13-12-11 RB Greenwich EIP - URS Response paper FINAL

Comments

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