP127_2 Draft Policy 29 - Education Site Allocations DLP127_3 Draft Policy 56 - Local Green Space

Format Email Full Name John Tiley Organisation

7

We live in Woodlands Road, Bickley, our house abutting Pines Road and very close to the St Hugh’s Playing Fields. We note that Bromley Council are requesting comments on the Draft Local Plan currently being considered and we have the following comments:- DRAFT POLICY 29 – EDUCATION SITE ALLOCATIONS In our view the St Hugh’s Playing Fields are not suitable for a new school and should be removed from the list of sites allocated for new education provision. There is already a planning application under consideration, submitted in July 2016 and subsequently, for the building of the new Bullers Wood School for Boys on this site (Planning Ref: 16/03315/FULL1). We have already lodged objections to this proposal as the site is totally inappropriate for the siting of a new school. Our objections centred around traffic congestion, major road safety issues to say nothing of the parking problems this will create in the area. There is little open space left in Bickley and the loss of this will impact adversely on the amenity enjoyed locally. We know that Sport England have already objected to the loss of existing playing fields which the building of the school will inevitably cause. We would question whether enough has been done to both identify the need for a new school of this size in the Borough. If this is so then more work should be done reviewing other opportunities to site a school including those included in the Education Background Paper (Autumn 2016) to identify a better alternative particularly one which will cause less traffic chaos and public danger than the approval of this proposal inevitably will. DRAFT POLICY 56 – LOCAL GREEN SPACE Much of Bickley is fully developed and there is little open space. We believe that the St Hugh’s Playing Fields should be added to the list of sites to be designated as Local Green Space in the Local Plan. Please acknowledge safe receipt of this e-mail.

8

Representation no.

DLP128_1


Housing mixed use allocation Site 10 - West of Bromley High Street and land at Bromley South

Format Online Full Name Davina Misroch Organisation

Do you have any concerns about legal compliance? Do you have any concerns about soundness?

I do not think that this part of the Local Plan is 'sound' because: - it has an unacceptable impact on the town centre's local character, and - would be in conflict with the heritage, historical value and open spaces which are the town's most valuable assets. - the plan is unsound because it is in conflict with its own draft policies within the Local Plan and that within the National Planning Policy Framework - there is insufficient evidence to justify this proposal with respect to sufficient local open space and play areas, - sufficient provision for local schools, - clear and irreversible impact on the Conservation Area, and - completely unjustified loss of existing housing particularly that in Ethelbert Close.

Has the Council complied with the Duty to Cooperate? Do you wish to appear at Examination? For what reason?

Yes. As a resident and owner of a property in Ethelbert Close, I consider this to be extremely important to have an opportunity to voice concerns about what happens in the town centre and on Site 10 in particular. I also have great concern as to how the Local Plan will impact the environment in a whole sense, in the Conservation Area and in the wider area.

9

Representation no.

DLP129_1


Education allocation Site 36 Land at Bushell Way, Chislehurst

Format Online Full Name Maria Martinez Organisation

Do you have any concerns about legal compliance?

I have concerns of allocating this area for educational use as these grounds and woods are home to an array of wildlife and these should remain natural open space for the use and benefit of the community.

Do you have any concerns about soundness?



No.

10

Representation no.

DLP130_1


Education allocation - Site 36 Land at Bushell Way, Chislehurst

Format Online Full Name Andrew Pope Organisation


This drafted 'allocation' is not compliant with the provisions of NPPF Chapter 11. This entry - Site 36 - should be deleted from App 10.4. The drafting of Site 36 Land at Bushell Way Chislehurst is nor compliant with NPPF Chapter 11. It's drafted use for 'education purposes' is not justified or needed. This entry (Site 36) should be deleted from the draft Local Plan.


All of this ground should remain Local Green Space. It is (all) important natural urban green infrastructure and should remain so. The drafted allocation is contrary to the environmental provisions of NPPF Chapter 11. I do not consider that this significant piece of Walden Wood should be destroyed; it performs a valuable service to the public as it is. This ground - Site 36 - is important natural Local Green Space and should remain as that. I do not want to see this significant part of Walden Wood destroyed. This drafted entry (Site 36) is unsound. This ground is attractive natural green infrastructure and should remain in its present form. The ground fulfils an important public function as it is. Use for would-be education purposes is unjustified and un-needed.


No.

11

Representation no.

DLP131


DLP131_1 - Draft Policy 27 - Education DLP131_2 - Education allocation Site 33 – St.Hugh’s Playing Fields DLP131_3 – Draft Policy 28 – Educational facilities DLP131_4 – Draft Policy 55 – Urban Open Space

Format Online Full Name Gillian Bailey Organisation


St. Hugh’s playing fields

In addition to loss of Open Space, objections to this application in the Schedule of consultation responses include traffic, parking, road safety and loss of playing fields.

Although the proposed allocation was at that stage maintained it was recognised that more detailed examination was required, major implications remained to be assessed at planning application stage. If the issues could not be satisfactorily resolved then the inference was that the allocation would be abandoned.

A planning application for a large boy’s secondary school has been submitted in July 2016, many objections have been made and detailed examination of the proposal clearly shows that the site is not suitable for this purpose and the negative impact on the locality and its residents unacceptable. The need for the level of additional secondary school capacity is disputed.

Whatever the eventual outcome of the “need” issue this site is not suitable. Its unsuitability is not just its impact on the neighbourhood but it will be a “bad product”. A major issue is the size of the site: - there is a loss of playing fields but what is left will be used not only by the 900 boys at the new school but also by 1,500 Bullers Wood Girls and 6th form boys. The assessments seem to overlook the fact that the existing use will not cease. Traffic and road safety issues are as pertinent for the pupils and their parents as the local residents, a school should not be sited on what is effectively an island with major frontages to two busy roads (one of the busiest in Bromley).

When looking for school sites a in the Borough, green belt and MOL sites should be given proper consideration and not dismissed simply because of these designations. This is particularly so in a Borough that has as much open space on the fringe of the urban area as Bromley but strict adherence to these designations is forcing consideration of an inappropriate site in an area of open space deficiency within the urban area . It is necessary to “think outside the box”.

12

This site does not work for a secondary school neither for the pupils nor the local residents. Retention of the proposed secondary school allocation on this site is not justified nor is it consistent with national sustainable development policy. A plan with this allocation will not be sound.

Has the Council complied with the Duty to Cooperate?

Do you wish to appear at Examination? For what reason?

Yes. There are moving situations with many potential variables by end of 2017. I would like the opportunity to address the then current situation

13

Representation no.

DLP132_1


Housing mixed use Site 2 – Land adjacent to Bromley North

Format Online Full Name Andrew Howcroft Organisation


Regarding Bromley North site:

As a local resident who lives in Glebe Road I would like to voice my option on the plan to redevelop the site by Bromley North. Any new housing should fit into the feel and character of the local Victorian streets. However, one of my biggest concerns is that Bromley North must be almost unique in London in that it has the opportunity to expand an existing transport hub to support the local residences and business. To throw away this opportunity to expand the transport links to and from Bromley with a clumsy short sighted redevelopment would be criminal.

As with any new development into existing infrastructure consideration must be given that there are facilities to support the new residence. As a current resident my son got into his third choice school. I rarely get to park on our road (Glebe Road) and it is difficult to get an appointment with a Doctor or Dentist. All these facilities need to be upgraded to support an additional demands that will be put on them.

Please take great care and consideration when redeveloping the Bromley North site.


14

Representation no.

DLP133_1


Draft Policy 29 – Education Site Allocations

Format Online Full Name Philippa Loades Organisation


it is more appropriate to seek to increase school places by expanding existing school sites; it is not an appropriate strategy to seek to build new schools on unsuitable sites and locations for example Eden Park High School in Balmoral Avenue. It would seem reasonable to expect Bromley Borough schools to only have students from the borough rather than having places taken by those living in Croydon and Lewisham boroughs, which means Bromley has to find more places for its own residents!


No.

15

Representation no.

DLP134 (Dylon 2 aka Footzie Social Club)


DLP134_1 Section 1.2 – About the Local Plan DLP134_2 Section 1.3 – Visions and Objectives DLP134_3 Section 1.4 – Spatial Strategy DLP134_4 Draft Policy 1 – Housing Supply DLP134_5 Draft Policy 13 – Renewal Areas DLP134_6 Draft Policy 30 – Parking DLP134_7 Draft Policy 50 – Metropolitan Open Land DLP134_8 Draft Policy 35 – Transport Investment Priorities

Format Online Full Name Chris Francis Organisation West and Partners for Dylon 2 Ltd

16

Representation no.

DLP134_1


Section 1.2 About the Local Plan



The Council's definition of material considerations as "significant matters" – is incorrect in planning and legal terms.

Do you have any concerns about soundness? Has the Council complied with the Duty to Cooperate? Do you wish to appear at Examination? For what reason?

No.

17

Representation no.

DLP134_2


Section 1.3 Visions and Objectives



The Vision fails to seek to encourage and enable development which will bring about qualitative improvements and greater accessibility while delivering and meeting the needs for housing, employment and related infrastructure in line with the NPPF and the London Plan and therefore fails to address the requirements of paragraph 182 of the NPPF and accordingly is not sound.


No.

18

Representation no.

DLP134_3


Section 1.4 Spatial Strategy



1. The Draft Plan fails to correctly assess and address ObjectivelyAssessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of Nathaniel Lichfield & Partners (NLP) dated 28 Dec 2016) and is therefore not in conformity with the NPPF and accordingly fails this requirement.

2. The Draft Plan fails to identify the area of Lower Sydenham, as aRenewal Area. This is an area which, together with the neighbouring wards in the London Borough of Lewisham, from a socio-economic perspective performs less well against a range of economic, deprivation and housing indicators than LBB averages and as such should be a focus for renewal and improvement. The Draft Plan is not therefore in conformity with the requirements of Policy 2.6; 2.7 and 2.8 of the London and accordingly fails this requirement.


1. The Draft Plan fails to correctly assess and address ObjectivelyAssessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of NLP dated 28 Dec 2016) and is therefore not in conformity with the requirements of the NPPF and is not sound.

2. The Draft Plan fails to embrace a review of the boundaries andcondition of existing designated MOL in compliance with the provisions of Policy 7.17 D of the London Plan and thereby contributes to the failure to address the OAN and make correct and sound provision of a 5YHLS for the reasons set out in the NLP letter of 28 Dec 2016. Accordingly, the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound

3. The Draft Plan fails to identify the area of Lower Sydenham, as aRenewal Area. This is an area which, together with the neighbouring wards in the London Borough of Lewisham, from a socio-economic perspective performs less well against a range of economic, deprivation and housing indicators than LBB averages and as such should be a focus for renewal and improvement. Accordingly, the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound


There is no evidence to indicate that LBB has sought to co-operate with LB Lewisham to address the issues associated with the evident low socio-economic performance when assessed against a range of economic, deprivation and housing indicators of the Lower Sydenham area of LBB and the adjoining areas of LBL.

Do you wish to appear at

No.

19

Examination? For what reason?

20

Representation no.

DLP134_4


Policy 1 Housing Supply



1. The Draft Plan fails to correctly assess and address ObjectivelyAssessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of Nathaniel Lichfield & Partners (NLP) dated 28 Dec 2016) and is therefore not in conformity with the NPPF and accordingly fails this requirement. 2. Draft Policy 1 fails to include any provisions which seek to exceedthe current target set by the London Plan, as is required by Policy 3.3 D and Da the latter of which states "Boroughs should draw on the housing benchmarks in table 3.1 in developing their LDF housing targets, augmented where possible with extra housing capacity to close the gap between identified housing need (see Policy 3.8) and supply in line with the requirement of the NPPF" It is therefore not in conformity with this requirement of the London Plan and not legally compliant.


1. The Draft Plan fails to correctly assess and address ObjectivelyAssessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of NLP dated 28 Dec 2016) and is therefore not in conformity with the requirements of the NPPF and is not sound. 2. Draft Policy 1 fails to seeks to meet objectively assesseddevelopment and infrastructure requirements, as it lacks any provisions which seek to materially and significantly exceed the current housing supply target set by the London Plan, as is required by Policy 3.3 D and Da the latter of which states "Boroughs should draw on the housing benchmarks in table 3.1 in developing their LDF housing targets, augmented where possible with extra housing capacity to close the gap between identified housing need (see Policy 3.8) and supply in line with the requirement of the NPPF" It is therefore not sound. 3. The Draft Plan, generally and Draft Policy 1 fail to have proper andproportionate regard to the clear indications in the direction of travel of government of the need to take every opportunity to provide for the delivery of new housing to meet identified need. In particular, no provision for increasing density within the vicinity of commuter hubs and on previous developed land; including such land in the Green Belt and MOL; is provided for. The Draft Plan therefore fails to seeks to meet objectively assessed development and infrastructure requirements and is not sound. 4. The Draft Plan fails to identify, as an allocated residentialdevelopment site, the land forming part of the former Dylon International Premises site off Station Approach, site at Lower Sydenham. In August 2016 the principle of a scheme for the residential redevelopment of the brown field elements of this site was in effect endorsed by an Inspector appointed by the Secretary of

21

State. This justifies the inclusion of the site as an allocated housing site as it can and will make a meaningful contribution to the objectively assessed housing needs of the borough within the early years of the Plan period. The omission of the site means that the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound.


Yes. To review the concerns outlined in respect of need and supply in the letter of 28 Dec 2016 from NLP and in particular the following: 1 NPPF requirements for identifying objective assessed housing need (OAN) 2 London and London Borough of Bromley’s (LBB) OAN 3 Meeting LBB ONA 4 The failure to identify as an allocated residential development site, the land forming part of the former Dylon International Premises site off Station Approach, site at Lower Sydenham

22

Nathaniel Lichfield & Partners Limited 14 Regent’s Wharf All Saints Street London N1 9RL

Registered in England No. 2778116 Regulated by the RICS

Offices also in Bristol Cardiff Edinburgh Leeds Manchester Newcastle Thames Valley

Planning Strategy Team London Borough of Bromley Civic Centre Stockwell Close Bromley BR1 3UH

14 Regent's Wharf All Saints Street London N1 9RL

020 7837 4477 [email protected]

nlpplanning.com

Date 29 December 2016 Our ref 14473/03/SB/RM/RC/13000303v3 By email only ([email protected])

Dear Sir / Madam

Bromley Proposed Submission Draft Local Plan Consultation

Representation on Housing Need and Supply, on behalf of Relta Limited

We write on behalf of our client, Relta Limited (‘Relta’), in respect of the statutory consultation on Bromley’s Proposed Submission Draft Local Plan (BDLP).

NLP acts on behalf of Relta Limited, the owner and applicant for the residential development proposed on land to the rear of the former Dylon International Premises site, next to the Crest Nicholson scheme (under construction), off Station Approach, at Lower Sydenham.

This representation relates specifically to Section 2.1 and Draft Policy 1 on Housing Supply (and associated Appendix 10.1: Housing Trajectory), including the Council’s assertion that it can demonstrate a five year housing land supply (5YHLS) of 3,686 units against the current London Plan minimum target of 3,205.

