13-12-11 RB Greenwich EIP - URS Response paper FINAL
Transcription
13-12-11 RB Greenwich EIP - URS Response paper FINAL
Greenwich Core Strategy and Development Management Policies EIP Report in response Quod Planning’s Examination Hearing Session Statement (Issue 6) for Royal London CIS Prepared for RB Greenwich December 2013 [LOCATION] Greenwich Core Strategy and DM Policies EIP - Response Paper Greenwich Core Strategy and DM Policies EIP - Response Paper REVISION SCHEDULE Rev Date Details Prepared by Reviewed by Approved by 1 December 2013 Report Issue 1 Tony Batten Rory Brooke Tony Batten Associate Planner Head of Infrastructure, Economics and Planning Associate Planner December 2013 Report Issue 2 2 Tony Batten Associate Planner URS Infrastructure and Environment UK Ltd. 6-8 Greencoat Place London SW1P 1PL UK GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 1 Greenwich Core Strategy and DM Policies EIP - Response Paper TABLE OF CONTENTS 1 INTRODUCTION ............................................................... 3 1.1 Issues ................................................................................ 3 2 URS EXPERIENCE ON EMPLOYMENT LAND REVIEWS5 2.1 10 Year Track Record ...................................................... 5 3 ELR APPROACH .............................................................. 7 3.1 Cluster Assessment ........................................................ 7 3.2 Appraisal of Employment Land Stupply...................... 10 3.3 Use of Plot Ratios .......................................................... 20 GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 2 Greenwich Core Strategy and DM Policies EIP - Response Paper 1 1.1 INTRODUCTION Issues This paper provides a response to incorrect and unsound assertions made within Quod Planning’s Examination Hearing Session Statement (Issue 6) for Royal London CIS (November 2013); and Capita Symonds representations towards the Greenwich Core Strategy and DM Policies proposed submission consultation on behalf of CIS (May 2013) - both in relation to the RB Greenwich ELR (2012) (as carried out by URS) and the Council’s proposals for retention of the Westminster Industrial Estate (WIE) within the existing Strategic Industrial Location (SIL) designation as part of their forthcoming development plan policies. Of importance is the fact that the adopted UDP and London Plan already locate WIE within the SIL designation so the Core Strategy proposal is not amending the land use policy for this site. This paper responds to key assertions made within the two response statements. In summary it includes: • Specific explanation of where the methodology for the study has been adopted and accepted as being sound by planning inspectors elsewhere (including in SE/E London boroughs), including justification for the cluster assessment approach. • Explanation of the supply / cluster scoring exercise explaining the full set of factors considered (including occupancy) and used in determining why C2.5 (as per the ELR site naming protocol) as a whole (which includes WIE) is considered to be a more suitable cluster for on-going B1c/B2/B8 uses than Cluster 2.4 for example which is recommended for release from SIL. • Further detailed justification on why WIE should not be de-designated from SIL for other uses including housing (compromises remaining industrial uses, impacts on the gross demand for industrial land within the borough) • Justification on use of the chosen plot ratios within the forecasting exercise. • Further conclusions on why the Quod’s proposals for greater release are unsound and in conflict with the GLA’s Land for Industry and Transport SPG. URS has found that the representation statements provide not only inaccurate but also conflicting evidence. For example the accuracy of assertions made by Quod Planning must be questioned such as in their report section 4.5 they state that: “the Westminster Industrial Estate (WIE) which forms part of C2.5 is incorrectly assessed in ELR to be in ‘good condition’ when a large proportion of the site, which contains the majority of the floorspace, is in fact derelict and incapable of being used for employment purposes.” ” Meanwhile Capita Symonds in Section 1.5 confirms that “the more modern low rise industrial units to the south of Faraday Way… have recently undergone refurbishment”. This investment has also been confirmed through site visits undertaken by URS, at the time of the study and nd on 2 December 2013 (see photos later in report). Plan 1 and Image 1 – WIE The plan and image below respectively show the footprints and massing of buildings within the WIE. GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 3 Greenwich Core Strategy and DM Policies EIP - Response Paper Sources: Quod Planning and Bing Maps GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 4 Greenwich Core Strategy and DM Policies EIP - Response Paper 2 2.1 URS EXPERIENCE ON EMPLOYMENT