Redbridge Local Plan 2015-2030

Transcription

Redbridge Local Plan
2015-2030
Preferred Options Report Extension: Alternative Development Strategies
November 2014
Redbridge Local Plan
2015-2030
Preferred Options Report Extension:
Alternative development strategies
November 2014
Forward
Redbridge is facing significant planning challenges. Its population is growing rapidly,
mainly driven by an increased birth rate. This population growth is placing pressure on the
borough’s social and environmental infrastructure, particularly housing, schools and
leisure facilities.
In response to these challenges, we are reviewing our Local Plan, which sets out where,
when and how growth and change will take place across the borough. The Review aims to
provide for the growing population of Redbridge while also improving the range of
community facilities available to everyone.
In January 2013 the Council published a report outlining the preferred direction of travel
(the ‘Preferred Options report’). The report outlined the Council’s proposed Investment
Area approach, which are areas that include a number of large sites which could deliver
balanced development like new community facilities, enhanced public open space and
additional family-sized housing in garden suburbs. The Investment Areas included Ilford,
the Crossrail Corridor (Seven Kings, Goodmayes and Chadwell Heath), Barkingside, Gants
Hill and South Woodford. Focusing development within Investment Areas would ensure
that the character of established residential neighbourhoods and natural assets could be
protected.
Whilst responses were generally supportive of the Investment Area approach, one site
attracted significant objection. This site was the Oakfields site at Barkingside, which was
identified as a mixed-use development opportunity site with potential to accommodate
approximately 800 new family-size houses, a new school and potentially a polyclinic, set in
a garden suburb. Objections related to the potential relocation / loss of playing fields,
impact upon neighbouring residents and traffic impacts. In September 2013 the Council
committed to ‘undertake a fresh review of alternative strategies to meet the Borough’s
needs whilst addressing the concerns that have been raised’.
This report documents the alternative strategies / options identified as part of that review,
as well as the original Oakfields option. The options were developed by the cross-party
Local Development Framework and Infrastructure Advisory Panel. All of the options have
positives and negatives. We have not at this stage come to a conclusion about which
strategy, or combination of strategies to employ. That decision will only be taken after
residents and stakeholders have had the opportunity to comment on this report and we
have considered their responses.
i There is however one thing that is certain - doing nothing is not an option. Redbridge’s
population is growing and this places pressure on housing need, supply and affordability,
and infrastructure. Failure to plan for this population growth will result in overcrowded
housing, worsening housing affordability, increased illegal housing such as beds-in-sheds,
and inadequate social and environmental infrastructure. Furthermore, if the Council’s
emerging Local Plan does not articulate how it will meet the borough’s housing target set
under the London Plan, there is a significant risk that the plan would be rejected by
Government inspectors. If this happens, we lose the ability to control the form and
location of new development across the borough.
Councillor Helen Coomb
Cabinet Member for Planning and Regeneration
ii Contents page
Forward ................................................................................................................................ i
Contents page.................................................................................................................... iii
List of Figures..................................................................................................................... iv
Section 1: Overview ............................................................................................................ 1
Purpose of this Report................................................................................................................................................. 1
Consultation Details..................................................................................................................................................... 3
Why a New Plan is Needed ........................................................................................................................................ 4
The Preferred Options Report 2013 ....................................................................................................................... 5
Section 2:The Key Planning Challenges ........................................................................... 7
Population Growth ....................................................................................................................................................... 7
Housing and Community Facility Need ................................................................................................................ 8
Housing Targets and the Consequences of Under-Delivery ......................................................................... 8
Meeting the Challenge Sustainably ..................................................................................................................... 10
Section 3: The Inclusion of Oakfields .............................................................................. 13
Representations Objecting to the Oakfields Proposals ................................................................................ 14
Section 4: Potential Strategies ........................................................................................ 15
Sites outside Redbridge............................................................................................................................................ 15
The potential strategies ............................................................................................................................................ 16
Strategy 1: Proceed with the proposals for Oakfields as set out in the original POR ......................... 16
Strategy 2: Increase the proposed development at land in and around Goodmayes and King
George hospitals and the Ford Sports Ground in Seven Kings / Chadwell Heath .............................. 17
Strategy 3: Designate a western corridor running from Woodford Broadway / Woodford to South
Woodford and Wanstead ......................................................................................................................................... 19
Strategy 4: Release further large parcels of green belt land. ...................................................................... 21
Doing nothing is not an option ............................................................................................................................. 23
Section 5: Selecting the Most Sustainable Strategy ...................................................... 25
Appendix A: The Evidence Base ...................................................................................... 27
Appendix B: Sustainability Appraisal ............................................................................. 29
Assessment Criteria .................................................................................................................................................... 29
The Sustainability Appraisal Matrix ...................................................................................................................... 33
Summary Table ............................................................................................................................................................ 47
Appendix C: Response Form............................................................................................ 51
iii List of Figures
Figure 1 - Location and Context of Oakfields .......................................................................................................... 2