Summary Soundness Review

We find that, in terms of housing need and supply:

(a) there is a clear objectively assessed need for the BDLP to plan for significantly more new homes (both market and affordable) than both the current minimum target for Bromley Borough in the London Plan (2016) and that provided within Draft Policy 1 and the Council’s 2015 - 2030 housing trajectory (BDLP Appendix 10.1); and

(b) there is not a five years housing land supply (5YHLS) in Bromley Borough (LBB), as a consequence of errors in the Council’s assessment methodology – a continuing position, as LBB has not adequately addressed the Dylon Appeal Inspector’s reasons for finding that

23

P2/7 13000303v3

“the Council cannot demonstrate a 5 year supply of deliverable housing sites.” (Appeal decision APP/G5180/W/16/3144248 dated 2 August 2016)

As a consequence, the BDLP is unsound, in respect of both the housing target (to meet the objectively assessed need [OAN]) and the housing supply available to do so, because these elements of the Plan are not:

1 positively prepared, as LBB’s strategy does not seek to meet objectively assessed need for residential development;

2 justified, as the BDLP does not provide the most appropriate planning strategy in response to the evidence available:

3 effective, as the Housing Trajectory is both inadequate and not deliverable; and

4 inconsistent with national policy, by not meeting the objectively assessed need to deliver new housing it is not planning for sustainable development.

We explain these judgements in the remainder of this representation which is structured as follows:

Housing Need - NPPF requirements for identifying the OAN - London and London Borough of Bromley’s OAN

Housing Supply to Meet Bromley’s OAN - Lapse rates - Windfall sites - Deliverability and delivery rates

Housing Need

NPPF Requirements

The National Planning Policy Framework (NPPF, para. 47) states: “To boost significantly the supply of housing, local planning authorities should:

use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the policies set out in this Framework, including identifying key sites which are critical to the delivery of the housing strategy over the plan period;”

The housing figure against which to measure housing supply in a five year housing land supply calculation is established in the below extract from the Planning Practice Guidance (ID 3-030). “Housing requirement figures in up-to-date adopted Local Plans should be used as the starting point for calculating the five year supply. Considerable weight should be given to the housing requirement figures in adopted Local Plans, which have successfully passed through the examination process, unless significant new evidence comes to light.”

24

P3/7 13000303v3

London and LBB OAN

LBB has used the minimum 641 annual housing target in the London Plan (Policy 3.3). This housing requirement was set through the Further Alterations to the London Plan (FALP) which, was examined by an independent Inspector in November 2014. The Inspector’s Report concluded that the FALP was an appropriate basis for strategic planning in London. However, the Inspector stated: “The targets …will not provide sufficient housing to meet objectively assessed need... Nor do I consider that the Mayor can rely on paragraph 47 of the NPPF or the duty to co-operate to make London Boroughs provide more” (para. 56, Report on the Examination in Public into the Further Alterations to the London Plan November 2014)

It is clear therefore that London as a whole is not planning to meet objectively assessed housing needs. Consequently, neither is LB Bromley.

There is a clear disparity between the housing needs of Bromley and the quantity of homes currently being planned for. The London SHMA (2013) identified housing need in Bromley of 1,315 dwellings per annum, more than double the target in the adopted London Plan (2015) of 641. (NB. The SHMA also identified a net annual need of c.1,400 affordable housing units p.a. in Bromley (BDLP 2.1.28)).

The Housing Supplementary Planning Guidance (SPG) (Published by the Mayor in March 2016) includes the three scenarios (below) which use more up to projections on population and household growth in Bromley to identify that housing needs are now significantly greater than those identified in the 2013 London SHMA:

1 GLA Household Projections 2014 Round Long Term Variant (December 2015) 1,535 per annum;

2 GLA Household Projections 2014 Round Short Term Variant (December 2015) 1,855 per annum; and

3 DCLG 2012-based Projected Annualised Household Growth 1,780 per annum.

The early review into the London Plan (2015) is underway and publication of the draft Plan for consultation is anticipated in autumn 2017. As such, new SHMA evidence on housing needs in London is expected to become available next year.

The NPPF expects Local Plans to meet OAN (para 14) and the immediate full review of the London Plan is being undertaken to meet the OAN of London as a whole. It is therefore highly likely that Bromley will have a significantly increased target in the new London Plan. If the early review of the London Plan introduced a target to meet housing needs based upon any of the projections set out in the Housing SPG, it would drastically alter the five year housing land supply position of the Council. On the basis of published projections of the Housing SPG, the level of housing need in Bromley is somewhere between 1,315 and 1,855 dwellings per annum.

If the minimum need figure of 1,315 were to be adopted and a 5% buffer applied, the minimum LBB OAN would be 1,381 per annum or 6,904 over the five year period..

Thus, Bromley’s housing target is anticipated to be revised when the new draft London Plan is published (scheduled for Autumn 2017) around the same time as the BDLP is scheduled for adoption and one year ahead of the anticipated adoption of the London Plan. In other words, in the context that Mayor’s March 2016 projections indicate that LBB’s OAN is likely to at least double the

25

P4/7 13000303v3

London Plan minimum requirement of 641 dwellings p.a. (if not triple it), draft Policy 1 and the housing provisions of the BDLP will become out of date almost immediately following the Plan’s adoption.

That is wholly unacceptable forward planning. It not only affects the 5YHLS, but there are self-evidently consequences for the 5 to 10 and 10 to 15 year housing trajectory periods too. The BDLP recognises that “The early review of the London Plan, with its linked evidence base, should provide

an early update of the housing land delivery in the Borough” (2.1.21, and 2.0.3), but does nothing to seek to address the need evidence available now. Failure to address the acute housing need in the Borough can only lead to further housing shortfall and hardship, contrary to the BDLP Homes objective, the London Plan and the NPPF.

Housing Supply to Meet Bromley’s OAN

There are a number of specific reasons why we do not consider the Council’s supply figures within Table 1 of the DBLP to be accurate or robust to demonstrate a 5YHLS and thus why the BDLP is unsound.

Lapse Rates

A primary consideration in the assessment of Housing Need and Supply is the ‘lapse rate’ of planning permissions and the need to reflect this in the assessment of supply.

The inclusion of a lapse rate for planning permissions which have been approved in the context of the requirements of the NPPF has been established in the High Court Judgment between Cotswold District Council and the SOS for CLG (Cotswold District Council Vs SoSCLG (27

November 2013)). Paragraph 71 of the judgment is clear that evidence of lapse rates in a local authority constitutes sufficient compelling evidence to justify why some schemes with planning permission will not be implemented.

Such evidence exists in LBB through a multitude of sources, namely:

1 Examination in Public into the FALP – where London SHLAA (2013) data was cited that found that in Bromley over the period of 2004-2012 56% of approvals were completed while in 2008 -2012 this increased to 69% i.e. lapse rates of 44% and 31% respectively. There is no evidence to support that for the period of the BDLP there will be a 0% lapse in the implementation of planning permissions that have been, and may be granted.

2 The London Mayor’s ‘Barriers to Housing Delivery Update’ (July 2014) – found that only about half of the total number of dwellings granted planning permission every year are built in schemes of 20+ units – i.e. a c.50% lapse rate.

3 London Borough of Bromley Housing Supply Strategy (2005) – found that only 63% of total permissions were converted into completions in the period 1999-2003 – i.e. a 37% lapse rate.

4 Blue Circle SOS Appeal1 – where the Inspector concluded: “I consider it unsafe to assume that

the Council’s purported 100% delivery rate will be achieved. Therefore… if it is assumed that

about a third of the planning permissions granted will not be implemented then there is a

significant deficit in the 5 year supply.” – i.e. a c.33% lapse rate.

1 Appeal decision APP/G5180/A/07/2043219 dated 22 November 2007

26

P5/7 13000303v3

5 Anerley School for Boys Appeal2 – where the Inspector concluded: “In fact… the Council have

achieved an average conversion rate of dwellings delivered against permissions granted of

49% over the period 1999 to 2008.” – i.e. a 51% lapse rate.

6 Dylon Phase 2 Appeal3 – where the Inspector concluded: “..a lapse rate should be applied, to

give a more accurate picture of what is likely to be achieved in terms of actual completions and

that figure should be higher than the Council's assumed 5% and applied.”

In the face of the substantive evidence which shows that lapse rates in the implementation of development following the grant of planning permission occur consistently in Bromley, the DBLP should not be adopted until a lapse rate of between 30% and 50% for sites with planning permission not commenced in Bromley is factored into the 5YHLS figure.

Windfall Sites

The NPPF (paragraph 48) is clear that windfalls can be used in a calculation of housing supply. However, the NPPF is also clear that any windfalls figure needs to be justified and based on sound evidence.

It is noteworthy that the Dylon Phase 2 Appeal Inspector considered that the appellant’s windfalls figure “would be a more realistic figure” and even a “conservative figure midway…” would miss the five year housing land supply target (on this ground alone).

The Council’s small sites windfall allowance takes an average over the period 2008/09 to 2011/12 removing 90% of completions on garden land. A figure of 352 per annum based on the London-wide SHLLA 2013 has been used on this basis. More recent data (post 2011/12) has not been analysed to justify the application of this outdated annual figure going forward. This is particularly pertinent given the Council’s use of a (much lower) 120 per annum figure in the Council’s 5YHLS Paper Nov 2016.

It is important that, when including windfalls in a five year housing land supply calculation, there is also no double counting with small site approvals. Windfalls are sites which come forward and secure planning permission but are not planned for on a site by site basis. Therefore, to ensure no double counting between small sites with planning permission or commenced, time has to be allowed for the permissions to be built out to avoid double counting.

In the absence of clear and transparent evidence of how the small sites allowance (windfall) figure relates to the various other small sites supply figures, there has to be concern as to whether there has been double counting in the windfall figures presented by the Council, particularly as the small sites allowance is the largest component of the Housing Trajectory. In the absence of the necessary evidence, we conclude that there is likely to be an overestimate for this allowance.

Deliverability and Delivery Rates

We do not consider a number of sites identified in the DBLP meet the NPPF footnote 11 definition of a deliverable site such that they are deliverable in the first five year period. The PPG also adds clarity to what constitutes a ‘deliverable site’ in respect of suitability, availability and achievability as follows:

2 Appeal decision APP/G5180/A/08/2088139 dated11 May 2009 3 Appeal decision APP/G5180/W/16/3144248 dated 2 August 2016

27

P6/7 13000303v3

a Sites should be assessed for their suitability by consideration of physical limitations, potential impacts (including landscape, nature, heritage and environmental/amenity impacts) and appropriateness. Sites with allocations or permissions will generally be considered suitable (ID:3- 019);

b Sites should be considered available when, best information gives confidence that there are no legal or ownership problems, such as unresolved multiple ownerships, ransom strips tenancies or operational requirements of landowners and that this will often mean that the land is controlled by a developer or landowner who has expressed an intention to develop, or the landowner has expressed an intention to sell (ID:3- 020); and

c Sites should be considered achievable where, based upon a judgement about the economic viability of the site, there is a reasonable prospect that the particular type of development will be developed on the site at a particular point in time (ID:3-021)

By way of example, the Small Halls site (York Rise, Orpington) is allocated for 35 units in the five year period. The DBLP identifies the site as Council-owned and vacant with a temporary approval for its use as a car park for up to three years (to 31st October 2019). Therefore the site is not available now and will not be for 3.5 years. As such, it does not fulfil the requirements of footnote 11 of the NPPF and, as per the PPG (ID: 3- 020), there are still operational requirements on site. The site is therefore not deliverable.

The Council has a long history of under-delivery from its allocated sites and over-reliance on a dwindling windfall sites being granted on appeal, contrary to its own planning decisions. Realistic assessments of delivery rates need to be factored into the BDLP. For example, the Town Centre AAP sites produced virtually no dwellings at all in the first five year period of that Plan: the Ringers Road site, first granted planning permission in 2007, did not produce new homes until eight years later; and the 200 units within the Westmorland Road Car Park, granted in 2012, are now anticipated to be complete at the end of 2017. Another example is at Lower Sydenham where the Dylon Phase 1 site first secured planning permission in 2010 and was commenced, but housing construction did not start until 2016.

Furthermore, LBB has been found to be one of the worst-performing boroughs in terms of where population growth is significantly outstripping housing supply (as reported in the Inside Housing article, ‘The 100 Club’, 14 October 2016, drawing on Savill’s research), in response to the Government having identified the 100 worst–performing local authority areas where it will work intensively to address the supply issues. The research compared data on projected household growth by 2020 and homes started in the last five years by local authority to conclude on the number of new homes delivered for each new household produced. In the case of Bromley, only 0.36 homes were delivered for each new household in the Borough, ranking Bromley in the 20 worst-performing local authority areas nationally and one of the worst in London.

Conclusions

There is a clear evidence based disparity between the current housing needs of Bromley and the quantity of homes currently being planned for in the Housing Trajectory. In addition, it is highly likely that Bromley will have a significantly increased housing target in the new London Plan based on meeting the OAN of London, for which the BDLP makes no provision. Bromley’s Local Plan for the next 15 years would therefore become out of date shortly after its scheduled adoption. This

28

P7/7 13000303v3

would also have consequential implications for other policies and proposals within the Plan, including the site specific allocations.

The housing supply section of the BDLP is defective in meeting the current minimum housing target – let alone the anticipated significantly increased minimum target in 2017/18 - as a consequence of assuming a zero lapse rate, double counting within the small windfall sites allowance and unrealistic site specific delivery factors.

The provision of additional housing land to increase housing supply is not only necessary to satisfy the BDLP’s ‘Homes objective’ to “Ensure there is an appropriate supply of homes to meet the

varying needs and incomes of the local population…” (1.3.7), but is fundamental to satisfy the NPPF requirement to meet the OAN and the London Plan’s requirement to exceed the minimum targets and to seek to provide extra housing capacity to close the gap between that target and the identified housing need.

Accordingly, we find the BDLP to be unsound, in respect of both the housing target (to meet the objectively assessed need) and the supply available to do so, because these elements of the Plan are not positively prepared, justified, effective or consistent with national policy.

The importance of maintaining a five year supply of housing land is paramount to the adoption of a sound Local Plan (NPPF para 47, point 2 and 4 and PPG ID 3-033) and in delivering much needed housing in the Borough. We therefore consider that the DBLP needs to be objectively and factually reassessed so these matters can all be addressed through the Local Plan Examination.

Yours sincerely

Steven Butterworth Senior Director

29

Representation no.

DLP134_5


Draft Policy 13 - Renewal Areas



The Draft Plan fails to identify the area of Lower Sydenham, as a Renewal Area. This is an area which, together with the neighbouring wards in the London Borough of Lewisham, from a socio-economic perspective performs less well against a range of economic, deprivation and housing indicators than LBB averages and as such should be a focus for renewal and improvement. The Draft Plan is not therefore in conformity with the requirements of Policy 2.6; 2.7 and 2.8 of the London and accordingly fails this requirement.


The Draft Plan fails to identify the area of Lower Sydenham, as a Renewal Area. This is an area which, together with the neighbouring wards in the London Borough of Lewisham, from a socio-economic perspective performs less well against a range of economic, deprivation and housing indicators than LBB averages and as such should be a focus for renewal and improvement. Accordingly, the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound.




No.

30

Representation no.

DLP134_6


Draft Policy 30 - Parking



The Parking Standards set out in the Draft Plan are not in conformity with the requirements of Policy 6.13 E of the London Plan 2016 in that they set minimum standards, not maximum as set out in Table 6.2 of the London Plan and accordingly it fails this requirement.