LAND REVIEWS 10 Year Track Record In response to the general assertion made by Quod Planning that the methodology used by URS for the ELR is “fundamentally flawed” “wholly inaccurate, unreliable and not sufficiently robust” (Quod, Executive Summary bullet 2 and para. 4.7) we confirm the following. URS has built a highly respected reputation for delivery of employment land reviews over the past ten years, particularly in Greater London (please see Appendix A for a partial long list of studies that we have successfully completed) having delivered more than thirty such studies for local planning authorities and regional planning authorities such as the GLA. All of those studies that have been independently tested by planning inspectors as part of development plan EIPs have been found to be sound, credible and thorough evidence base documents upon which employment land policies can reliably be based. A list of some of our successfully completed employment land reviews that have directly informed adopted policy which have been tested and found to be sound by inspectors through EIPs is listed below along with hyperlinks to the studies. We are happy to provide planning authority client references to validate the robustness of our work and detailed CVs of key personnel if that would be helpful. Local Employment land Reviews • • • • • • • • London Borough of Southwark (2010) - Employment Land Review (http://www.southwark.gov.uk/downloads/download/1687/employment_land_review_2 010) London Borough of Newham (2011) - Employment Land Review (http://www.newham.gov.uk/Pages/ServiceChild/Planning-policydocuments.aspx#EmpLandReview) London Borough of Tower Hamlets (2009) - Employment Land Study (http://www.towerhamlets.gov.uk/lgsl/451500/494_th_planning_guidance/evidence_base.aspx) London Borough of Croydon (2010) - Office, Industrial and Warehousing Land/Premises Market Assessment (http://www.croydon.gov.uk/planningandregeneration/framework/lpevidence/economyemployment) London Borough of Havering (2006) – Employment Land Review (No online link available) London Borough of Brent (2009) – Employment Land Study (http://www.brent.gov.uk/services-for-residents/planning-and-building-control/planningpolicy/local-plan/local-plan-supporting-documents/employment-local-plan-supportingdocuments/) London Borough of Brent (2006) – Employment Land Demand Study (http://www.brent.gov.uk/services-for-residents/planning-and-building-control/planningpolicy/local-plan/local-plan-supporting-documents/employment-local-plan-supportingdocuments/) London Borough of Waltham Forest (2009) - Employment Land Study (http://www.walthamforest.gov.uk/documents/ke61-wf-employment-landstudy2009.pdf) GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 5 Greenwich Core Strategy and DM Policies EIP - Response Paper • • London Borough of Richmond (2009) – Employment Land Study (http://www.richmond.gov.uk/home/environment/planning/planningpolicy/local_develo pment_framework/local_development_framework_research/employment_land_study_ november_2009.htm) Sevenoaks District Council (2007) – Employment Land Review (http://www.sevenoaks.gov.uk/__data/assets/pdf_file/0019/83602/Employment-LandReview-December-2007.pdf) Strategic Employment Land Studies • • • • London Development Agency / Greater London Authority (2010) – London Industrial Land Baseline study (https://www.london.gov.uk/sites/default/files/london-industrial-land-baseline-finalreport%20Nov%202010.pdf) Greater London Authority (2007) – Industrial Land Demand and Release Benchmarks (https://www.london.gov.uk/sites/default/files/il-release-benchmarks.pdf) Greater London Authority (2007) - North East And South East London Industrial Land Baseline Project (http://legacy.london.gov.uk/mayor/planning/industrial-land/docs/il-ne-se-baseline.pdf) Greater London Authority (2007) – Demand and Supply of Land for Logistics in London (http://legacy.london.gov.uk/mayor/planning/industrial-land/docs/il-demand-supplylogistics.pdf) Some of the specific issues raised in relation to the ELR work are covered below. GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 6 Greenwich Core Strategy and DM Policies EIP - Response Paper 3 ELR APPROACH 3.1 Cluster Assessment The primary focus and scope of the ELR, which is a strategic study, is to assess the overall supply and demand for employment land within an administrative area. Within this context it considers sites’ overall and continued suitability for employment uses based on a wide range of local and strategic characteristics in the context of future demand. Employment land reviews should focus on those employment uses or premises traditionally grouped under the B Use Classes (ELR Guidance Note, 2004, para.2.25). The point to emphasise is that key employment sites (the supply) should have suitable strategic and local characteristics that mean that with balancing of supply and demand values can go up over time and it will become viable to