Figure 2 - Development Opportunity Sites identified in Preferred Options Report ................................. 6
Figure 3 - Redbridge Population - Actual (2011) and Projected ....................................................................... 7
Figure 4 - Housing Completions - 2003/04 to 2013/14........................................................................................ 9
Figure 5 - Investment Areas (original Preferred Options Report - 2013) ..................................................... 11
Figure 6 - The potential alternative development strategies / options ....................................................... 17
Figure 7 - Indicative Housing Yields – previously identified development opportunity sites
(Western Corridor) ................................................................................................................................................. 20
Figure 8 - Development at 300 dwellings per hectare ....................................................................................... 21
iv Section 1: Overview
High population growth (mainly as a result of increased birth rates) means that Redbridge
faces a significant shortage of housing and growing demand for new community facilities
such as schools, health clinics and leisure centres. Many London boroughs are in a similar
position and across the capital developable land is in short supply. Difficult choices must
be made about the best way to accommodate growth. Failure to do so will have
significant implications for the present and future generations.
This report stems from a statement made by the Cabinet Member for Planning and Public
Protection at full Council in September 2013. The statement was made in the context of
opposition to proposals to develop land at Oakfields, Barkingside for housing and
community infrastructure in a garden suburb setting. The statement committed the
Council to consider alternative strategies to meet the borough’s housing and
infrastructure needs, should it be decided that Oakfields will not be designated as a
development opportunity site.
This report therefore presents a number of possible strategies for discussion and debate
so that the final choice is fully informed by the views of residents and other stakeholders
and allows the borough to grow sustainably, that is in a way that balances the long term
social, economic and environmental needs of the Borough.
Purpose of this Report
The Council is in the process of reviewing its Local Plan, currently called the Core Strategy,
but in future to be known as the Redbridge Local Plan 2015-2030. Between 7 January and
22 February 2013 it conducted public consultation on the Core Strategy Review Preferred
Options Report (POR).
The report set out the Council’s thinking about the main planning issues facing Redbridge
and the general direction of policies it was proposing to adopt. The overriding concern of
the document was to show how the borough could develop in a sustainable manner,
providing the homes and community facilities needed by a rapidly growing population
(mainly as a result of increased birth rates), while preserving what is good about the
Redbridge environment and the quality of life its residents enjoy.
One of its proposals was to designate the Oakfields Playing Fields to the north of
Barkingside Town Centre as part of a major mixed-use Development Opportunity site
(shown on Figure 1). The report suggested that Oakfields could potentially deliver a new
school and a health clinic and potentially up to 800 homes in a garden suburb setting of
parks and open space and leisure facilities.
1
Figure 1 - Locatio
on and Con
ntext of Oaakfields
The Co
ouncil receivved a large
e number o
of represen
ntations abo
out this prooposal. Mo
ost were
from lo
ocal residents and sporrting clubs who curren
ntly use or look onto O
Oakfields an
nd most
objecteed on the grounds
g
th
hat a valuaable sportin
ng facility and
a recreattional open space
could b
be lost.
Oakfield
ds is one of
o the largest of nearlyy 200 Deve
elopment Opportunity
O
y Sites identified in
the POR. If they were
w
all de
eveloped, th
hey could deliver justt over 1,1000 homes per
p year
2
Yet, this
t
is still well shortt of real
averageed over the 15 year life of thee plan to 2030.
(‘objecttively assesssed’) need,, which is rrunning at about 2,000 homes p
per year. If the
t new
Local P
Plan is to meet
m
the re
equirementts of Goverrnment pollicy, the Coouncil will have to
demonstrate thatt it has exp
plored all o
options in finding ad
dditional soources of housing
h
supply..
In respo
onse to all this the Co
ouncil decid
ded to und
dertake a sttudy into p
possible alte
ernative
strategies which might
m
be em
mployed to meet the growth
g
needs of Redbrridge by de
elivering
homes and comm
munity faccilities and considerin
ng if this could
c
be d
done without the
redevellopment of
o Oakfieldss. This rep
port flows from that decision. It presentts three
alternattive strate
egies alongside thee original strategy proposed in the POR in
Januaryy/February 2013 and examines
e
th
he argumen
nts for and against
a
all oof them.
2
While the immediate focus of this report is off-setting the potential loss of Oakfields, it also
serves the wider purpose of exhaustively examining all realistic options for delivering the
homes and services a growing community needs. Proposed changes to the London Plan
will require all boroughs to seek to exceed their minimum housing targets, which the
Mayor of London acknowledges are insufficient to meet full housing need across the
Capital. As Redbridge has one of the largest shortfalls between housing supply (its London
Plan housing target) and housing need, there is likely to be significant scrutiny of the
extent to which the borough seeks to exceed the London Plan target.
Consultation Details
The Council is conducting a formal six-week consultation on the four potential strategies /
options outlined in this document.
The six-week consultation period runs from Friday 7 November 2014 to Monday
22 December 2014.
There will be a number of consultation events during November and December 2014 to
enable people to discuss the potential options in greater detail and to express their views
directly to us. Details of these events can be found on Redbridge i
(www.redbridge.gov.uk/ldf) or by phoning 020 8708 2748.
A formal response form is provided at the end of this document. This includes a number of
questions that the Council is especially keen to hear views about, but you are welcome to
include comments about any other aspects of this report that you think are relevant.
The survey is also available online at redbridge.gov.uk (www.redbridge.gov.uk/ldf).
Responses should be received by 5pm on Monday 22 December 2014.
There are a number of ways to send your completed form or any other written
representation to us:
Freepost:
Preferred Options Report Extension –Alternative Development
Strategies
Planning and Regeneration Service
London Borough of Redbridge
Freepost RSLR – JACE – HSUG
Ilford IG1 1DD
Scan and e-mail to:
[email protected]
Fax:
0208 708 2062
By hand
Planning Policy Team – Room A1, Redbridge Town Hall
128-142 High Road, Ilford, IG1 1DD.
3
We acknowledge that the Redbridge COMPACT 2011- 14
specifies that the Council should allow at least 12 weeks to
receive responses so that voluntary groups can involve
stakeholders wherever possible in preparing their responses.
However, due to the planning regulations which require a 6
week consultation period and the overall Local Plan
timeframes (which include a number of opportunities for
formal consultation) there is considered to be an overriding
requirement to hold a 6 week consultation on the Preferred
Options Extension- Alternative Development Strategies report.
The Council has not at this stage come to a conclusion about which strategy, or
combination of strategies to employ. That decision will only be taken after residents and
stakeholders have had the opportunity to comment on this report and the Council has
considered their responses.
Why a New Plan is Needed
The Council’s main planning policy document is called the Core Strategy. It was first
adopted in March 2008 and since September 2011 the Council has been engaging with
residents and stakeholders to review its contents. The review is needed to keep policies up
to date because since March 2008:

The 2011 census showed population growth in Redbridge has greatly outstripped
predictions (mainly due to an increased birth rate) leading to an acute need for
new homes and community facilities such as schools, health clinics and leisure
centres to support new residents and address existing deficiencies.

The economic downturn has reduced levels of development activity (especially
house building) and increased unemployment in the borough.

Government planning policy (formerly issued as Planning Policy Statements or
Planning Policy Guidance Notes) has been completely revised. Most such policy is
now contained in a single concise document called the National Planning Policy
Framework (NPPF). Local planning policies must comply with the NPPF.

London has a new Mayor and he has published a new version of the London Plan
(2011) and Further Alterations to its policies are proposed, including increasing
Redbridge’s housing target from 760 homes per year to 1,123 per year. Local
planning policies must be in general conformity with London Plan policies.

Several local studies have provided important new pieces of evidence to inform
the planning process. These studies are listed in Appendix 1 The Evidence Base.
4
The Preferred Options Report 2013
A milestone was reached in January 2013, when the Council published its Core Strategy
Review Preferred Options Report for public consultation. This report was based around the
pursuit of sustainable development and its central proposal was to identify five
Investment Areas in accessible locations and close to town centres with the capacity to
accommodate major growth and change based on a balanced mix of uses. This in turn
would allow the character of established residential areas and environmentally sensitive
locations to be protected from excessive growth pressures and inappropriate
development.
Together, these Investment Areas include the great majority of nearly 200 Development
Opportunity Sites which the Council considers are likely to become available for
redevelopment during the plan period (shown on Figure 2). One of the largest of these is
the Oakfields Playing Fields at Barkingside.
The intention of the POR was to indicate the general direction of the Council’s thinking on
major issues, not to spell out every policy detail. In relation to Oakfields the report
suggested that the site could provide a school and a health Polyclinic. The Council’s
Children’s Services and Redbridge NHS had indicated the need for such facilities
somewhere in this general area.
In addition, the report suggested that around 800 homes could be provided on the site.
There would be an emphasis on family sized homes in a garden suburb setting of parks
and open spaces for recreation. The Council’s intention was that any redevelopment
should either retain or re-provide existing sporting facilities at Oakfields on the site, or if
this was not feasible, to relocate them to another site in the vicinity. A development of this
scale would require detailed planning and even then would probably be implemented in
phases over several years, so there would be time to work with existing users of the site to
find a solution to their long-term needs.
In keeping with the general nature of the POR proposals, no definitive plan of
development at Oakfields was put forward. The POR recognised that if the general
proposal was ultimately accepted, a further period of intense planning and consultation
would be required before the final form of redevelopment at Oakfields was determined.
In a departure from previous government policy the National Planning Policy Framework
suggests there may only be a need for a single Local Plan. Accordingly, the POR also
proposed that to expand the Core Strategy review to include the Borough Wide Primary
Policies document and to replace both documents with a single plan, reflecting the 15
year horizon the Council is expected to plan for. This will henceforth be called the
Redbridge Local Plan 2015-2030.
5
Figure 2 - Develo
opment Opportunity Sites identtified in Preferred Op
ptions Report
Five O
Oaks Lan e Oakfieelds
es
Goodmaye
Note: thee developmen
nt opportunitty sites abovee could potentially be used
d for a range oof uses, includ
ding
residentiial and new or improved co
ommunity inffrastructure.
6
Section 2:The Key Planning Challenges
Population Growth
If the population growth trends recorded at the last census continue, Redbridge may have
another 80,000 residents by 2030. The growth is being driven largely by an increase in the
local birth rate, rather than by people moving into the borough. Figure 3 shows how the
borough’s population at the 2011 census exceeded all previous Office of National
Statistics projections. The growing population will need homes, jobs, schools, health
centres, recreational open space and all the other services and facilities existing residents
expect now. Population growth is not the only planning challenge facing the borough,
but how the Council deals with it will largely determine how it is able to cope with all the
rest.
Figure 3 - Redbridge Population - Actual (2011) and Projected
Redbridge Population (1,000s)
400
380
360
340
320