The Parking Standards set out in the Draft Plan are not in conformity with the requirements of Policy 6.13 E of the London Plan 2016 in that they set minimum standards, not maximum as set out in Table 6.2 of the London Plan and accordingly it is not sound.


No.

31

Representation no.

DLP134_7


Draft Policy 50 - Metropolitan Open Land



The Draft Plan fails to embrace a review of the boundaries and condition of existing designated MOL in compliance with the provisions of Policy 7.17 D of the London Plan and thereby contributes to the failure to address the OAN and make correct and sound provision of a 5YHLS for the reasons set out in the NLP letter of 28 Dec 2016. Accordingly the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound.


No.

32

Representation no.

DLP134_8


Draft Policy 35 - Transport Investment Priorities



The draft plan fails to objectively assess the potential extension of the Bakerloo Line, which currently terminates at Elephant and Castle. In their ‘Options Assessment Report’, published in December 2015, TfL detail a proposed option to provide an extension of the line to Hayes (Kent) and Beckenham Junction. This option consists of a tunnelled extension to Lewisham via Old Kent Road with the line extension, beyond Lewisham, replacing existing national rail services to Hayes. If implemented, services would call at Lower Sydenham, New Beckenham, Clock House, Elmers End, Eden Park, West Wickham and Hayes with a spur to Beckenham Junction: all within the borough which the Council acknowledges is not well served with a lack of an Underground and an extensive Overground network and unacceptable crowded train services to Central London. It is anticipated that the extended Bakerloo line could provide up to 27 trains per hour to Catford Bridge with 15 trains per hour continuing south to Hayes, and a further 6 trains per hour to Beckenham Junction. This leads to the potential for 21 trains per hour operating south of Catford Bridge serving the boroughs current and future resident population. TfL’s Option Selection Summary Report (Dec 2015) notes that there could be significant additional benefits from an extension beyond Lewisham and that further work is required to develop the deliverability and case.

The Council is therefore wrong to fail to support this potential to bring forward a significant increase in journey frequency, and the associated added connectivity. Accordingly the Council has failed to positively prepare to meet objectively assessed development and infrastructure requirements which it should have reasonably done in order to address the need to achieve sustainable development and the Draft Plan is therefore not sound.


Yes. In order to fully address the issues and test the Councils approach to its assessment of the Spatial Strategy and Housing delivery.

33

Representation no.



DLP135_1 Section 1.2 – About the Local Plan DLP135_2 Section 1.3 – Visions and Objectives DLP135_3 Section 1.4 – Spatial Strategy DLP135_4 Draft Policy 1 – Housing Supply DLP135_5 Draft Policy 13 – Renewal Areas DLP135_6 Draft Policy 30 – Parking DLP135_7 Draft Policy 35 – Transport Investment Priorities DLP135_8 Draft Policy 50 – Metropolitan Open Land

Format Online Full Name Chris Francis Organisation West and Partners for Relta Ltd

34

Representation no.

DLP135_1


Section 1.2 - About the Local Plan





No.

35

Representation no.

DLP135_2







No.

36

Representation no.

DLP135_3



Format Online Full Name Chris Francis Organisation West and Partners for Delta Ltd



2. The Draft Plan fails to identify the area of Lower Sydenham, as aRenewal Area. This is an area which, together with the neighbouring wards in the London Borough of Lewisham, from a socio-economic perspective performs less well against a range of economic, deprivation and housing indicators than LBB averages and as such should be a focus for renewal and improvement. The Draft Plan is not therefore in conformity with the requirements of Policy 2.6; 2.7 and 2.8 of the London and accordingly fails this requirement.



2. The Draft Plan fails to embrace a review of the boundaries andcondition of existing designated MOL in compliance with the provisions of Policy 7.17 D of the London Plan and thereby contributes to the failure to address the OAN and make correct and sound provision of a 5YHLS for the reasons set out in the NLP letter of 28 Dec 2016. Accordingly, the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound

3. The Draft Plan fails to identify the area of Lower Sydenham, as aRenewal Area. This is an area which, together with the neighbouring wards in the London Borough of Lewisham, from a socio-economic perspective performs less well against a range of economic, deprivation and housing indicators than LBB averages and as such should be a focus for renewal and improvement. Accordingly, the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound




Yes. In order to fully address the issues and test the Councils approach to its assessment of the Spatial Strategy and Housing

37


delivery.

38

Representation no.

DLP135_4


Draft Policy 1 Housing Supply

Format Online Full Name Chis Francis Organisation West and Partners for Relta Ltd



2. Draft Policy 1 fails to include any provisions which seek to exceedthe current target set by the London Plan, as is required by Policy 3.3 D and Da the latter of which states "Boroughs should draw on the housing benchmarks in table 3.1 in developing their LDF housing targets, augmented where possible with extra housing capacity to close the gap between identified housing need (see Policy 3.8) and supply in line with the requirement of the NPPF" It is therefore not in conformity with this requirement of the London Plan and not legally compliant.



2. Draft Policy 1 fails to seeks to meet objectively assesseddevelopment and infrastructure requirements, as it lacks any provisions which seek to materially and significantly exceed the current housing supply target set by the London Plan, as is required by Policy 3.3 D and Da the latter of which states "Boroughs should draw on the housing benchmarks in table 3.1 in developing their LDF housing targets, augmented where possible with extra housing capacity to close the gap between identified housing need (see Policy 3.8) and supply in line with the requirement of the NPPF" It is therefore not sound.

3. The Draft Plan, generally and Draft Policy 1 fail to have proper andproportionate regard to the clear indications in the direction of travel of government of the need to take every opportunity to provide for the delivery of new housing to meet identified need. In particular, no provision for increasing density within the vicinity of commuter hubs and on previous developed land; including such land in the Green Belt and MOL; is provided for. The Draft Plan therefore fails to seeks to meet objectively assessed development and infrastructure requirements and is not sound.

4. The Draft Plan fails to identify, as an allocated residentialdevelopment site, the land forming part of the former Dylon

39

International Premises site off Station Approach, site at Lower Sydenham. In August 2016 the principle of a scheme for the residential redevelopment of the brown field elements of this site was in effect endorsed by an Inspector appointed by the Secretary of State. This justifies the inclusion of the site as an allocated housing site as it can and will make a meaningful contribution to the objectively assessed housing needs of the borough within the early years of the Plan period. The omission of the site means that the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound.



40





14 Regent's Wharf All Saints Street London N1 9RL

020 7837 4477 [email protected]

nlpplanning.com


Dear Sir / Madam






Summary Soundness Review

We find that, in terms of housing need and supply:



41

P2/7 13000303v3










Housing Need

NPPF Requirements




42

P3/7 13000303v3

London and LBB OAN












43

P4/7 13000303v3






Lapse Rates











significant deficit in the 5 year supply.” – i.e. a c.33% lapse rate.

1 Appeal decision APP/G5180/A/07/2043219 dated 22 November 2007

44

P5/7 13000303v3








Windfall Sites







We do not consider a number of sites identified in the DBLP meet the NPPF footnote 11 definition of a deliverable site such that they are deliverable in the first five year period. The PPG also adds clarity to what constitutes a ‘deliverable site’ in respect of suitability, availability and achievability as follows:

2 Appeal decision APP/G5180/A/08/2088139 dated11 May 2009 3 Appeal decision APP/G5180/W/16/3144248 dated 2 August 2016

45

P6/7 13000303v3







Conclusions


46

P7/7 13000303v3







Yours sincerely


47

Representation no.

DLP135_5












48

Representation no.

DLP135_6










49

Representation no.

DLP135_7


Draft Policy 35 Transport Investment Priorities



The draft plan fails to objectively assess the potential extension of the Bakerloo Line, which currently terminates at Elephant and Castle. In their ‘Options Assessment Report’, published in December 2015, TfL detail a proposed option to provide an extension of the line to Hayes (Kent) and Beckenham Junction. This option consists of a tunnelled extension to Lewisham via Old Kent Road with the line extension, beyond Lewisham, replacing existing national rail services to Hayes. If implemented, services would call at Lower Sydenham, New Beckenham, Clock House, Elmers End, Eden Park, West Wickham and Hayes with a spur to Beckenham Junction: all within the borough which the Council acknowledges is not well served with a lack of an Underground and an extensive Overground network and unacceptable crowded train services to Central London. It is anticipated that the extended Bakerloo line could provide up to 27 trains per hour to Catford Bridge with 15 trains per hour continuing south to Hayes, and a further 6 trains per hour to Beckenham Junction. This leads to the potential for 21 trains per hour operating south of Catford Bridge serving the boroughs current and future resident population. TfL’s Option Selection Summary Report (Dec 2015) notes that there could be significant additional benefits from an extension beyond Lewisham and that further work is required to develop the deliverability and case.

The Council is therefore wrong to fail to support this potential to bring forward a significant increase in journey frequency, and the associated added connectivity. Accordingly the Council has failed to positively prepare to meet objectively assessed development and infrastructure requirements which it should have reasonably done in order to address the need to achieve sustainable development and the Draft Plan is therefore not sound.



50

Representation no.

DLP135_8


Draft Policy 50 Metropolitan Open Land






51

Representation no.

DLP136_1


Housing mixed use allocation Site 2 – Land adjacent to Bromley North Station

Format Online Full Name Matt Walker Organisation


Whether this matter is legally compliant I cannot judge, nor whether I am completing the correct area of the form which I would suggest is a deliberate action to prevent comment from concerned residents. In relation to the development situated at Bromley North I would first echo the comments and points raised by the BRRA.

I fail to see how the proposed development can reasonably be deemed suitable and in character with the current local area. The addition of such a large quantity of housing will pose serious issues for all residents in relation to parking, access to facilities such as doctor’s surgeries / schools which will not be increased in line with the population.

LBB and its councillors clearly have no regard for the wellbeing of its residents as demonstrated by the current development at Bromley south. As the council itself previously objected to developments at BN site it will be interesting to learn why there position has changed. Whilst the end result will affect all who reside nearby the disruption / noise pollution such an extensive development will create will also be intolerable.


No.

52

Representation no.

DLP137


DLP137_1 Housing Mixed-Use Site 13 – Banbury House, Chislehurst DLP137_2 Education Allocation Site 36 – Land at Bushell Way, Chislehurst

Format Online and Email Full Name Anthony Johnson Organisation Bushell Way Residents Association

53

Representation no.

DLP137_1


Housing mixed use allocation Site 13 Banbury House, Bushell Way, Chislehurst

Format Online and email Full Name Anthony Johnson Organisation Bushell Way Residents Association


I would like to be reassured that the impact of this development on local highway safety has been considered. In particular the junction of Bushell Way with White Horse Hill is perceived by local residents as dangerous and anecdotally there have been casualties including deaths due to road traffic accidents. The additional traffic caused by a further 25 dwellings (and by the proposed school at the end of Bushell Way) would considerably increase the movements from Bushell Way out onto White Horse Hill where despite traffic calming measures traffic often appears unexpectedly from behind parked cars.

I suggest that this could be mitigated by (a) extending no parking restrictions on White Horse Hill either side of the junction to improve sight lines (b) offering parking space on the Banbury House site to residents on White Horse Hill without off-road parking (c) using the Banbury House site for low car use accommodation such as a care home. I note that a care home was demolished to allow Stead Close and the adjoining properties on Bushell Way to be built, and there is a growing need for more such accommodation, so a quid pro quo would be for the Banbury House site to be designated for this use in the local plan, rather than for housing.

If the site is designated for housing, at 25 dwellings the density would be unacceptably high compared with adjoining sites in the Bushell Way neighbourhood.


TThe Council may not be aware of the Bushell Way Residents Association (BWRA), which is a management company responsible for the management of Stead Close and some aspects of services to 2-2e Bushell Way. It is controlled by the residents who request that the Council cooperate with BWRA on issues regarding the local plan and its implementation.


54

Representation no.

DLP137_2



Format Online and email Full Name Anthony Johnson Organisation Bushell Way Residents Association


I note that previous concerns about maintaining biodiversity on this site, and the need to maintain a public right of way past it to Walden Woods have been acknowledged.

However it is not clear that the impact of this development on local highway safety has been considered. In particular the junction of Bushell Way with White Horse Hill is perceived by local residents as dangerous and anecdotally there have been casualties including deaths due to road traffic accidents. The additional traffic caused by the proposed school at the end of Bushell Way (and 25 dwellings on the Banbury House site) would considerably increase the movements from Bushell Way out onto White Horse Hill where despite traffic calming measures traffic often appears unexpectedly from behind parked cars.

I suggest that this could be mitigated by (a) extending no parking restrictions on White Horse Hill either side of the junction to improve sight lines (b) offering parking space on the Banbury House site to residents on White Horse Hill without off-road parking (c) introducing a mini-roundabout or traffic signals at the junction.

Within Bushell Way there is already a problem with inconsiderate car parking, and the "school run" is notorious for adding to this in other areas. This could only be mitigated by stricter parking restrictions for non-residents and assiduous policing of such restrictions.

If these traffic control measures cannot be introduced then the re-designation from UOS to educational use should not be sanctioned in the local plan.

In view of the likelihood of more impermeable surfaces being introduced, it would be good to be reassured that sustainable drainage measures would be mandatory to prevent run-off under storm conditions into adjoining areas.


The Council may not be aware of the Bushell Way Residents Association (BWRA), which is a management company responsible for the management of Stead Close and some aspects of services to 2-2e Bushell Way. It is controlled by the residents who request that the Council cooperate with BWRA on issues regarding the local plan and its implementation.

55


56

Representation no.

DLP138


Draft Policy 1 – Housing Supply Draft Policy 2 – Affordable Housing Draft Policy 11 – Specialist and Older Peoples Accommodation

Format Email Full Name Andy Black Organisation PRP for CALA Homes

57

30 December 2016

Dear Sir / Madam

By Email/Post AT6551-6.03/001/ab [email protected] 7653 1427

Planning Strategy and Projects Team London Borough of Bromley Civic Centre Stockwell Close Bromley BR1 3UH

Consultation on the Proposed Submission Draft Local Plan - December 2016

I write in response to the consultation on the proposed submission draft local plan under Regulation 19 of the Town and Country Planning (Local Planning) Regulations 2012. PRP acts as agent on behalf of CALA Homes (South Homes Counties) Limited specifically in relation to the Langley Court site in Beckenham.

As you may be aware, outline planning permission for residential development of the site (Ref: PA/12/00976/OUT) was granted on the Langley Court site by London Borough of Bromley in June 2014. The application comprised up to 179 new homes of which up to 79 were affordable, 629sqm of Class D1 (Non-residential institution), and up to 1,040sqm of Class D2 (Assembly and Leisure).

In the draft Local Plan, the extant planning permission is noted in the Housing Trajectory (10.1) as providing 179 dwellings (page 255) to be developed in the period up to 2020.

This letter makes representation on a number of specific policies within the draft local plan.

Duty to cooperate and Strategic Planning

The provisions within the draft plan at para 1.2.9 in relation to the statutory duty to cooperate are noted. The Council will be aware that the Policy 2.2 E within the London Plan requires all London Boroughs, particularly those in outer London such as Bromley, to work with all authorities and agencies in neighbouring regions both inside and outside Greater London to develop common approaches to issues of cross-border significance.