refurbish/redevelop them. As a comparable context we could point to increased land values and rents in Lower Lea for B2/B8 in light of the Olympics plan – ie balancing out demand and supply for industrial land. From our experience of undertaking ELRs it is not appropriate, feasible or necessary to collect detailed information at the individual building or property owner site boundary level (as suggested should be the case within the two hearing documents). The cluster assessment approach that has been adopted within the Greenwich ELR is appropriate and credible as it identifies coherent parcels of employment land for which the considered appraisal criteria set out within Annex E of the ELR Guidance Note (DCLG, 2004) and as per the London Plan (Policy 4.4) can practically be collected. Variations and differences within the Cluster are however specifically recorded (see attached supplementary dataset 12-08-17 RBG ELR Field Survey Data AB issued). For the Greenwich ELR as with other ELRs, our approach to undertaking the audit of employment land was to agree a matrix of site characteristics to be collected and assessed. The characteristics are based on the data source identified above and our own extensive experience / good practice. For the Greenwich ELR (as with those URS studies listed in report section 2) we collected information on the following: 1. Strategic access (road and public transport) 2. Access to wharves 3. Existing employment use / activity 4. Neighbourhood issues 5. Vacant land and derelict buildings 6. Physical site constraints (e.g. access, topography, obvious visual contamination, layout issues) 7. Policy context (e.g. SILs and LSIS designation, and other key sites) 8. Access to amenities and facilities 9. Age and quality of buildings 10. Quality of environment and public realm 11. Servicing of businesses including parking 12. Congestion and capacity 13. Evidence of active marketing on site GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 7 Greenwich Core Strategy and DM Policies EIP - Response Paper 14. Intensification or regeneration potential for existing uses or other appropriate B Use classes or employment uses (including reviewing and considering if adjacent sites appear possible options to accommodate business expansion) 15. Opportunities for other land use aspirations The detailed information collected as part of the site surveys and supply appraisal was recorded in a spreadsheet which was issued to the Council. Please see attached “12-08-17 RBG ELR Field Survey Data AB issued” as well as within the ELR report (including within Section 5). This information was interpreted and appraised in the form of a comparative analysis using the scoring criteria for on-going suitability for industrial and warehousing uses contained in Appendix B. The outcome of this comparative analysis exercise is contained within Appendix C, which is explored further in the next section. As it can be seen, these criteria and the evidence collected as part of the ELR does fully cover the considerations and factors required to assess whether sites may suitably be retained as industrial land designations (including SIL) as per Policy 4.4 of the London Plan. We therefore reject the assertion made by Quod Planning (under para 3.3 of their report) that our assessment does not fully consider all of the criteria. Specifically Policy 4.4 of the London Plan on ‘Managing industrial land and premises’ says the following with regard to LDF preparation. We then explain how each of these criteria has been covered in our work: B - LDFs should demonstrate how the borough stock of industrial land and premises in strategic industrial locations (Policy 2.17), locally significant industrial sites and other industrial sites will be planned and managed in local circumstances in line with this strategic policy and the location strategy in Chapter 2, taking account of: a) the need to identify and protect locally significant industrial sites where justified by evidence of demand The ELR identifies a gross demand of between 187.7 and 190.8 hectares of employment land during the 2012 to 2028 plan period. Alongside recommendations on retaining but rationalising existing SIL designations the ELR provides a firm recommendation on allocating a new LSIS to cover the non designated Lyndean Industrial Estate where there is evidence of on-going local demand for industrial space. The Council has advised that they plan to review this site through their Site Allocations DPD. b) strategic and local criteria to manage these and other industrial sites The ELR assessed SIL, LSIS and other employment sites against well considered suitability criteria (as identified directly above). Within the context of the overall supply and demand for employment land, it is intended that these criteria and any future guidance published since the ELR can be used to assess the ongoing suitability of employment sites for industrial uses. c) the