300
280
260
240
220
2005
2008
2010
Source: Office of National Statistics
7
2014
2011 Census
Housing and Community Facility Need
The need for new homes in Redbridge is currently estimated to be at least 2,000 dwellings
per annum1. National planning policy says that the Local Plan should ensure “that
sufficient land of the right type is available in the right places and at the right time to
support growth2” and that it should meet “the full, objectively assessed needs….for
housing…..as far as is consistent with the policies set out in this Framework3”.
Government Planning Inspectors examining Local Plans are taking a tough line on this.
Draft plans without a credible housing strategy are being rejected. Development
applications for new homes which conflict with adopted local policy are often being
approved on appeal because existing Local Plans cannot demonstrate an adequate supply
of land for housing.
Natural population growth also means that Redbridge Children’s Services must find sites
for several new primary and secondary schools, as well as undertaking major expansions
at a number of existing schools. The most recent Redbridge Community Infrastructure
Plan estimates that in the period 2015-2030 the borough will require facilities to house an
additional 6,570 childcare places, three new Primary Schools and at least five new High
Schools in addition to planned expansions at the Beal, Mayfield, Woodbridge and Oaks
Park High Schools. The NHS is also seeking sites for new Polyclinics. Such facilities often
require large amounts of land, but the supply of sites which are sufficiently large and likely
to become available is extremely limited.
Housing Targets and the Consequences of Under-Delivery
The current target for new homes in Redbridge as set out in the London Plan is 760 per
annum. This is expected to rise to 1,123 per annum as a result of a review of housing land
availability recently undertaken by the Greater London Authority (GLA) in conjunction
with the London boroughs. The new target still falls well short of meeting full housing
need (2,000 per annum), but is based on a pragmatic assessment of the supply of land
with realistic prospects of being redeveloped for housing.
Actual housing delivery since the economic downturn has fallen well short of any of the
above targets as shown in Figure 4 below:
1
Redbridge Housing Needs and Requirements Study (ORS, 2010). National Planning Policy Framework (CLG, March 2012), paragraph 7. 3
Ibid, paragraph 47. 2
8
Figure 4 - Housing Completions - 2003/04 to 2013/14
Housing Completions
1600
1351
1400
1333
1200
Units
1000
885
794
800
607
618
515
600
400
348
247
271
239
200
0
Financial Year
Source: Redbridge Monitoring Report 2012/13, 2013/14 internal completions data
The consequences of housing completions lower than the London Plan’s housing target
for Redbridge have included an increase in overcrowding, growing numbers of Houses in
Multiple Occupation (HMOs) and more unlawful “beds in sheds”. In the period between
the 2001 census and 2011 census the average occupancy of all Redbridge households rose
from 2.56 people to 2.82 people. This general trend was repeated across London and is a
remarkable turn-around because it follows a century-long trend of falling household sizes.
It is also relevant to note that whilst housing completions have been below the London
Plan targets for the borough, population growth has been far in excess of that projected
when the housing targets were set. This re-enforces that much of the borough’s
population growth is occurring as a result of an increased birth rate rather than the
construction of new housing. New housing is required to accommodate the growing
population, otherwise the living standards of residents will suffer through overcrowding,
affordability and illegal forms of housing.
The 2010 Strategic Housing Market Assessment (SHMA) reported that 12,355 households
(12% of the Borough’s households) were living in unsuitable housing, of which 5,848
households were found to be overcrowded. Smaller, privately rented units are often the
only feasible option for residents faced with the high cost of family sized housing and the
shortage of affordable properties.
9
The SHMA also identified a mismatch between housing need and the composition of the
existing stock. There is an oversupply of larger privately owned homes resulting from the
phenomenon of “empty nesters” where children have grown up and left home. Market
demand is overwhelmingly for smaller dwellings. Conversely, social housing demand is
overwhelmingly for larger family homes.
Redbridge Local Plan 2015-2030 must demonstrate that the Council is doing all it can to
meet the housing and other needs of future residents while preserving (and where
possible improving) the quality of life of existing residents.
Meeting the Challenge Sustainably
The 2013 Preferred Options Report proposed a Redbridge “Model” of sustainable
development based on balanced growth in which economic, social and environmental
goals are all seen as equally important. Based on this model it set out criteria for
identifying where new development should go to achieve sustainable development:

Close to the jobs, services and facilities of town centres.

Where there are deliverable sites with substantial capacity for homes and
infrastructure.

To avoid land which floods or is environmentally sensitive.

Where good transport connections are available.

In areas where public open space can be made available for recreation.

To protect established residential character and built heritage.

In the fastest growing parts of Redbridge where need is greatest.

Where carbon dioxide emissions can best be mitigated.

Where the land can be used efficiently and regeneration and high quality design
can be achieved.
As part of the evidence base for the revised Local Plan comprehensive studies were
undertaken to identify all sites in the borough exceeding 0.25ha in area and with realistic
prospects of being redeveloped (either residential / other uses, including infrastructure).
Almost 200 of these “Development Opportunity” sites were listed in the POR (refer
Figure 2).
Applying the sustainability criteria developed above, five broad “Investment Areas” were
identified which include the great majority of these Development Opportunity sites. Each
is distinctive and could support a balanced mix of land uses, helping to revitalise town
centres and local employment and leisure opportunities while also providing new
community facilities and homes.
10
The fivee Investmen
nt Areas we
ere based a round:

Ilford Metro
opolitan Ce
entre and Ilfford Lane Local
L
Centre
e

The Crossrail Corrido
or (includi ng land in and aro
ound the King Georrge and
Goodmaye
es Hospitalss)