The NPPF also requires boroughs to cooperate on planning issues that cross administrative boundaries, particularly those that relate to those strategic priorities set out in paragraph 156 of the Framework. This includes planning for homes and jobs in the area.

58

mailto:[email protected]

Paragraph 179 of the framework states that local planning authorities should work collaboratively with other bodies to ensure that strategic priorities across local boundaries are properly coordinated and clearly reflected in individual local plans.

Paragraph 181 of the framework specifically states: Local planning authorities will be expected to demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts when their Local Plans are submitted for examination. This could be by way of plans or policies prepared as part of a joint committee, a memorandum of understanding or a jointly prepared strategy which is presented as evidence of an agreed position.

Whilst it is acknowledged that there has been discussion with other London Boroughs, it remains unclear from the draft plan of how the policies have been shaped as a result of this. Several of the housing renewal areas cross into neighbouring planning authorities and there is no detail in the housing policies to explain how the housing numbers are to be allocated between the neighbouring authorities in order to avoid double counting.

Overall, other than statements contained within the supporting text for individual policies setting out that the duty to co-operate has been met, no supporting evidence has been submitted alongside the plan which would clearly demonstrate that this has been achieved or carried out to a satisfactory level which would lead to the plan being found sound.

Housing Need

The London Plan treats London as a single HMA and undertakes a single assessment of objective housing need on behalf of all the London boroughs within the SHMA published in 2013. It is established that the full OAN for London is 49,000 dpa for the period of time of 2015-2025 as covered by the London Plan. It is held by many that the actual OAN may be as high as 62,000 dpa. Nevertheless the actual housing needs of London will only ever be addressed if 49,000 dpa is provided every year for the next 21 years – 2015- 2036. The Mayor has been very clear within the London Plan that this figure should be regarded as a minimum (paragraph 3.16b).

It is common ground amongst the GLA and London Boroughs that there is an under delivery from the current London Plan of 7,000 dwellings per annum against the full objectively assessed need (an assessed capacity of 42,000 against a full OAN of 49,000). Many of the plans produced in draft form or fully adopted by London Boroughs since the London Plan was adopted have also shown that the gap between OAN and actually capacity remains in place. Bromley is one of a number of London Boroughs which has produced a draft plan which will only match the London Plan baseline of 641 dpa and goes no further to close the gap.

Paragraph 2.1.4 of the draft plan states a housing supply of 641 dpa for a total of 10 years between 2015/16 - 2024/25 but this is only actually 9 financial years. This is assumed to be an error and the council did in fact mean 2025/26.

It is clear that the Council has done the minimum necessary to be in conformity with the London Plan. Bromley has not shown through the draft plan that it has done anything to close the gap between demand and supply within London This does not reflect the way in which the NPPF was written with the firm instruction to local authorities to “boost significantly the supply of housing”.

Bromley Local Plan Consultation Response 2

59

In preparing the new local plan it is expected that a new Strategic Housing Market Assessment would be published to establish the local objectively assessed need but this has not been done. The last SHMA which was produced was published in 2014 and this is now considered to be dated but in any event this has not been included within the evidence base documentation which accompanies the new draft plan. However the SHMA is referred to in paragraph 2.1.15 which states that:

A SHMA for the South-East London sub region was finalised in June 2014 and estimates an annual housing requirement across the sub region of 7188 units and a net annual need for 5000 affordable units. The net additional dwelling requirement for Bromley per annum was estimated at approximately 1320 units. Across the sub-region annual capacity targets identified within the 2013 SHLAA reach 7893 units. GLA household projections in 2014 estimate an annual short term variant of 1840 households per annum for the Borough and a long term variant of 1530 households per annum.

The figure of 1,320 dwellings per annum is higher that the London Plan monitoring figure yet the plan shows little acknowledgement of the need to address this higher requirement.

Housing Supply

Table 1 on page 29 of the plan shows a land supply to accommodate 7,259 homes over the plan period. The minimum number of homes necessary to meet Bromley’s requirement is 6,410 and Table 1 therefore implies that an additional 849 homes would be supplied over the minimum requirement. It is therefore unclear whether the council considers the plan requirement as 726dpa (7,259 divided by 10) or if this is considered as an oversupply to reflect housing need. .

In any event this is a very small increase in supply above the total unmet need with a potential contribution of just 85 dwellings per annum compared to an undersupply across London of 7,000 dwellings per annum.

Most local planning authorities elsewhere in England apply a slippage rate to any housing trajectory which accounts for non-implementation of planning permissions. Camden Council allows for a figure of 10% within its adopted plan and if this figure were applied to the housing trajectory for Bromley then it would equate to almost the entire 849 dwelling oversupply rendering this irrelevant and highlights the minimum approach taken by the council towards housing supply.

From the housing trajectory it is clear that council is reliant on small sites (effectively windfall sites) for providing more than half of the overall housing target. There is little certainty that these sites will actually materialise and do not have the same assurance of delivery as larger allocated sites.

Paragraph 2.1.21 sets out that the council will seek to "bring forward other policy compliant larger sites if the small sites rate is too low” and that these other sites would take the form of large windfall sites. If there are other large policy compliant sites which exist in the borough then these should be identified within the plan in order to boost supply above minimum figure of 641 dpa. There is also no evidence within the plan of what the council would consider to be the definition of the rate of delivery from small sites as being "too low".


60

Appendix 10.1 of the draft plan identifies Langley Court as having planning for 179 dwellings. This is one of the larger sites within the housing trajectory with delivery identified for 1-5 years within the plan period. Within draft policy 1 there is no objective to increase the density and housing supply from sites already benefiting from planning permission and not yet started as is the case with Langley Court.

A detailed study of the site demonstrates that a planning application could be brought forward which increases the density on the site to 251 units including an increase in affordable housing. In addition a 100 bed care home. It is therefore submitted that sites with the benefit of an existing outline planning permission, which have not yet been implemented should be reconsidered to establish if an increase in density and unit numbers can be achieved without a detrimental impact on character of the area or other material planning considerations. It is clear from the current draft local plan that this exercise has not been carried out and as such the strategy under delivers on the potential to significantly boost the supply of housing as directed by the framework.

Draft Policy 11 deals with Specialist Housing and Older Peoples Accommodation and the inclusion of this policy within the draft plan is supported. However the policy makes it clear that provision of older peoples housing is only supported where they are "conveniently located for a range of local shops, services and public transport appropriate to the mobility of the residents". This element of the policy is not supported and there is no justification to place this level of restriction upon the provision of specialist housing when such a policy is not applied to the provision of general needs housing.

Furthermore the policy places the emphasis on the applicant to justify demand for such housing and it is submitted that the council has done nothing to quantify this demand as evidenced within a number of other assessments for London and the closer sub region. It is suggested that the council should assess the need for care and provision of older peoples housing as part of its obligation under the Care Act and sites which have the potential to supply specialist housing of differing tenures should be specifically identified.

Provision of Affordable Housing

Paragraph 2.1.28 refers to the most recent SHMA for the South-East London region which was published in 2014. However this is not listed as an evidence base document accompanying the draft plan and it is therefore not possible to establish the exact need for affordable housing in Bromley based on accurate and up to date evidence.

The affordable housing target is set at 35% within the draft plan and this is based upon the Affordable Housing Viability Assessment Update produced in 2012. This report is considerably out of date and London Plan policies have moved on significantly since then. The new Local Plan must be supported by a more up to date assessment of viability which reflects updated design, construction standards and costs. The viability assessment also needs to take into account the associated costs for compliance with the Nationally Described Space Standards as required by draft policy 4 of the plan.

Draft policy 2 also requires 60% of units to be ‘social rent / affordable rent’, but the accompanying Viability Assessment only uses affordable rent to justify the affordable housing level at 35%. Using a social rent level would inevitably have a detrimental impact on the viability of a site and this is not reflected within the wording of this policy.

Furthermore the policy goes on to state that a departure from the required tenure split would be acceptable where it can be demonstrated that a lower level should be sought or


61

that the 60:40 split would not create mixed and balanced communities. However there is no explanation of what is meant by this within the amplification of this policy. Nor is there any guidance on the implementation of this element of the policy by the development management team as part of a planning application.

In its current form it is submitted that the 35% level of affordable housing and accompany 60:40 tenure split has not been adequately justified or based on robust and up to date evidence.

For the reasons set out within this submission there is concern that the council has not satisfied the statutory duty to cooperate and furthermore in its strategic plan making has done the bare minimum to meet a substantial undersupply within the borough and the wider London housing market area.

There are clearly opportunities to make the best use of previously consented sites which have not yet been implemented and these should be identified specifically within the draft plan.

It is therefore submitted on behalf of CALA Homes (South Home Counties) Limited that the plan cannot be found sound in its current form and further modifications are required prior to submission in advance of examination.

Yours Sincerely

Andy Black Director Planning


62

Representation no.

DLP139


Education Allocation Site 33 – St. Hugh’s Playing Field Draft Policy 29 – Education Site Allocations Draft Policy 56 – Local Green Space

Format Email Full Name Susan Savage Organisation

63

Draft Policies 28 (Education Facilities) and 29 (Education Site Allocations) The Draft Local Plan currently includes an allocation of the St Hugh’s Playing Fields in Bickley for new education provision. A planning application was submitted to Bromley’s Planning Department in July 2016 by Kier Construction for the construction of a new secondary school, Bullers Wood School for Boys, on this site (Bromley Planning Ref: DC/16/03315/FULL1). It is clear from looking at the proposals that the site is not suitable for a new school because of the significant negative local impacts. These include increased traffic, congestion and road safety hazards on the already busy local roads, loss of scarce open space in an Area of Open Space Deficiency and loss of valuable playing fields which Sport England has objected to. The current plans will also result in an unacceptable loss of residential amenity due to close proximity of the new school to the houses on Chislehurst Road in terms of disturbance, noise, light and loss of privacy. We and many other local residents have written to object to the planning application on the above grounds. The current planning application has clearly shown that the St Hugh’s Playing Fields is not a suitable site for a new school. We, therefore, consider that it should be removed from the list of sites allocated for educational use under Draft Policy 29. Bromley Council needs to be making a much greater effort to encourage the expansion of existing schools in Bromley to meet any future increase in demand for secondary school places and, if a new secondary school is still needed, it should undertake a more detailed examination of the other sites included in the Education Background Paper Autumn 2016 to identify one which is more suitable, particularly from a highways perspective. In particular, the Widmore Centre or the Bromley Civic Centre would appear to be much more suitable sites for a new secondary school. Importantly, using one of these local Brownfield sites would avoid the need to build on the limited green space in our area. Draft Policy 56 (Local Green Space) Given the particular value and significance of the St Hugh’s Playing Fields to the local community, we consider that it should be added to the list of sites to be designated as Local Green Space under Draft Policy 56. The St Hugh’s Playing Fields is a small, but valuable, green space in an Area of Open Space Deficiency and contains wildlife and trees subject to a blanket TPO. It acts as a green lung in an otherwise intensively developed area. As such, it represents a very important local amenity that should be protected.

64

Representation no.

DLP140_1


Housing Allocations Site 2 – Land adjacent to Bromley North Station

Format Email Full Name Morag Hughes Organisation

65

We wish to comment on the proposed “Proposed Submission Draft Local Plan” regarding LBB’s plans to develop 525 residential units around Bromley North Station. As your website is not particularly user-friendly, we have opted to send an email instead. We have lived in this area (Babbacombe Road then Holligrave Road) for over 30 years and are extremely concerned about this development, not least because of the lack of information that has been circulated to residents and those who work in the local area, although we understand that the minimum requirements have been met. Reasons for our concern include the following: Drainage: this is a fairly high density area of Victorian and Edwardian properties and drainage can already be a problem, particularly when there is heavy rain with flooding occurring at some drains in the road. Is there a plan to update this before a further 525 properties are introduced into the area? We have seen no mention of this in the Plan. Schools: the primary schools in the area are oversubscribed with the pupil population already set to increase. There are no secondary schools in the Bromley North area, with the nearest one being outside the Borough in Lewisham. What measures are being taken to ensure that the children moving into the 525 new properties will be allocated a place at a school, without a negative impact on children who already live in the area? Trains to and from Bromley North: since the through trains to London were stopped around 30 years ago, there has been no mention of reinstating these, although the numbers of people travelling has increased due to the large numbers of flats which have already been built in the area replacing individual houses. It can be very difficult to get on some of the rush hour trains at Sundridge Park (e.g. the 08.01 train) and crossing the footbridge at Grove Park can be extremely dangerous due to the volume of passengers. (Indeed there are no facilities for disabled access from Platform 1 at Grove Park so disabled passengers are effectively unable to use this route at present). The Plan talks about long-term aspirational schemes such as extending the DLR from Catford to Bromley South (NB the DLR does not currently serve Catford). Such schemes would take many years to be realised, so are there any concrete plans to serve the increase in commuter traffic which will undoubtedly be an outcome of the Plan? It is irresponsible to embark on this development without having firm assurances from transport providers that an already failing transport provision will be upgraded to meet the additional need. Car access to local homes during construction period: there is already limited access to the Babbacombe Road area due to the barrier across the railway bridge in Lansdowne Road and exit only from Cambridge Road on to Plaistow Green. It seems therefore that the only access to the construction site would be via Crescent Road, Florence Road (both of which are solely residential) or Mitchell Way. This would be very disruptive for the whole area. Parking: parking is already very difficult in this area, in particular for those residents who live in Station Road. This is exacerbated by the number of commercial white vans which are parked in the area on a daily basis, taking up the ‘free’ parking spaces. Although we have been told that those living in the 525 new properties will not have the right to parking permits, we have not been told where they do have the right to park. It is unrealistic to assume that none of the estimated 1,000 residents will be car owners. Tall buildings: we understand that the proposal includes 17-storey buildings. This is not in keeping with the other buildings in the area which, with the exception of Sherman House, are a maximum of 4 storeys. Building taller buildings will significantly alter the character of the area, which is adjacent to a conservation area and includes a listed building. It is not clear how this new development would preserve or enhance the setting, nor whether the new buildings will affect the right to light and privacy of those living close by.

66

Representation no.

DLP141_1


Education Allocation Site 36 – Land at Bushell Way, Chislehurst

Format Email Full Name Joanne Smith Organisation

67

I would like to make my objection to the building on the site of Walden Woods. This has been kept very quite and I only found out this week. Don't build on those woods. I love those woods and use them all the time to walk my dogs. Why not make a bike trail or exercise trail in there for people to have fun. The children have a park for them in the recreation ground. Now give something back to the older ones? As I understand another school is to be built. The traffic will be far worse than it is now on Red Hill/White Horse Hill, Elmstead Lane and Willow Grove/Sainsbury's junction and surrounding roads. The Cowpath is also a very important walkway for those walking to the station and children being walked to school etc. More housing means more areas of concrete where water cannot drain away properly and flooding will occur. More cars parked up on the kerbs. More ugly BT/communication boxes and cheap road furnishings to make the place look 'housing association' - which is very recognisable in building design Having witnessed the demolition of Ravensbourne College BR7 and all the lorries breaking up the road surface, causing potholes making cyclists/scooters vunerable. Was a chemical dump there and the ground contaminated? please can you confirm?

68

Representation no.

DLP142_1



Format Email Full Name Andrew and Kate Brown Organisation

We are opposing to build any building on the green belt because it provides a natural environment for wildlife and provide natural recreational space that is enjoyed / used by our local community.