borough level groupings for transfer of industrial land to other uses (see Map 4.1) and strategic monitoring benchmarks for industrial land release in supplementary planning guidance th The most recent guidance supplied directly to Greenwich Council by the GLA on the 26 June 2012 (during the ELR study) (which has since has fed into the GLA’s ‘Land for Industry and Transport SPG’), identified the borough as one with ‘managed release’ of industrial land (with a benchmark release of -50ha over the plan period). These are defined as Boroughs which ‘typically have a greater supply of vacant industrial sites relative to demand and should generally adopt a rigorous but sensitively managed GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 8 Greenwich Core Strategy and DM Policies EIP - Response Paper approach to transfer’. In proposing industrial employment land release in the region of -41 hectares URS recognises and fully takes account of this guidance. d) the need for strategic and local provision for waste management, transport facilities (including inter-modal freight interchanges), logistics and wholesale markets within London and the wider city region; and to accommodate demand for workspace for small and medium sized enterprises and for new and emerging industrial sectors including the need to identify sufficient capacity for renewable energy generation The ELR fully accounts for net additional land requirements for logistics as part of the B8 forecasting exercise (See report Section 7). The ELR also fully recognises and accounts for the ongoing need for land for waste, transport functions, utilities and other ‘wider’ industrial type uses which exist on industrial employment land. The net additional requirement for land for waste is factored into Table 7.11 of the ELR. There is no evidence of a decrease or increase in demand for land from the other ‘wder’ uses noted above such as land for transport functions and utilities so the ELR assumes that the current stock of land for these uses remains broadly constant during the plan period and does not recommend release of industrial sites that contain these uses. The wide range of sites and premises typologies within that are being protected as part of the ELR recommendations fully accounts for the wide ranging floor space requirements of businesses of varying size and type that are located within the borough, including those involved in utilities and renewable energy generation. e) quality and fitness for purpose of sites The appraisal criteria noted above; Sections 5, 6 and 8 of the ELR report; report appendices B and C of this report; and supplementray spreadsheet of detailed information entitled ‘12-08-17 RBG ELR Field Survey Data AB issued’, demonstrates that a comprehensive, relevant and well considered set of appraisal criteria has been used to help determine the quality and fitness for purpose of employment sites in RB Greenwich. The comparative assessement of employment sites that was carried out as part of the ELR to determine their suitability is described in section 3.2 of this report and the results set out in Appendix C. We therefore fully reject the assertion made by Quod Planning that this specific criterion from the London Plan has not been considered. f) accessibility to the strategic road network and potential for transport of goods by rail and/or water transport These criteria are covered within the site appraisal criteria identified above. g) accessibility to the local workforce by public transport, walking and cycling The PTAL and local accessibility context was covered as part of the appraisal of sites as demonstrated. h) integrated strategic and local assessments of industrial demand to justify retention and inform release of industrial capacity in order to achieve efficient use of land As explained above, the primary focus and scope of the ELR – which is the approach we have taken here - is to assess the overall supply and demand for employment land within an administrative area. Within this context it considers sites’ overall and continued suitability for employment uses based on a wide range of local and strategic characteristics in the context of future and ongoing demand. GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 9 Greenwich Core Strategy and DM Policies EIP - Response Paper The point to emphasise is that key employment sites (the supply) should have suitable strategic characteristics that mean that with balancing of supply and demand values can go up over time and it will become viable to refurbish/redevelop them. i) the potential for surplus industrial land to help meet strategic and local requirements for a mix of other uses such as housing and, in appropriate locations, to provide social infrastructure and to contribute to town centre renewal. The appraisal criteria noted above; and supplementary spreadsheet of detailed information entitled ‘12-08-17 RBG ELR Field Survey Data AB issued’ demonstrates that these factors were considered. In our assessment of employment areas these were covered through: • Intensification or regeneration potential for existing uses or other appropriate employment uses (including reviewing and considering if adjacent sites appear possible options to accommodate business expansion) • Opportunities for other land use aspirations The detailed criteria, site survey and appraisal information as set out within the supplementary spreadsheet ‘12-08-17 RBG ELR Field Survey Data AB issued’ was shared with the Council during each stage of the ELR work and the outputs then issued in final format following completion of the work in August 2012. This detailed information is a supplementary evidence base output produced as part of the project work. The detailed site scoring analysis as contained within appendices B and C is purposefully not included in the ELR report because this exercise is intended as a higher level analytical tool that can be used to help appraise the sites against the strategic and local criteria, alongside other evidence to help determine sites’ overal suitability for ongoing employment uses. A clear summary of this information is included in Section 5 of the ELR however. Section 3.2 of this report explains this further. 3.2 Appraisal of Employment Land Stupply The URS approach to ELRs as advocated in the ELR Guidance Note and validated by different planning inspectors over a number of years is to undertake a comparative assessment of the strategic characteristics of employment sites (the supply) once the information, data and baseline of information has been collected. This data is contained within the Appendices B and C and within the attached “12-08-17 RBG ELR Field Survey Data AB issued” spreadsheet. Based on the assessment criteria and scoring exercise against characteristics that has been applied as a result of the detailed appraisal of all employment land, it can clearly be seen that Cluster 2.5 as a whole, which contains the defined WIE as a significant land parcel in a prominent position within it, is performing above average against the B2/B8 suitability criteria as suitable industrial employment land designation when compared to other clusters of employment land such as Cluster 2.4 for example which is recommended for release from SIL GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 10 Greenwich Core Strategy and DM Policies EIP - Response Paper Plan 2 – WIE within the proposed SIL designation / Cluster 2.5 of the ELR The specific reasons we believe that Cluster 2.5 including the whole of WIE scored more positively against the B2/B8 suitability criteria and should be retained for SIL use are as follows: • The overall quality of environment is considered to be good both within the majority of the cluster and within most of the WIE. By Capita Symonds own admission (in Section 1.5 of their representation) it is confirmed that “the more modern low rise industrial units to the south of Faraday Way (which are evidenced by URS in Appendix E to form a significant proportion of the floorspace on the site)… have recently undergone refurbishment” and this investment manifests itself through good quality public realm and environment in that vicinity. The photos in this section demonstrate good quality environment across most of WIE and Cluster 2.5. GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 11 Greenwich Core Strategy and DM Policies EIP - Response Paper Image 2 – View west of good environmental quality along Westfield Street in WIE • There are relatively few bad neighbours issues (excessive noise, dust and traffic generation) compared to other clusters (such as Cluster 2.4 which is proposed for release) and none that are currently impacting negatively on adjacent residential uses. • The majority of businesses are well-served - both within WIE and Cluster 2.5 - with clear, wide roads and designated off-road loading/unloading spaces. • Parking facilities are adequate throughout the WIE and Cluster 2.5 with dedicated parking bays present. GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 12 Greenwich Core Strategy and DM Policies EIP - Response Paper Image 3 - View north from Westfield Street along Swan Road (Buildings 218+217 on either side) demonstrating adequate parking and servicing • The site has good strategic road access, with direct access onto the A206, which is attractive and amenable to logistical and industrial operators. Image 4 – Strategic Road access directly into the site (on the right) from A206 GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 13 Greenwich Core Strategy and DM Policies EIP - Response Paper • WIE and Cluster 2.5 currently have poor public transport access (as evidenced through a poor PTAL rating). This accessibility context does not lend itself to either future residential or primarily office uses. • Most of the buildings within WIE and Cluster 2.5 are evidenced from our survey to be in good condition (as demonstrated through the photos of WIE in this report such images 5+6 below and the additional photos of the well-functioning heavily invested Mellish Industrial Estate directly to the north as shown in images 9-13). The two multistorey brick buildings within WIE north of Faraday Way are the poorest quality stock, however these are both a minority of the stock within WIE and Cluster 2.5 (as evidenced above and in Appendix E) and they are partly occupied by creative and cultural industries such as Art Hub so not entirely derelict as asserted by Quod Planning (see images 7-8 below). Image 5 - Buildings 208A-D – recently invested in / good quality buildings in WIE Image 6 - Buildings 217A-D + 76/77 – Other good quality industrial units in WIE indicative of the majority of supply on WIE • GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 14 Greenwich Core Strategy and DM Policies EIP - Response Paper Image 7 + 8 - Building 62 – one possibly two floors in this building appear to be fully occupied by Art Hub indicating the building is not entirely ‘derelict’ The two hearing statements propose that WIE should be designated for residential led mixed use claiming that there is developer interest in the site for such uses. Capita Symonds proposes the following masterplan for the site on behalf of CIS: Plan 3 - CIS masterplan proposal for WIE GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 15 Greenwich Core Strategy and DM Policies EIP - Response Paper In our professional view the masterplan is very poorly conceived and has a number of significant issues and weaknesses. The proposed residential uses would be sandwiched between two busy operational industrial estates and residential amenity would be severely and negatively affected by the presence of such uses. The main access for the new residential uses also appears to be proposed from the roundabout off the A206 and would be shared with all HGV and other industrial related traffic serving the sites to the north and south of it, which would be wholly unacceptable in planning and highways terms. The housing proposals for WIE would compromise the integrity of the remaining industrial and logistical uses within the immediate surroundings for which there is evidenced to be an on-going demand for space at these locations both in the short, medium and long term. Owners and/or occupiers of the Mellish Industrial Estate directly to the north of WIE and the proposed residential uses in the masterplan appear to have invested heavily in premises, services and environment within this estate which is considered to be a high quality industrial area. Images 9-12 demonstrate that this investment and the well-functioning of this industrial space. In this context it is highly unlikely that they would support residential uses to their immediate south, potentially creating a tension for their operations. Images 9-13 – High quality well-functioning industrial space directly adjacent to WIE GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 16 Greenwich Core Strategy and DM Policies EIP - Response Paper Images 9, 12 and 13 show that older the older period multi-storey buildings at Mellish industrial estate (which are similar to the aforementioned industrial building at WIE which currently have vacancy) have been recently invested in / refurbished and that they appear to be fully occupied. This suggests that with investment from the owners there would be a demand for space within the period multi-storey brick buildings at WIE. GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 17 Greenwich Core Strategy and DM Policies EIP - Response Paper GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 18 Greenwich Core Strategy and DM Policies EIP - Response Paper GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 19 Greenwich Core Strategy and DM Policies EIP - Response Paper 3.3 Use of Plot Ratios Quod Planning questions URS’ use of plot ratios for calculating future land requirements from net floorspace requirements. For calculating future land requirements from forecast B2 and B8 floorspace, URS used typical plot ratios as specified within the ELR Guidance Note (Annex D, Box D.7) and our experience of undertaking similar studies, particularly in Greater London. For industry (B2) a plot ratio of 0.4 was used which was the average of the range specified (0.35 to 0.45). For warehousing (B8) a plot ratio of 0.6 was used which was at the upper end of the range specified (0.4 to 0.6) based on the fact that warehousing in RB Greenwich is considered to be more concentrated on smaller sites owing to its inner urban location. The weighted average plot ratio used based on the actual floorspace of B2 and B8 space in Greenwich (using the floorspace totals in RB Greenwich shown in Table 7.8 of the ELR) is calculated to be 0.47. URS believes that use of this figure is fully justified because the actual plot ratios within