69

Representation no.

DLP143


Draft Policy 1 – Housing Supply Draft Policy 29 – Education Site Allocations Draft Policy 56 – Local Green Space Draft Policy 49 – The Green Belt Section 4 – Getting Around (Transport and Accessibility) Section 5.3 – Nature Conservation and Development Draft Policy 24 – Allotments and Leisure Gardens

Format Email Full Name Bob Neill MP Organisation

70

I make the following observations, in response to the Council’s consultation on the Draft Local Plan, as one of the Borough’s Members of Parliament. I recognise the need for both additional housing and school provision in the Borough, and welcome the Council’s explicit acknowledgement that these are areas of priority over the coming years. In relation to housing in particular, preference should always be given to previously developed sites, albeit with different previous uses, and building upon open land avoided if at all possible, reflecting the hierarchy of open land protection. With regards to specific site proposals in the Bromley & Chislehurst constituency, I make the following observations: Mixed use sites - I support the proposals, but in relation to plans in the Bromley Town ward, including the Bromley Civic Centre site, any development should be of a sensitive design in both high and density to the adjoining residential areas. School sites - given the clearly proven need for additional school spaces, I welcome the allocations that have been set out in the Plan. In principle, I broadly support any schemes that will support education provision, providing they are shown to be acceptable in planning and highways terms through the usual planning process. I welcome the clear inclusion of areas such as the Bull Lane allotments, Havelock Recreation Ground and Chislehurst Recreational Grounds, Walden Recreational Grounds and Whytes and Walden Woods as Local Green Space sites. I also support the continued importance attached to protecting our local Green Belt, as well as efforts to improve transport routes in areas such as Sundridge Park Railway Station to strengthen access to employment. I echo the concerns raised by the Chislehurst Society with regards to the felling of trees in conservation areas, and to the apparent scaling down of protections offered to allotments and leisure gardens by dropping the requirement to demonstrate long term insufficient demand in Draft Policy 24.

71

Representation no.

DLP144_1


Education Allocation Site 33 – St. Hugh’s Playing Field

Format Email Full Name Alan and Linda Howes Organisation

72

With reference to Bromley's Draft Local Plan "Draft Policy 29 - Education Site Allocation", we have already submitted two objections to the planning application for the proposed Bullers Wood Boys School on St Hugh's Playing Field. Briefly, these objections relate to the adverse effect on traffic in an already heavily congested area, the safety of pedestrians at the entrance/exit onto Chislehurst Road, that the site is too small for the proposed buildings together with playing fields for both the girls and the boys schools, the shortage of parking space in local roads during the daytime, and the possible nuisance from the evening use of the community sports hall.

For these reasons we hope that the council will find a more suitable site for any necessary expansion of school places.

73

Representation no.

DLP145


DLP145_1 - Education Allocation Site 33 – St. Hugh’s Playing Field DLP145_2 - Draft Policy 56 – Local Green Space

Format Email Full Name Joan and Graeme Shankland Organisation

74

SUBJECT - COMMENTS ON BROMLEY’S DRAFT LOCAL PLAN Dear Sir/Madam, We have set out below our comments on Bromley’s Draft Local Plan: DRAFT POLICY 29 – EDUCATION SITE ALLOCATIONS We believe St Hugh’s Playing Fields should be removed from the list of sites allocated for new education provision as it is not a suitable for for the building of the new Bullers Wood School for Boys (Planning Ref: 16/03315/FULL1), for the following reasons: The area in Pines Road is already congested with parking for Bickley station. Woodlands Road as you will be aware is unadopted by the council, and is maintained at the residents’ expense. It is inevitable that if the school is built on the proposed site that Woodlands will become a “cut through” for the increased traffic. Chislehurst Road is unsuitable for the school entrance and it is likely that there would be a bottleneck for traffic at the mini roundabout. this will cause considerable inconvenience to local residents. Increased traffic is also a safety concern for local residents and children. The Mayor of London has noted that the partial loss of playing fields and Urban Open Space is a major concern with the proposed development. The current planning application has clearly shown that the St Hugh’s Playing Fields is not a suitable site for a new school. Other suitable sites need to be urgently considered. DRAFT POLICY 56 – LOCAL GREEN SPACE St Hugh’s Playing Fields provide much needed green space to the local community, and as such we think it should be designated as Local Green Space in the Local Plan.

75

Representation no.

DLP146_1


Housing Allocation Site 2 – Land adjacent to Bromley North Station

Format Email Full Name David Sterling Organisation

76

I am writing to register my objection to the proposed plan to build 525 residential units around Bromley North Station.

The grounds for my opposition to the proposed development are as follows:

1. If planning permission is granted, the development will increase thepopulation of Bromley North Village by approximately one thousand residents.This will change the local dynamic from being one of a relaxed family-friendlyvillage – where visitors and local residents can socialise, shop and enjoy thetranquil environment together – to that of a busy metropolis that is ill-equippedto meet the environmental, medical, educational, social, welfare anddevelopmental needs of the local community.

2. The development will be unsightly and overbearing on the existingresidences, thereby making the locality a less desirable place to live.

3. The current infrastructure of the local area (i.e., transport, parking, medicalfacilities and schools etc.,) cannot withstand an increase of one thousandresidents, concentrated in such a small area. This will significantly reduce thequality of life for the current, and the future residents, of Bromley NorthVillage.

4. The proposed development also does not respect the Grade II status of thelocal Railway Station and the adjacent Conservation Area.

The overall detrimental impact of the proposed development, referred to above, threatens to undo all the hard work that the London Borough of Bromley, and the local residents, have put into making Bromley North Village a quality place to live and to do business.

77

Representation no.

DLP126_1


Draft Policy 56 - Local Green Space

Format Email Full Name Daniel Miller Organisation Shortlands Residents Association

78



Ms Mary Manuel Head of Planning Strategy and Projects London Borough of Bromley Civic Centre Stockwell Close Bromley BR1 3UH 30 December 2016 By email and first class post Dear Ms Manuel Re: Shortlands Golf Course Designation as Local Green Space This is a letter of objection submitted on behalf of the committee and the members of the Shortlands Residents' Association. We have very recently been made aware of the decision of LBB not to designate Shortlands Golf Course as a Local Green Space (LGS). Our submission is that the Golf Course is vital, not only to its members, but to the local community as a whole and should be provided with the additional protection of LGS status. We therefore request that you revoke the decision not to recognise for designation. The original decision justified the refusal to recommend for designation on the basis that the site did not meet criteria 1, 4, 6 and 7 and it was unknown whether the site met criterion 8. Criterion 1: Support of the Local Community The grounds of rejection state that there was no further support from other more representative community groups in order to make a stronger case for designation. No evidence had been provided of support from local organisations or how members of those organisations would specifically enjoy the site's special qualities. The Local Plan Background Paper dealing with Local Green Space and dated September 2016 identifies the methodology for assessment against each criterion. We are a legally constituted local Residents' Association representing some 1000 households who are members of our Association. The committee is authorised by its members and its rules to make policy decisions on behalf of its members for the benefit of the community. Our committee has taken the decision that representation should be made by the Shortlands Residents' Association in support of the original proposal to have the Golf Course recognised as an LGS. All our members and, indeed, all residents of Shortlands and Bromley benefit from the retention of Shortlands Golf Course in its present form with a maximum protection possible against future development. Clearly, not all of our members will also be members of the Golf

79



Club but everybody in the community enjoys the benefit generated by having a green space virtually adjacent to Bromley Town Centre and the centre of Shortlands. This is not just a question of being able to walk through the Golf Course and to enjoy its trees, its shrubs, its woods and the wildlife in this special open space, but the healthy environment created for the community by having green space so close to a town centre. We know that Bromley is a polluted area. One wonders what the situation would be if we did not have the benefit of this green space? It would be a fair presumption that we would have a dangerously polluted area were it not for such green spaces as we now enjoy and protect. While we cannot deny that the members of the Golf Club would specifically enjoy the immediate benefits, in our view the space is of great benefit to the whole community in limiting the extent of development and adding to the healthiest environment which we might enjoy. To run any risk of damaging that environment is unacceptable so, in our view, this green space is vital to the whole community in order to avoid overdevelopment and damage to health. Criterion 4: the site proposed for designation is local in character and is not an extensive tract of land The Local Plan Background Paper referring to the site assessment against this criterion and the National Planning Policy Framework does not seek to define too rigidly how big a Local Green Space can be except to say that the blanket designation of open countryside adjacent to settlement will not be appropriate. ‘This should not be a new area of Green Belt by another name’. Paragraph 46 identifies some criteria for sites considered to meet criterion 4. These include that where facilities are not publicly accessible they are still considered to be local in character where they are, for example, demonstrably historically significant. This is most certainly the case for this Golf Course, believed to be established in the late 19th century as a women’s only golf course, something no doubt unique at that time. A further criterion is whether this provides a visible and important break in the urban form. The spread of the suburbs in the 1920s and 1930s were protected against excessive development because of the existence of this golf course. That remains the case today as development has surrounded this green space. As Bromley Town continues to develop and expand, perhaps upwards, then there needs to be a visible balance, as happens throughout London, between the developed and the protected for the benefit of all who live nearby. The fact that this is not an open park does not detract from its importance as a ‘lung’ for the community as a whole, local in character and a visible break between in the urban form. In the grounds of rejection there is reference to local residential properties. There are probably some 150 properties and therefore perhaps 300 people who immediately enjoy the benefits of views onto the golf course which we suggest they greatly appreciate, whether or not they are actually golfers. It would be a fundamental reason for living nearby, the fact that their gardens do overlook the course. Criterion 6: this space is demonstrably special to a local community and holds a particular local significance because of a special qualities relating to, for example, beauty, historic significance, recreational value, tranquillity or richness of wildlife.

80



The main ground of rejection is that no details have been provided how the case for beauty and quietness and the site’s function as a link are being enjoyed and how they are special. The Local Plan Background Paper refers to paragraph 77 of the National Planning Policy Framework. A number of categories such as beauty, historical significance, recreational value and tranquillity must be shown to be demonstrably special for the local community in at least one of these categories. The detail inevitably overlaps with other criteria. For example in dealing with beauty there must be a significant enhancement to the built environment. An open space alone would not be sufficient. There can be no doubt, as mentioned above in respect of criterion 4, that all immediate local residents living adjacent to the golf course would regard the tranquillity, trees and sculpted open space as being something of beauty in an otherwise urban or suburban environment. We have already mentioned above the historical importance of this golf course. While it is accepted that this is not a recreational area for everybody in the community, the demise or proposed demise of the golf course in Beckenham Place Park suggests that a nearby golfing facility must grow in importance. For those who, like the writer, frequently walk around the area of the golf course can be no doubt that this is a place of particular tranquility. Criterion 7: the special characteristics would not be protected through any other reasonable or more effective means As is stated in paragraph 76 of the Local Plan Background Paper, most of the borough is covered by planning designations and most of the sites nominated for LGS designation are to various degrees already protected by planning designations. It is acknowledged that the grounds of rejection refer to the existing levels of protection but given the importance of the Golf Club land the maximum protection should be provided consistent with the approach to green belt. Criterion 8: managing the site beyond the local plan period As is already stated it is not possible to know what the future will hold because of the private ownership of the club. This is a very strong reason for arguing that the maximum protection and therefore LGS status should be applied now. Yours faithfully Daniel Miller

81

Representation no.

DLP127


DLP127_1 Education Site 33 - St Hugh’s Playing Field DLP127_2 Draft Policy 29 - Education Site Allocations DLP127_3 Draft Policy 56 - Local Green Space

Format Email Full Name John Tiley Organisation

82

We live in Woodlands Road, Bickley, our house abutting Pines Road and very close to the St Hugh’s Playing Fields. We note that Bromley Council are requesting comments on the Draft Local Plan currently being considered and we have the following comments:- DRAFT POLICY 29 – EDUCATION SITE ALLOCATIONS In our view the St Hugh’s Playing Fields are not suitable for a new school and should be removed from the list of sites allocated for new education provision. There is already a planning application under consideration, submitted in July 2016 and subsequently, for the building of the new Bullers Wood School for Boys on this site (Planning Ref: 16/03315/FULL1). We have already lodged objections to this proposal as the site is totally inappropriate for the siting of a new school. Our objections centred around traffic congestion, major road safety issues to say nothing of the parking problems this will create in the area. There is little open space left in Bickley and the loss of this will impact adversely on the amenity enjoyed locally. We know that Sport England have already objected to the loss of existing playing fields which the building of the school will inevitably cause. We would question whether enough has been done to both identify the need for a new school of this size in the Borough. If this is so then more work should be done reviewing other opportunities to site a school including those included in the Education Background Paper (Autumn 2016) to identify a better alternative particularly one which will cause less traffic chaos and public danger than the approval of this proposal inevitably will. DRAFT POLICY 56 – LOCAL GREEN SPACE Much of Bickley is fully developed and there is little open space. We believe that the St Hugh’s Playing Fields should be added to the list of sites to be designated as Local Green Space in the Local Plan. Please acknowledge safe receipt of this e-mail.

83

Representation no.

DLP128_1


Housing mixed use allocation Site 10 - West of Bromley High Street and land at Bromley South

Format Online Full Name Davina Misroch Organisation Do you have any concerns about legal compliance?


I do not think that this part of the Local Plan is 'sound' because: - it has an unacceptable impact on the town centre's local character, and - would be in conflict with the heritage, historical value and open spaces which are the town's most valuable assets. - the plan is unsound because it is in conflict with its own draft policies within the Local Plan and that within the National Planning Policy Framework - there is insufficient evidence to justify this proposal with respect to sufficient local open space and play areas, - sufficient provision for local schools, - clear and irreversible impact on the Conservation Area, and - completely unjustified loss of existing housing particularly that in Ethelbert Close.



Yes. As a resident and owner of a property in Ethelbert Close, I consider this to be extremely important to have an opportunity to voice concerns about what happens in the town centre and on Site 10 in particular. I also have great concern as to how the Local Plan will impact the environment in a whole sense, in the Conservation Area and in the wider area.

84

Representation no.

DLP129_1



Format Online Full Name Maria Martinez Organisation Do you have any concerns about legal compliance?






No.

85

Representation no.

DLP130_1


Education allocation - Site 36 Land at Bushell Way, Chislehurst

Format Online Full Name Andrew Pope Organisation Do you have any concerns about legal compliance?

This drafted 'allocation' is not compliant with the provisions of NPPF Chapter 11. This entry - Site 36 - should be deleted from App 10.4. The drafting of Site 36 Land at Bushell Way Chislehurst is nor compliant with NPPF Chapter 11. It's drafted use for 'education purposes' is not justified or needed. This entry (Site 36) should be deleted from the draft Local Plan.


All of this ground should remain Local Green Space. It is (all) important natural urban green infrastructure and should remain so. The drafted allocation is contrary to the environmental provisions of NPPF Chapter 11. I do not consider that this significant piece of Walden Wood should be destroyed; it performs a valuable service to the public as it is. This ground - Site 36 - is important natural Local Green Space and should remain as that. I do not want to see this significant part of Walden Wood destroyed. This drafted entry (Site 36) is unsound. This ground is attractive natural green infrastructure and should remain in its present form. The ground fulfils an important public function as it is. Use for would-be education purposes is unjustified and un-needed.



No.

86

Representation no.

DLP131


DLP131_1 - Draft Policy 27 - Education DLP131_2 - Education allocation Site 33 – St.Hugh’s Playing Fields DLP131_3 – Draft Policy 28 – Educational facilities DLP131_4 – Draft Policy 55 – Urban Open Space

Format Online Full Name Gillian Bailey Organisation Do you have any concerns about legal compliance?


St. Hugh’s playing fields In addition to loss of Open Space, objections to this application in the Schedule of consultation responses include traffic, parking, road safety and loss of playing fields. Although the proposed allocation was at that stage maintained it was recognised that more detailed examination was required, major implications remained to be assessed at planning application stage. If the issues could not be satisfactorily resolved then the inference was that the allocation would be abandoned. A planning application for a large boy’s secondary school has been submitted in July 2016, many objections have been made and detailed examination of the proposal clearly shows that the site is not suitable for this purpose and the negative impact on the locality and its residents unacceptable. The need for the level of additional secondary school capacity is disputed. Whatever the eventual outcome of the “need” issue this site is not suitable. Its unsuitability is not just its impact on the neighbourhood but it will be a “bad product”. A major issue is the size of the site: - there is a loss of playing fields but what is left will be used not only by the 900 boys at the new school but also by 1,500 Bullers Wood Girls and 6th form boys. The assessments seem to overlook the fact that the existing use will not cease. Traffic and road safety issues are as pertinent for the pupils and their parents as the local residents, a school should not be sited on what is effectively an island with major frontages to two busy roads (one of the busiest in Bromley). When looking for school sites a in the Borough, green belt and MOL sites should be given proper consideration and not dismissed simply because of these designations. This is particularly so in a Borough that has as much open space on the fringe of the urban area as Bromley but strict adherence to these designations is forcing consideration of an inappropriate site in an area of open space deficiency within the urban area . It is necessary to “think outside the box”.

87

This site does not work for a secondary school neither for the pupils nor the local residents. Retention of the proposed secondary school allocation on this site is not justified nor is it consistent with national sustainable development policy. A plan with this allocation will not be sound.



Yes. There are moving situations with many potential variables by end of 2017. I would like the opportunity to address the then current situation

88

Representation no.

DLP132_1


Housing mixed use Site 2 – Land adjacent to Bromley North

Format Online Full Name Andrew Howcroft Organisation Do you have any concerns about legal compliance?


Regarding Bromley North site: As a local resident who lives in Glebe Road I would like to voice my option on the plan to redevelop the site by Bromley North. Any new housing should fit into the feel and character of the local Victorian streets. However, one of my biggest concerns is that Bromley North must be almost unique in London in that it has the opportunity to expand an existing transport hub to support the local residences and business. To throw away this opportunity to expand the transport links to and from Bromley with a clumsy short sighted redevelopment would be criminal. As with any new development into existing infrastructure consideration must be given that there are facilities to support the new residence. As a current resident my son got into his third choice school. I rarely get to park on our road (Glebe Road) and it is difficult to get an appointment with a Doctor or Dentist. All these facilities need to be upgraded to support an additional demands that will be put on them. Please take great care and consideration when redeveloping the Bromley North site.



89

Representation no.

DLP133_1


Draft Policy 29 – Education Site Allocations

Format Online Full Name Philippa Loades Organisation Do you have any concerns about legal compliance?


it is more appropriate to seek to increase school places by expanding existing school sites; it is not an appropriate strategy to seek to build new schools on unsuitable sites and locations for example Eden Park High School in Balmoral Avenue. It would seem reasonable to expect Bromley Borough schools to only have students from the borough rather than having places taken by those living in Croydon and Lewisham boroughs, which means Bromley has to find more places for its own residents!



No.

90

Representation no.



DLP134_1 Section 1.2 – About the Local Plan DLP134_2 Section 1.3 – Visions and Objectives DLP134_3 Section 1.4 – Spatial Strategy DLP134_4 Draft Policy 1 – Housing Supply DLP134_5 Draft Policy 13 – Renewal Areas DLP134_6 Draft Policy 30 – Parking DLP134_7 Draft Policy 50 – Metropolitan Open Land DLP134_8 Draft Policy 35 – Transport Investment Priorities


91

Representation no.

DLP134_1


Section 1.2 About the Local Plan

Format Online Full Name Chris Francis Organisation West and Partners for Dylon 2 Ltd Do you have any concerns about legal compliance?





No.

92

Representation no.

DLP134_2








No.

93

Representation no.

DLP134_3




1. The Draft Plan fails to correctly assess and address Objectively Assessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of Nathaniel Lichfield & Partners (NLP) dated 28 Dec 2016) and is therefore not in conformity with the NPPF and accordingly fails this requirement. 2. The Draft Plan fails to identify the area of Lower Sydenham, as a Renewal Area. This is an area which, together with the neighbouring wards in the London Borough of Lewisham, from a socio-economic perspective performs less well against a range of economic, deprivation and housing indicators than LBB averages and as such should be a focus for renewal and improvement. The Draft Plan is not therefore in conformity with the requirements of Policy 2.6; 2.7 and 2.8 of the London and accordingly fails this requirement.


1. The Draft Plan fails to correctly assess and address Objectively Assessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of NLP dated 28 Dec 2016) and is therefore not in conformity with the requirements of the NPPF and is not sound. 2. The Draft Plan fails to embrace a review of the boundaries and condition of existing designated MOL in compliance with the provisions of Policy 7.17 D of the London Plan and thereby contributes to the failure to address the OAN and make correct and sound provision of a 5YHLS for the reasons set out in the NLP letter of 28 Dec 2016. Accordingly, the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound 3. The Draft Plan fails to identify the area of Lower Sydenham, as a Renewal Area. This is an area which, together with the neighbouring wards in the London Borough of Lewisham, from a socio-economic perspective performs less well against a range of economic, deprivation and housing indicators than LBB averages and as such should be a focus for renewal and improvement. Accordingly, the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound




No.

94


95

Representation no.

DLP134_4


Policy 1 Housing Supply


1. The Draft Plan fails to correctly assess and address Objectively Assessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of Nathaniel Lichfield & Partners (NLP) dated 28 Dec 2016) and is therefore not in conformity with the NPPF and accordingly fails this requirement. 2. Draft Policy 1 fails to include any provisions which seek to exceed the current target set by the London Plan, as is required by Policy 3.3 D and Da the latter of which states "Boroughs should draw on the housing benchmarks in table 3.1 in developing their LDF housing targets, augmented where possible with extra housing capacity to close the gap between identified housing need (see Policy 3.8) and supply in line with the requirement of the NPPF" It is therefore not in conformity with this requirement of the London Plan and not legally compliant.


1. The Draft Plan fails to correctly assess and address Objectively Assessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of NLP dated 28 Dec 2016) and is therefore not in conformity with the requirements of the NPPF and is not sound. 2. Draft Policy 1 fails to seeks to meet objectively assessed development and infrastructure requirements, as it lacks any provisions which seek to materially and significantly exceed the current housing supply target set by the London Plan, as is required by Policy 3.3 D and Da the latter of which states "Boroughs should draw on the housing benchmarks in table 3.1 in developing their LDF housing targets, augmented where possible with extra housing capacity to close the gap between identified housing need (see Policy 3.8) and supply in line with the requirement of the NPPF" It is therefore not sound. 3. The Draft Plan, generally and Draft Policy 1 fail to have proper and proportionate regard to the clear indications in the direction of travel of government of the need to take every opportunity to provide for the delivery of new housing to meet identified need. In particular, no provision for increasing density within the vicinity of commuter hubs and on previous developed land; including such land in the Green Belt and MOL; is provided for. The Draft Plan therefore fails to seeks to meet objectively assessed development and infrastructure requirements and is not sound. 4. The Draft Plan fails to identify, as an allocated residential development site, the land forming part of the former Dylon International Premises site off Station Approach, site at Lower Sydenham. In August 2016 the principle of a scheme for the residential redevelopment of the brown field elements of this site was in effect endorsed by an Inspector appointed by the Secretary of

96

State. This justifies the inclusion of the site as an allocated housing site as it can and will make a meaningful contribution to the objectively assessed housing needs of the borough within the early years of the Plan period. The omission of the site means that the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound.




97





14 Regent's Wharf All Saints Street London N1 9RL 020 7837 4477 [email protected] nlpplanning.com


Dear Sir / Madam






Summary Soundness Review We find that, in terms of housing need and supply:



98

P2/7 13000303v3










Housing Need

NPPF Requirements




99

P3/7 13000303v3

London and LBB OAN












100

P4/7 13000303v3






Lapse Rates











significant deficit in the 5 year supply.” – i.e. a c.33% lapse rate. 1 Appeal decision APP/G5180/A/07/2043219 dated 22 November 2007

101

P5/7 13000303v3








Windfall Sites







We do not consider a number of sites identified in the DBLP meet the NPPF footnote 11 definition of a deliverable site such that they are deliverable in the first five year period. The PPG also adds clarity to what constitutes a ‘deliverable site’ in respect of suitability, availability and achievability as follows: 2 Appeal decision APP/G5180/A/08/2088139 dated11 May 2009 3 Appeal decision APP/G5180/W/16/3144248 dated 2 August 2016

102

P6/7 13000303v3







Conclusions


103

P7/7 13000303v3







Yours sincerely


104

Representation no.

DLP134_5










No.

105

Representation no.

DLP134_6









No.

106

Representation no.

DLP134_7


Draft Policy 50 - Metropolitan Open Land






No.

107

Representation no.

DLP134_8


Draft Policy 35 - Transport Investment Priorities



The draft plan fails to objectively assess the potential extension of the Bakerloo Line, which currently terminates at Elephant and Castle. In their ‘Options Assessment Report’, published in December 2015, TfL detail a proposed option to provide an extension of the line to Hayes (Kent) and Beckenham Junction. This option consists of a tunnelled extension to Lewisham via Old Kent Road with the line extension, beyond Lewisham, replacing existing national rail services to Hayes. If implemented, services would call at Lower Sydenham, New Beckenham, Clock House, Elmers End, Eden Park, West Wickham and Hayes with a spur to Beckenham Junction: all within the borough which the Council acknowledges is not well served with a lack of an Underground and an extensive Overground network and unacceptable crowded train services to Central London. It is anticipated that the extended Bakerloo line could provide up to 27 trains per hour to Catford Bridge with 15 trains per hour continuing south to Hayes, and a further 6 trains per hour to Beckenham Junction. This leads to the potential for 21 trains per hour operating south of Catford Bridge serving the boroughs current and future resident population. TfL’s Option Selection Summary Report (Dec 2015) notes that there could be significant additional benefits from an extension beyond Lewisham and that further work is required to develop the deliverability and case. The Council is therefore wrong to fail to support this potential to bring forward a significant increase in journey frequency, and the associated added connectivity. Accordingly the Council has failed to positively prepare to meet objectively assessed development and infrastructure requirements which it should have reasonably done in order to address the need to achieve sustainable development and the Draft Plan is therefore not sound.




108

Representation no.



DLP135_1 Section 1.2 – About the Local Plan DLP135_2 Section 1.3 – Visions and Objectives DLP135_3 Section 1.4 – Spatial Strategy DLP135_4 Draft Policy 1 – Housing Supply DLP135_5 Draft Policy 13 – Renewal Areas DLP135_6 Draft Policy 30 – Parking DLP135_7 Draft Policy 35 – Transport Investment Priorities DLP135_8 Draft Policy 50 – Metropolitan Open Land


109

Representation no.

DLP135_1


Section 1.2 - About the Local Plan

Format Online Full Name Chris Francis Organisation West and Partners for Relta Ltd Do you have any concerns about legal compliance?





No.

110

Representation no.

DLP135_2








No.

111

Representation no.

DLP135_3



Format Online Full Name Chris Francis Organisation West and Partners for Delta Ltd Do you have any concerns about legal compliance?

1. The Draft Plan fails to correctly assess and address Objectively Assessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of Nathaniel Lichfield & Partners (NLP) dated 28 Dec 2016) and is therefore not in conformity with the NPPF and accordingly fails this requirement. 2. The Draft Plan fails to identify the area of Lower Sydenham, as a Renewal Area. This is an area which, together with the neighbouring wards in the London Borough of Lewisham, from a socio-economic perspective performs less well against a range of economic, deprivation and housing indicators than LBB averages and as such should be a focus for renewal and improvement. The Draft Plan is not therefore in conformity with the requirements of Policy 2.6; 2.7 and 2.8 of the London and accordingly fails this requirement.


1. The Draft Plan fails to correctly assess and address Objectively Assessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of NLP dated 28 Dec 2016) and is therefore not in conformity with the requirements of the NPPF and is not sound. 2. The Draft Plan fails to embrace a review of the boundaries and condition of existing designated MOL in compliance with the provisions of Policy 7.17 D of the London Plan and thereby contributes to the failure to address the OAN and make correct and sound provision of a 5YHLS for the reasons set out in the NLP letter of 28 Dec 2016. Accordingly, the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound 3. The Draft Plan fails to identify the area of Lower Sydenham, as a Renewal Area. This is an area which, together with the neighbouring wards in the London Borough of Lewisham, from a socio-economic perspective performs less well against a range of economic, deprivation and housing indicators than LBB averages and as such should be a focus for renewal and improvement. Accordingly, the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound




Yes. In order to fully address the issues and test the Councils approach to its assessment of the Spatial Strategy and Housing

112


delivery.

113

Representation no.

DLP135_4


Draft Policy 1 Housing Supply

Format Online Full Name Chis Francis Organisation West and Partners for Relta Ltd Do you have any concerns about legal compliance?

1. The Draft Plan fails to correctly assess and address Objectively Assessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of Nathaniel Lichfield & Partners (NLP) dated 28 Dec 2016) and is therefore not in conformity with the NPPF and accordingly fails this requirement. 2. Draft Policy 1 fails to include any provisions which seek to exceed the current target set by the London Plan, as is required by Policy 3.3 D and Da the latter of which states "Boroughs should draw on the housing benchmarks in table 3.1 in developing their LDF housing targets, augmented where possible with extra housing capacity to close the gap between identified housing need (see Policy 3.8) and supply in line with the requirement of the NPPF" It is therefore not in conformity with this requirement of the London Plan and not legally compliant.


1. The Draft Plan fails to correctly assess and address Objectively Assessed Housing Needs including failure to address Affordable Housing needs (as set out in detail in the letter of NLP dated 28 Dec 2016) and is therefore not in conformity with the requirements of the NPPF and is not sound. 2. Draft Policy 1 fails to seeks to meet objectively assessed development and infrastructure requirements, as it lacks any provisions which seek to materially and significantly exceed the current housing supply target set by the London Plan, as is required by Policy 3.3 D and Da the latter of which states "Boroughs should draw on the housing benchmarks in table 3.1 in developing their LDF housing targets, augmented where possible with extra housing capacity to close the gap between identified housing need (see Policy 3.8) and supply in line with the requirement of the NPPF" It is therefore not sound. 3. The Draft Plan, generally and Draft Policy 1 fail to have proper and proportionate regard to the clear indications in the direction of travel of government of the need to take every opportunity to provide for the delivery of new housing to meet identified need. In particular, no provision for increasing density within the vicinity of commuter hubs and on previous developed land; including such land in the Green Belt and MOL; is provided for. The Draft Plan therefore fails to seeks to meet objectively assessed development and infrastructure requirements and is not sound. 4. The Draft Plan fails to identify, as an allocated residential development site, the land forming part of the former Dylon

114

International Premises site off Station Approach, site at Lower Sydenham. In August 2016 the principle of a scheme for the residential redevelopment of the brown field elements of this site was in effect endorsed by an Inspector appointed by the Secretary of State. This justifies the inclusion of the site as an allocated housing site as it can and will make a meaningful contribution to the objectively assessed housing needs of the borough within the early years of the Plan period. The omission of the site means that the Draft Plan fails to meet objectively assessed development and infrastructure requirements and is not sound.