the two main areas of industrial land release are found to be very similar to this (shown to be 0.42 overall in Table 1 below) based on the actual land areas (minus a proportion for roads) and the actual B2 and B8 floorspace contained within these sites. At the time of the ELR, RB Greenwich worked with the consultancy team to obtain detailed information on floorspace contained within these areas. Table 1 - Key employment land release areas proposed in ELR Cluster No. Site Area (approx. area proposed for release from employment) C2.4 Site Area (Minus 15% allowance for internal roads) Actual industy and warehousing floorspace (GEA) on site as measured Actual plot ratio Ha Square metres Square metres Square metres 35.4 354,000 300,900 134,546 0.45 4.7 47,000 39,950 8,557 0.21 40.1 401,000 340,850 143,103 0.42 C5 (SW section) Total Sourse: URS, RB Greenwich Finally, it was emphasised within the response statements that URS had not recommended sites totalling the maximum range of release in the ELR. It is not appropriate in our experience to set release at the total ceiling of the range as there are likely to be unforeseen scenarios over the plan period that the Council must respond to for example where smaller nondesignated site may be proposed for release. Allowing some flexibility is the specific point of Recommendation 6 on page 92 of the ELR. GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 20 Greenwich Core Strategy and DM Policies EIP - Response Paper APPENDIX A – PARTIAL LONG LIST OF SUCESSFULLY COMPLETED URS’ ELRs Greater London • • • • • • • • • • • • • • • • • • • • • • • • Royal Borough of Greenwich (2012) - Employment Land Review Royal Borough of Greenwich (2007) - Employment Land Review London Borough of Southwark (2010) - Employment Land Review London Borough of Bromley (2013- current) - Planning for Growth in Bromley- Cray Business Corridor Employment Land Study London Borough of Croydon (2012) - Employment Land Review Update London Borough of Croydon (2010) - Office, Industrial and Warehousing Land/Premises Market Assessment London Borough of Newham (2011) - Employment Land Review London Borough of Tower Hamlets (2009) - Employment Land Review London Borough of Barking and Dagenham (2005) - Industrial Land Study London Borough of Havering (2012) – Employment Land Review London Borough of Havering (2006) - Employment Land Review and Business Survey London Borough of Harrow (2007) – Employment Land Demand Study London Borough of Waltham Forest (2009) - Employment Land Study update London Borough of Waltham Forest (2007) - Employment Land Study London Borough of Brent (2013) - Employment Land Review London Borough of Brent (2008) - Employment Land Review London Borough of Hillingdon (2012) - Employment Land Review London Borough of Hounslow (2011) - Employment Land Study London Borough of Richmond (2009) - Employment Land Review update London Borough of Richmond (2005) - Employment Land Review London Development Agency / Greater London Authority (2010) – London Industrial Land Baseline study Greater London Authority (2007) – Industrial Land Demand and Release Benchmarks Greater London Authority (2007) - North East And South East London Industrial Land Baseline Project Greater London Authority (2007) – Demand and Supply of Land for Logistics in London Other • • • • • Anglesey County Council and Gwynedd Council (2013)- Economic and Employment Land Review Study Cherwell District Council (2010)- Employment Land Study Update Vale of White Horse District Council (2012) – Employment Land Review update Vale of White Horse District Council (2008)- Employment Land Review Elmbridge Borough Council (2008) - Employment Land Review GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 21 Greenwich Core Strategy and DM Policies EIP - Response Paper • • • • • • Blaenau Gwent County Borough Council (2007) - Employment Sites and Premises Study Sevenoaks District Council (2008) – Employment Land Study update Sevenoaks District Council (2005)- Employment Land Study Cherwell District Council (2012) – Employment Land Review Cherwell District Council (2006) - Employment Land Study Thurrock Council (2006) - Employment Land Study GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 22 Greenwich Core Strategy and DM Policies EIP - Response Paper APPENDIX B – GREENWICH ELR: SUITABILITY SCORING FOR B2/B8 USE Cluster Ranking Criteria Strategic Road Access Links with wharves Quality of Environment Condition of Buildings Topography Issues Contamination Bad neighbourhood issues • Good, Very Good: 1 point • Poor, Very Poor: 0 point • Direct: 1 point • No access: 0 point • >75% of environment in good or very good condition: 1 point • 50-75% of environment in good or very good condition: 0.67 point • 25-49% of environment in good or very good condition: 0.33 point • 0-24% of environment in good or very good condition: 0 point • >75% of buildings in good or very good condition: 1 point • • 