115





14 Regent's Wharf All Saints Street London N1 9RL 020 7837 4477 [email protected] nlpplanning.com


Dear Sir / Madam






Summary Soundness Review We find that, in terms of housing need and supply:



116

P2/7 13000303v3










Housing Need

NPPF Requirements




117

P3/7 13000303v3

London and LBB OAN












118

P4/7 13000303v3






Lapse Rates











significant deficit in the 5 year supply.” – i.e. a c.33% lapse rate. 1 Appeal decision APP/G5180/A/07/2043219 dated 22 November 2007

119

P5/7 13000303v3








Windfall Sites







We do not consider a number of sites identified in the DBLP meet the NPPF footnote 11 definition of a deliverable site such that they are deliverable in the first five year period. The PPG also adds clarity to what constitutes a ‘deliverable site’ in respect of suitability, availability and achievability as follows: 2 Appeal decision APP/G5180/A/08/2088139 dated11 May 2009 3 Appeal decision APP/G5180/W/16/3144248 dated 2 August 2016

120

P6/7 13000303v3







Conclusions


121

P7/7 13000303v3







Yours sincerely


122

Representation no.

DLP135_5











123

Representation no.

DLP135_6










124

Representation no.

DLP135_7


Draft Policy 35 Transport Investment Priorities



The draft plan fails to objectively assess the potential extension of the Bakerloo Line, which currently terminates at Elephant and Castle. In their ‘Options Assessment Report’, published in December 2015, TfL detail a proposed option to provide an extension of the line to Hayes (Kent) and Beckenham Junction. This option consists of a tunnelled extension to Lewisham via Old Kent Road with the line extension, beyond Lewisham, replacing existing national rail services to Hayes. If implemented, services would call at Lower Sydenham, New Beckenham, Clock House, Elmers End, Eden Park, West Wickham and Hayes with a spur to Beckenham Junction: all within the borough which the Council acknowledges is not well served with a lack of an Underground and an extensive Overground network and unacceptable crowded train services to Central London. It is anticipated that the extended Bakerloo line could provide up to 27 trains per hour to Catford Bridge with 15 trains per hour continuing south to Hayes, and a further 6 trains per hour to Beckenham Junction. This leads to the potential for 21 trains per hour operating south of Catford Bridge serving the boroughs current and future resident population. TfL’s Option Selection Summary Report (Dec 2015) notes that there could be significant additional benefits from an extension beyond Lewisham and that further work is required to develop the deliverability and case. The Council is therefore wrong to fail to support this potential to bring forward a significant increase in journey frequency, and the associated added connectivity. Accordingly the Council has failed to positively prepare to meet objectively assessed development and infrastructure requirements which it should have reasonably done in order to address the need to achieve sustainable development and the Draft Plan is therefore not sound.




125

Representation no.

DLP135_8


Draft Policy 50 Metropolitan Open Land







126

Representation no.

DLP136_1


Housing mixed use allocation Site 2 – Land adjacent to Bromley North Station

Format Online Full Name Matt Walker Organisation Do you have any concerns about legal compliance?

Whether this matter is legally compliant I cannot judge, nor whether I am completing the correct area of the form which I would suggest is a deliberate action to prevent comment from concerned residents. In relation to the development situated at Bromley North I would first echo the comments and points raised by the BRRA. I fail to see how the proposed development can reasonably be deemed suitable and in character with the current local area. The addition of such a large quantity of housing will pose serious issues for all residents in relation to parking, access to facilities such as doctor’s surgeries / schools which will not be increased in line with the population. LBB and its councillors clearly have no regard for the wellbeing of its residents as demonstrated by the current development at Bromley south. As the council itself previously objected to developments at BN site it will be interesting to learn why there position has changed. Whilst the end result will affect all who reside nearby the disruption / noise pollution such an extensive development will create will also be intolerable.




No.

127

Representation no.

DLP137


DLP137_1 Housing Mixed-Use Site 13 – Banbury House, Chislehurst DLP137_2 Education Allocation Site 36 – Land at Bushell Way, Chislehurst

Format Online and Email Full Name Anthony Johnson Organisation Bushell Way Residents Association

128

Representation no.

DLP137_1


Housing mixed use allocation Site 13 Banbury House, Bushell Way, Chislehurst

Format Online and email Full Name Anthony Johnson Organisation Bushell Way Residents Association Do you have any concerns about legal compliance?


I would like to be reassured that the impact of this development on local highway safety has been considered. In particular the junction of Bushell Way with White Horse Hill is perceived by local residents as dangerous and anecdotally there have been casualties including deaths due to road traffic accidents. The additional traffic caused by a further 25 dwellings (and by the proposed school at the end of Bushell Way) would considerably increase the movements from Bushell Way out onto White Horse Hill where despite traffic calming measures traffic often appears unexpectedly from behind parked cars. I suggest that this could be mitigated by (a) extending no parking restrictions on White Horse Hill either side of the junction to improve sight lines (b) offering parking space on the Banbury House site to residents on White Horse Hill without off-road parking (c) using the Banbury House site for low car use accommodation such as a care home. I note that a care home was demolished to allow Stead Close and the adjoining properties on Bushell Way to be built, and there is a growing need for more such accommodation, so a quid pro quo would be for the Banbury House site to be designated for this use in the local plan, rather than for housing. If the site is designated for housing, at 25 dwellings the density would be unacceptably high compared with adjoining sites in the Bushell Way neighbourhood.


TThe Council may not be aware of the Bushell Way Residents Association (BWRA), which is a management company responsible for the management of Stead Close and some aspects of services to 2-2e Bushell Way. It is controlled by the residents who request that the Council cooperate with BWRA on issues regarding the local plan and its implementation.


129

Representation no.

DLP137_2



Format Online and email Full Name Anthony Johnson Organisation Bushell Way Residents Association Do you have any concerns about legal compliance?


I note that previous concerns about maintaining biodiversity on this site, and the need to maintain a public right of way past it to Walden Woods have been acknowledged. However it is not clear that the impact of this development on local highway safety has been considered. In particular the junction of Bushell Way with White Horse Hill is perceived by local residents as dangerous and anecdotally there have been casualties including deaths due to road traffic accidents. The additional traffic caused by the proposed school at the end of Bushell Way (and 25 dwellings on the Banbury House site) would considerably increase the movements from Bushell Way out onto White Horse Hill where despite traffic calming measures traffic often appears unexpectedly from behind parked cars. I suggest that this could be mitigated by (a) extending no parking restrictions on White Horse Hill either side of the junction to improve sight lines (b) offering parking space on the Banbury House site to residents on White Horse Hill without off-road parking (c) introducing a mini-roundabout or traffic signals at the junction. Within Bushell Way there is already a problem with inconsiderate car parking, and the "school run" is notorious for adding to this in other areas. This could only be mitigated by stricter parking restrictions for non-residents and assiduous policing of such restrictions. If these traffic control measures cannot be introduced then the re-designation from UOS to educational use should not be sanctioned in the local plan. In view of the likelihood of more impermeable surfaces being introduced, it would be good to be reassured that sustainable drainage measures would be mandatory to prevent run-off under storm conditions into adjoining areas.


The Council may not be aware of the Bushell Way Residents Association (BWRA), which is a management company responsible for the management of Stead Close and some aspects of services to 2-2e Bushell Way. It is controlled by the residents who request that the Council cooperate with BWRA on issues regarding the local plan and its implementation.

130


131

Representation no.

DLP138


Draft Policy 1 – Housing Supply Draft Policy 2 – Affordable Housing Draft Policy 11 – Specialist and Older Peoples Accommodation

Format Email Full Name Andy Black Organisation PRP for CALA Homes

132

30 December 2016

Dear Sir / Madam

By Email/Post AT6551-6.03/001/ab [email protected] 7653 1427

Planning Strategy and Projects Team London Borough of Bromley Civic Centre Stockwell Close Bromley BR1 3UH

Consultation on the Proposed Submission Draft Local Plan - December 2016

I write in response to the consultation on the proposed submission draft local plan under Regulation 19 of the Town and Country Planning (Local Planning) Regulations 2012. PRP acts as agent on behalf of CALA Homes (South Homes Counties) Limited specifically in relation to the Langley Court site in Beckenham.

As you may be aware, outline planning permission for residential development of the site (Ref: PA/12/00976/OUT) was granted on the Langley Court site by London Borough of Bromley in June 2014. The application comprised up to 179 new homes of which up to 79 were affordable, 629sqm of Class D1 (Non-residential institution), and up to 1,040sqm of Class D2 (Assembly and Leisure).

In the draft Local Plan, the extant planning permission is noted in the Housing Trajectory (10.1) as providing 179 dwellings (page 255) to be developed in the period up to 2020.

This letter makes representation on a number of specific policies within the draft local plan.

Duty to cooperate and Strategic Planning

The provisions within the draft plan at para 1.2.9 in relation to the statutory duty to cooperate are noted. The Council will be aware that the Policy 2.2 E within the London Plan requires all London Boroughs, particularly those in outer London such as Bromley, to work with all authorities and agencies in neighbouring regions both inside and outside Greater London to develop common approaches to issues of cross-border significance.

The NPPF also requires boroughs to cooperate on planning issues that cross administrative boundaries, particularly those that relate to those strategic priorities set out in paragraph 156 of the Framework. This includes planning for homes and jobs in the area.

133

mailto:[email protected]

Paragraph 179 of the framework states that local planning authorities should work collaboratively with other bodies to ensure that strategic priorities across local boundaries are properly coordinated and clearly reflected in individual local plans.

Paragraph 181 of the framework specifically states: Local planning authorities will be expected to demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts when their Local Plans are submitted for examination. This could be by way of plans or policies prepared as part of a joint committee, a memorandum of understanding or a jointly prepared strategy which is presented as evidence of an agreed position.

Whilst it is acknowledged that there has been discussion with other London Boroughs, it remains unclear from the draft plan of how the policies have been shaped as a result of this. Several of the housing renewal areas cross into neighbouring planning authorities and there is no detail in the housing policies to explain how the housing numbers are to be allocated between the neighbouring authorities in order to avoid double counting.

Overall, other than statements contained within the supporting text for individual policies setting out that the duty to co-operate has been met, no supporting evidence has been submitted alongside the plan which would clearly demonstrate that this has been achieved or carried out to a satisfactory level which would lead to the plan being found sound.

Housing Need

The London Plan treats London as a single HMA and undertakes a single assessment of objective housing need on behalf of all the London boroughs within the SHMA published in 2013. It is established that the full OAN for London is 49,000 dpa for the period of time of 2015-2025 as covered by the London Plan. It is held by many that the actual OAN may be as high as 62,000 dpa. Nevertheless the actual housing needs of London will only ever be addressed if 49,000 dpa is provided every year for the next 21 years – 2015- 2036. The Mayor has been very clear within the London Plan that this figure should be regarded as a minimum (paragraph 3.16b).

It is common ground amongst the GLA and London Boroughs that there is an under delivery from the current London Plan of 7,000 dwellings per annum against the full objectively assessed need (an assessed capacity of 42,000 against a full OAN of 49,000). Many of the plans produced in draft form or fully adopted by London Boroughs since the London Plan was adopted have also shown that the gap between OAN and actually capacity remains in place. Bromley is one of a number of London Boroughs which has produced a draft plan which will only match the London Plan baseline of 641 dpa and goes no further to close the gap.

Paragraph 2.1.4 of the draft plan states a housing supply of 641 dpa for a total of 10 years between 2015/16 - 2024/25 but this is only actually 9 financial years. This is assumed to be an error and the council did in fact mean 2025/26.

It is clear that the Council has done the minimum necessary to be in conformity with the London Plan. Bromley has not shown through the draft plan that it has done anything to close the gap between demand and supply within London This does not reflect the way in which the NPPF was written with the firm instruction to local authorities to “boost significantly the supply of housing”.


134

In preparing the new local plan it is expected that a new Strategic Housing Market Assessment would be published to establish the local objectively assessed need but this has not been done. The last SHMA which was produced was published in 2014 and this is now considered to be dated but in any event this has not been included within the evidence base documentation which accompanies the new draft plan. However the SHMA is referred to in paragraph 2.1.15 which states that:

A SHMA for the South-East London sub region was finalised in June 2014 and estimates an annual housing requirement across the sub region of 7188 units and a net annual need for 5000 affordable units. The net additional dwelling requirement for Bromley per annum was estimated at approximately 1320 units. Across the sub-region annual capacity targets identified within the 2013 SHLAA reach 7893 units. GLA household projections in 2014 estimate an annual short term variant of 1840 households per annum for the Borough and a long term variant of 1530 households per annum.

The figure of 1,320 dwellings per annum is higher that the London Plan monitoring figure yet the plan shows little acknowledgement of the need to address this higher requirement.

Housing Supply

Table 1 on page 29 of the plan shows a land supply to accommodate 7,259 homes over the plan period. The minimum number of homes necessary to meet Bromley’s requirement is 6,410 and Table 1 therefore implies that an additional 849 homes would be supplied over the minimum requirement. It is therefore unclear whether the council considers the plan requirement as 726dpa (7,259 divided by 10) or if this is considered as an oversupply to reflect housing need. .

In any event this is a very small increase in supply above the total unmet need with a potential contribution of just 85 dwellings per annum compared to an undersupply across London of 7,000 dwellings per annum.

Most local planning authorities elsewhere in England apply a slippage rate to any housing trajectory which accounts for non-implementation of planning permissions. Camden Council allows for a figure of 10% within its adopted plan and if this figure were applied to the housing trajectory for Bromley then it would equate to almost the entire 849 dwelling oversupply rendering this irrelevant and highlights the minimum approach taken by the council towards housing supply.

From the housing trajectory it is clear that council is reliant on small sites (effectively windfall sites) for providing more than half of the overall housing target. There is little certainty that these sites will actually materialise and do not have the same assurance of delivery as larger allocated sites.

Paragraph 2.1.21 sets out that the council will seek to "bring forward other policy compliant larger sites if the small sites rate is too low” and that these other sites would take the form of large windfall sites. If there are other large policy compliant sites which exist in the borough then these should be identified within the plan in order to boost supply above minimum figure of 641 dpa. There is also no evidence within the plan of what the council would consider to be the definition of the rate of delivery from small sites as being "too low".


135

Appendix 10.1 of the draft plan identifies Langley Court as having planning for 179 dwellings. This is one of the larger sites within the housing trajectory with delivery identified for 1-5 years within the plan period. Within draft policy 1 there is no objective to increase the density and housing supply from sites already benefiting from planning permission and not yet started as is the case with Langley Court.

A detailed study of the site demonstrates that a planning application could be brought forward which increases the density on the site to 251 units including an increase in affordable housing. In addition a 100 bed care home. It is therefore submitted that sites with the benefit of an existing outline planning permission, which have not yet been implemented should be reconsidered to establish if an increase in density and unit numbers can be achieved without a detrimental impact on character of the area or other material planning considerations. It is clear from the current draft local plan that this exercise has not been carried out and as such the strategy under delivers on the potential to significantly boost the supply of housing as directed by the framework.

Draft Policy 11 deals with Specialist Housing and Older Peoples Accommodation and the inclusion of this policy within the draft plan is supported. However the policy makes it clear that provision of older peoples housing is only supported where they are "conveniently located for a range of local shops, services and public transport appropriate to the mobility of the residents". This element of the policy is not supported and there is no justification to place this level of restriction upon the provision of specialist housing when such a policy is not applied to the provision of general needs housing.

Furthermore the policy places the emphasis on the applicant to justify demand for such housing and it is submitted that the council has done nothing to quantify this demand as evidenced within a number of other assessments for London and the closer sub region. It is suggested that the council should assess the need for care and provision of older peoples housing as part of its obligation under the Care Act and sites which have the potential to supply specialist housing of differing tenures should be specifically identified.

Provision of Affordable Housing

Paragraph 2.1.28 refers to the most recent SHMA for the South-East London region which was published in 2014. However this is not listed as an evidence base document accompanying the draft plan and it is therefore not possible to establish the exact need for affordable housing in Bromley based on accurate and up to date evidence.

The affordable housing target is set at 35% within the draft plan and this is based upon the Affordable Housing Viability Assessment Update produced in 2012. This report is considerably out of date and London Plan policies have moved on significantly since then. The new Local Plan must be supported by a more up to date assessment of viability which reflects updated design, construction standards and costs. The viability assessment also needs to take into account the associated costs for compliance with the Nationally Described Space Standards as required by draft policy 4 of the plan.

Draft policy 2 also requires 60% of units to be ‘social rent / affordable rent’, but the accompanying Viability Assessment only uses affordable rent to justify the affordable housing level at 35%. Using a social rent level would inevitably have a detrimental impact on the viability of a site and this is not reflected within the wording of this policy.

Furthermore the policy goes on to state that a departure from the required tenure split would be acceptable where it can be demonstrated that a lower level should be sought or


136

that the 60:40 split would not create mixed and balanced communities. However there is no explanation of what is meant by this within the amplification of this policy. Nor is there any guidance on the implementation of this element of the policy by the development management team as part of a planning application.

In its current form it is submitted that the 35% level of affordable housing and accompany 60:40 tenure split has not been adequately justified or based on robust and up to date evidence.

For the reasons set out within this submission there is concern that the council has not satisfied the statutory duty to cooperate and furthermore in its strategic plan making has done the bare minimum to meet a substantial undersupply within the borough and the wider London housing market area.

There are clearly opportunities to make the best use of previously consented sites which have not yet been implemented and these should be identified specifically within the draft plan.

It is therefore submitted on behalf of CALA Homes (South Home Counties) Limited that the plan cannot be found sound in its current form and further modifications are required prior to submission in advance of examination.

Yours Sincerely

Andy Black Director Planning


137

Representation no.

DLP139


Education Allocation Site 33 – St. Hugh’s Playing Field Draft Policy 29 – Education Site Allocations Draft Policy 56 – Local Green Space

Format Email Full Name Susan Savage Organisation

138

Draft Policies 28 (Education Facilities) and 29 (Education Site Allocations) The Draft Local Plan currently includes an allocation of the St Hugh’s Playing Fields in Bickley for new education provision. A planning application was submitted to Bromley’s Planning Department in July 2016 by Kier Construction for the construction of a new secondary school, Bullers Wood School for Boys, on this site (Bromley Planning Ref: DC/16/03315/FULL1). It is clear from looking at the proposals that the site is not suitable for a new school because of the significant negative local impacts. These include increased traffic, congestion and road safety hazards on the already busy local roads, loss of scarce open space in an Area of Open Space Deficiency and loss of valuable playing fields which Sport England has objected to. The current plans will also result in an unacceptable loss of residential amenity due to close proximity of the new school to the houses on Chislehurst Road in terms of disturbance, noise, light and loss of privacy. We and many other local residents have written to object to the planning application on the above grounds. The current planning application has clearly shown that the St Hugh’s Playing Fields is not a suitable site for a new school. We, therefore, consider that it should be removed from the list of sites allocated for educational use under Draft Policy 29. Bromley Council needs to be making a much greater effort to encourage the expansion of existing schools in Bromley to meet any future increase in demand for secondary school places and, if a new secondary school is still needed, it should undertake a more detailed examination of the other sites included in the Education Background Paper Autumn 2016 to identify one which is more suitable, particularly from a highways perspective. In particular, the Widmore Centre or the Bromley Civic Centre would appear to be much more suitable sites for a new secondary school. Importantly, using one of these local Brownfield sites would avoid the need to build on the limited green space in our area. Draft Policy 56 (Local Green Space) Given the particular value and significance of the St Hugh’s Playing Fields to the local community, we consider that it should be added to the list of sites to be designated as Local Green Space under Draft Policy 56. The St Hugh’s Playing Fields is a small, but valuable, green space in an Area of Open Space Deficiency and contains wildlife and trees subject to a blanket TPO. It acts as a green lung in an otherwise intensively developed area. As such, it represents a very important local amenity that should be protected.

139

Representation no.

DLP140_1


Housing Allocations Site 2 – Land adjacent to Bromley North Station

Format Email Full Name Morag Hughes Organisation

140

We wish to comment on the proposed “Proposed Submission Draft Local Plan” regarding LBB’s plans to develop 525 residential units around Bromley North Station. As your website is not particularly user-friendly, we have opted to send an email instead. We have lived in this area (Babbacombe Road then Holligrave Road) for over 30 years and are extremely concerned about this development, not least because of the lack of information that has been circulated to residents and those who work in the local area, although we understand that the minimum requirements have been met. Reasons for our concern include the following: Drainage: this is a fairly high density area of Victorian and Edwardian properties and drainage can already be a problem, particularly when there is heavy rain with flooding occurring at some drains in the road. Is there a plan to update this before a further 525 properties are introduced into the area? We have seen no mention of this in the Plan. Schools: the primary schools in the area are oversubscribed with the pupil population already set to increase. There are no secondary schools in the Bromley North area, with the nearest one being outside the Borough in Lewisham. What measures are being taken to ensure that the children moving into the 525 new properties will be allocated a place at a school, without a negative impact on children who already live in the area? Trains to and from Bromley North: since the through trains to London were stopped around 30 years ago, there has been no mention of reinstating these, although the numbers of people travelling has increased due to the large numbers of flats which have already been built in the area replacing individual houses. It can be very difficult to get on some of the rush hour trains at Sundridge Park (e.g. the 08.01 train) and crossing the footbridge at Grove Park can be extremely dangerous due to the volume of passengers. (Indeed there are no facilities for disabled access from Platform 1 at Grove Park so disabled passengers are effectively unable to use this route at present). The Plan talks about long-term aspirational schemes such as extending the DLR from Catford to Bromley South (NB the DLR does not currently serve Catford). Such schemes would take many years to be realised, so are there any concrete plans to serve the increase in commuter traffic which will undoubtedly be an outcome of the Plan? It is irresponsible to embark on this development without having firm assurances from transport providers that an already failing transport provision will be upgraded to meet the additional need. Car access to local homes during construction period: there is already limited access to the Babbacombe Road area due to the barrier across the railway bridge in Lansdowne Road and exit only from Cambridge Road on to Plaistow Green. It seems therefore that the only access to the construction site would be via Crescent Road, Florence Road (both of which are solely residential) or Mitchell Way. This would be very disruptive for the whole area. Parking: parking is already very difficult in this area, in particular for those residents who live in Station Road. This is exacerbated by the number of commercial white vans which are parked in the area on a daily basis, taking up the ‘free’ parking spaces. Although we have been told that those living in the 525 new properties will not have the right to parking permits, we have not been told where they do have the right to park. It is unrealistic to assume that none of the estimated 1,000 residents will be car owners. Tall buildings: we understand that the proposal includes 17-storey buildings. This is not in keeping with the other buildings in the area which, with the exception of Sherman House, are a maximum of 4 storeys. Building taller buildings will significantly alter the character of the area, which is adjacent to a conservation area and includes a listed building. It is not clear how this new development would preserve or enhance the setting, nor whether the new buildings will affect the right to light and privacy of those living close by.

141

Representation no.

DLP141_1



Format Email Full Name Joanne Smith Organisation

142

I would like to make my objection to the building on the site of Walden Woods. This has been kept very quite and I only found out this week. Don't build on those woods. I love those woods and use them all the time to walk my dogs. Why not make a bike trail or exercise trail in there for people to have fun. The children have a park for them in the recreation ground. Now give something back to the older ones? As I understand another school is to be built. The traffic will be far worse than it is now on Red Hill/White Horse Hill, Elmstead Lane and Willow Grove/Sainsbury's junction and surrounding roads. The Cowpath is also a very important walkway for those walking to the station and children being walked to school etc. More housing means more areas of concrete where water cannot drain away properly and flooding will occur. More cars parked up on the kerbs. More ugly BT/communication boxes and cheap road furnishings to make the place look 'housing association' - which is very recognisable in building design Having witnessed the demolition of Ravensbourne College BR7 and all the lorries breaking up the road surface, causing potholes making cyclists/scooters vunerable. Was a chemical dump there and the ground contaminated? please can you confirm?

143

Representation no.

DLP142_1



Format Email Full Name Andrew and Kate Brown Organisation We are opposing to build any building on the green belt because it provides a natural environment for wildlife and provide natural recreational space that is enjoyed / used by our local community.

144

Representation no.

DLP143


Draft Policy 1 – Housing Supply Draft Policy 29 – Education Site Allocations Draft Policy 56 – Local Green Space Draft Policy 49 – The Green Belt Section 4 – Getting Around (Transport and Accessibility) Section 5.3 – Nature Conservation and Development Draft Policy 24 – Allotments and Leisure Gardens

Format Email Full Name Bob Neill MP Organisation

145

I make the following observations, in response to the Council’s consultation on the Draft Local Plan, as one of the Borough’s Members of Parliament. I recognise the need for both additional housing and school provision in the Borough, and welcome the Council’s explicit acknowledgement that these are areas of priority over the coming years. In relation to housing in particular, preference should always be given to previously developed sites, albeit with different previous uses, and building upon open land avoided if at all possible, reflecting the hierarchy of open land protection. With regards to specific site proposals in the Bromley & Chislehurst constituency, I make the following observations: Mixed use sites - I support the proposals, but in relation to plans in the Bromley Town ward, including the Bromley Civic Centre site, any development should be of a sensitive design in both high and density to the adjoining residential areas. School sites - given the clearly proven need for additional school spaces, I welcome the allocations that have been set out in the Plan. In principle, I broadly support any schemes that will support education provision, providing they are shown to be acceptable in planning and highways terms through the usual planning process. I welcome the clear inclusion of areas such as the Bull Lane allotments, Havelock Recreation Ground and Chislehurst Recreational Grounds, Walden Recreational Grounds and Whytes and Walden Woods as Local Green Space sites. I also support the continued importance attached to protecting our local Green Belt, as well as efforts to improve transport routes in areas such as Sundridge Park Railway Station to strengthen access to employment. I echo the concerns raised by the Chislehurst Society with regards to the felling of trees in conservation areas, and to the apparent scaling down of protections offered to allotments and leisure gardens by dropping the requirement to demonstrate long term insufficient demand in Draft Policy 24.

146

Representation no.

DLP144_1


Education Allocation Site 33 – St. Hugh’s Playing Field

Format Email Full Name Alan and Linda Howes Organisation

147

With reference to Bromley's Draft Local Plan "Draft Policy 29 - Education Site Allocation", we have already submitted two objections to the planning application for the proposed Bullers Wood Boys School on St Hugh's Playing Field. Briefly, these objections relate to the adverse effect on traffic in an already heavily congested area, the safety of pedestrians at the entrance/exit onto Chislehurst Road, that the site is too small for the proposed buildings together with playing fields for both the girls and the boys schools, the shortage of parking space in local roads during the daytime, and the possible nuisance from the evening use of the community sports hall.

For these reasons we hope that the council will find a more suitable site for any necessary expansion of school places.

148

Representation no.

DLP145


DLP145_1 - Education Allocation Site 33 – St. Hugh’s Playing Field DLP145_2 - Draft Policy 56 – Local Green Space

Format Email Full Name Joan and Graeme Shankland Organisation

149

SUBJECT - COMMENTS ON BROMLEY’S DRAFT LOCAL PLAN Dear Sir/Madam, We have set out below our comments on Bromley’s Draft Local Plan: DRAFT POLICY 29 – EDUCATION SITE ALLOCATIONS We believe St Hugh’s Playing Fields should be removed from the list of sites allocated for new education provision as it is not a suitable for for the building of the new Bullers Wood School for Boys (Planning Ref: 16/03315/FULL1), for the following reasons: The area in Pines Road is already congested with parking for Bickley station. Woodlands Road as you will be aware is unadopted by the council, and is maintained at the residents’ expense. It is inevitable that if the school is built on the proposed site that Woodlands will become a “cut through” for the increased traffic. Chislehurst Road is unsuitable for the school entrance and it is likely that there would be a bottleneck for traffic at the mini roundabout. this will cause considerable inconvenience to local residents. Increased traffic is also a safety concern for local residents and children. The Mayor of London has noted that the partial loss of playing fields and Urban Open Space is a major concern with the proposed development. The current planning application has clearly shown that the St Hugh’s Playing Fields is not a suitable site for a new school. Other suitable sites need to be urgently considered. DRAFT POLICY 56 – LOCAL GREEN SPACE St Hugh’s Playing Fields provide much needed green space to the local community, and as such we think it should be designated as Local Green Space in the Local Plan.

150

Representation no.

DLP146_1


Housing Allocation Site 2 – Land adjacent to Bromley North Station

Format Email Full Name David Sterling Organisation

151

I am writing to register my objection to the proposed plan to build 525 residential units around Bromley North Station.

The grounds for my opposition to the proposed development are as follows:

1. If planning permission is granted, the development will increase the population of Bromley North Village by approximately one thousand residents. This will change the local dynamic from being one of a relaxed family-friendly village – where visitors and local residents can socialise, shop and enjoy the tranquil environment together – to that of a busy metropolis that is ill-equipped to meet the environmental, medical, educational, social, welfare and developmental needs of the local community.

2. The development will be unsightly and overbearing on the existing residences, thereby making the locality a less desirable place to live.

3. The current infrastructure of the local area (i.e., transport, parking, medical facilities and schools etc.,) cannot withstand an increase of one thousand residents, concentrated in such a small area. This will significantly reduce the quality of life for the current, and the future residents, of Bromley North Village.

4. The proposed development also does not respect the Grade II status of the local Railway Station and the adjacent Conservation Area.

The overall detrimental impact of the proposed development, referred to above, threatens to undo all the hard work that the London Borough of Bromley, and the local residents, have put into making Bromley North Village a quality place to live and to do business.

152

Documents

Draft Local Plan Representations 126 to 146...Draft Local Plan Representations 126 to 146 Note: You can jump to specific representations by clicking on their respective labels in the