50-75% of buildings in good or very good condition: 0.67 point 25-49 of buildings in good or very good condition: 0.33 point • 0-24% of buildings in good or very good condition: 0 point • 1 point if there is no topography issues • 0 point if there is a topography issue on or immediately adjacent to the site • 1 point if no contamination issues. • 0 point of there is a contamination issue • Employment areas start with 1 point and minus 0.2 for each bad neighbourhood use (Noise pollution, air pollution, smell, HGV traffic, significant car traffic, other) To maximum of –0.2. • Additional -0.5 point if employment area in close proximity to existing or proposed residential • Adequate: 1 • Not adequate: 0 Parking Facilities • • Adequate: 1 Not adequate: 0 Level of utilisation for active employment uses (B use class) • More than 75% cluster currently actively used for employment uses: 1.5 points • 50-74% cluster currently actively used for employment uses: 1 point • 25-49% cluster currently actively used for employment uses: 0.5 points • Under 25% cluster currently actively used for employment uses: 0 points • Clusters are accessed by vehicle directly via the A102, A200 or A206 both of which are heavily congested: 0 points • Clusters are accessed by vehicle via trunk roads other than the A102, A200 or A206: 1 point • • Very high = 1.5 point High = 1.0 point • • Medium = 0.5 point Medium Low = 0 point • Low = 0 point Servicing of businesses in cluster Congestion and Capacity Issues Market attractiveness • • We asked agents What has been the general “market attractiveness” of the existing industrial/employment areas over the past ten years? They commented in each individual industrial / commercial estate in each cluster (an average was taken). GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 23 Greenwich Core Strategy and DM Policies EIP - Response Paper APPENDIX C – CLUSTER SCORING – SUITABILITY FOR B2/B8 USE Private and confidential Private and confidential Private and confidential Suitability as employment areas (B2 and BB) Rank Strategic Road Access Proximity to Wharves Quality of Environment Parking provision Servicing of businesses Contamination issues Topography Issues Bad Neighbourhood Uses Condition of Buildings w ithin cluster Level of utilisation for employment Congestion and Capacity Issues Market attractiviness over past ten years Total Site score 1 0 1 1 1 1 1 1 1 1 1 1 11 1 1 1 1 1 1 0.5 0.67 1.5 1 0.75 10.42 Employment Areas, uses and users cluster number White Hart Triangle Business Park C1.2 Syral Refinery, Greenwich Distillers Ltd, Spicers Greenwich Depot, Alcatel, Other small industrial and business units C5 West Thamesmead Business Park, Birchfield Business Park, Crown industrial Park, White Hart Triangle Business Park C1.1 1 0 1 1 1 1 1 1 0.67 1.5 1 0 10.17 C2.3 1 1 0.33 1 1 1 1 0.4 0.67 1.5 0 1 9.9 C2.1 1 1 0 1 1 1 1 0.2 0.67 1.5 0 1 9.37 C2.5 1 0 1 1 1 1 1 0.8 0.67 1 0 0.5 8.97 C2.2 C3 1 0 0 0 1 1 1 1 1 1 1 1 1 1 0.8 0.8 1 1 0 1.5 0 0 0.875 0 8.675 8.3 C4.2 1 0 0.67 1 1 1 1 0.4 0.67 0 1 0.5 8.24 C6 C4.1 1 1 0 0 1 0.33 0 1 1 1 1 1 1 1 1 0.4 0.67 1 1 0 0 0 0 0 7.67 6.73 C2.4 1 1 0 0 0 1 1 1 0 0.5 1 2 3 4 5 6 Meridian Trading Estate, Lombard Trading Estate, Cory & Sons Environmental, Sainsbury's distribution depot, Hunt&Sons Security, Anchor and Hope Pub, Topps Tiles DAY Aggregates, United Marine Aggregates Westminster Industrial Estate, Thames Barrier Industrial Park, Animal Care Clinic, Claire's Resturaunt Bed and Breakfast, Greenwich Training Institute, Charlton Skills Centre, Arts Hub. Charlton Business Park, Greenwich Shopping Centre, Peninsula Pak, Meridian Trading Estate 7 Metropolitan Police Car Pound and Kerry Logistics Warehouse 8 Small industrial units, residential, community uses, car repair, small retail units, Greenwich Pumping Station (Thameswater), West Greenwich neighbourhood housing office, North Pole Pub, Davy's Wine shop and resturaunt, vacant Kwikfit shop and residential at MU4 9 10 Tunnel Avenue Trading estate, O'Kewte Group Gas Works, Lorry Park, Depot, night club Brookmarsh Industrial Estate, Greenwich Industrial Estate, Storage, Toulouse Plant Hire, Acorn Exhibitions, Hilton Wharf, Saxon Wharf waste management and ship hire, Dowell Wharf, Dreadnough Wharf, Brewery Wharf, Union Wharf 11 12 Riverside Wharf, Anchorage Point Industrial Estate, Thames Barrier industrial Park, Stone Lake Industrial Park, Stone Lake Retail Park, Ropery Business Park, Charlton Gate, New Lyndenburg Commercial Estate, Ashleigh Commercial Estate and residential uses on Hope Lane 0.2 0 Median 8.06 Average 7.85 5.7 94.145 GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 24 Greenwich Core Strategy and DM Policies EIP - Response Paper APPENDIX D – BUILDING FOOTPRINTS OF WIE GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 25 Greenwich Core Strategy and DM Policies EIP - Response Paper GREENWICH CORE STRATEGY AND DM POLICIES EIP - RESPONSE PAPER December 2013 26