Gants Hill District
D
Centre

South Woo
odford Distrrict Centre

Barkingside
e District Ce
entre
The pro
oposed Inve
estment Are
eas are sho
own in Figure 5 below.
Figure 5 - Investm
ment Areass (original Preferred Options
O
Re
eport - 20113)
11
Based on the Investment Area strategy and the identified Development Opportunity sites
and making an allowance for smaller, unanticipated “windfall sites”, the POR established
that the Council should be able to meet the proposed minimum London Plan housing
supply target for Redbridge of 1,123 dwellings per annum. Although short of full assessed
need, the Council took the view that a higher target would be unsustainable because it
would require extensive building on open spaces or environmentally sensitive land and
raising housing densities to the point where the quality of life of established suburbs
began to suffer4.
Sustainable development is all about balance. National planning policy recognises this
and the Council considered that the POR proposals struck an appropriate overall balance
between providing for growth and ensuring that the quality of life of existing and future
residents could be maintained and improved.
4
Under the NPPF (para. 47), the Council needs to ensure that its 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.’ 12
Section 3: The Inclusion of Oakfields
In developing its evidence base for the Local Plan and as required by national guidance,
the Council commissioned an independent review of Green Belt boundaries in 2010.5 This
review concluded that a number of parcels of land were not meeting the purpose of Green
Belt land. Under Government policy this purpose is to stop neighbouring towns merging
into one another and prevent urban sprawl. One of these parcels of land was the Oakfields
playing fields. The report found that the presence of the London Underground Central
Line embankment and the construction of buildings for the Redbridge Sports and Leisure
Centre had severed Oakfields from the broader green belt and compromised is ability to
fulfil this purpose. Having accepted the recommendation to release Oakfields the Council
then considered the best use that could be made of the site if it was no longer protected
as Green Belt.
The POR proposed that the Redbridge Sports and Leisure Centre should not be
redeveloped, but that the remainder of the site could deliver a major mixed-use scheme
with a new school, health clinic and residential development. The report did not propose
the exact number of homes which could be accommodated. This was to be determined
through a further master planning process, but initial estimates are that something in the
region of 800 homes could be provided on the 22.4 ha site.
Significant areas of open space were also proposed to be retained with the aspiration of
the site becoming a new garden suburb. Accordingly Oakfields was proposed as a
Development Opportunity site. Oakfields meets many of the goals of the Redbridge Model
of Sustainable Development because:

It is large and can provide for a mix of uses, including those developments which
need big sites such as schools.

It is adjacent to the services and facilities of Barkingside Town Centre which is
currently being improved through the “Better Barkingside” project.

It is close to the Fairlop London Underground Central Line Station and has good
bus services.

Redbridge Sports and Leisure Centre and Fairlop Waters Country Park provide
excellent nearby indoor and outdoor recreation facilities.

It is not fragmented into multiple ownerships which might otherwise delay the
assembly of the site for redevelopment.
5
Redbridge Green Belt Review (Colin Buchanan, 2010). 13
Oakfields is also an important local open space and a sporting asset of regional
significance. In addition to sporting clubhouses, the Old Parkonians Cricket and Football
Clubs in particular have made a significant investment over many years to develop high
quality playing pitches. The clubs have leasehold tenure only and in order to carry out the
POR proposals, it would necessary to relocate their activities in whole or part to an
alternative site, or risk losing an important recreational and sporting asset from the
borough.
Representations Objecting to the Oakfields Proposals
The purpose of consulting on the Preferred Options Report was to test the Council’s basic
approach before the Local Plan was finalised with a detailed suite of policies.
Representations received on the report were generally supportive of the overall
Investment Area strategy, but a variety of views were expressed about a number of
individual sites.
A large number of representations were received in relation to the Oakfields Playing
Fields, many after the formal close of consultation. These came from organisations
currently using the site and from local residents. The representations overwhelmingly
objected to the Council’s proposals on the grounds that Oakfields provides a valuable
regional facility for sporting clubs (notably football and cricket) and recreational open
space for local residents that should not be lost. The London Playing Fields Association
also wrote to support the objections on these grounds. Other significant points of concern
raised in objections included the ability of the local road network to handle the increase in
traffic volumes which could result and the impact of new development on the amenity of
residents living in close proximity to Oakfields.
In response to the large number of objections to the Oakfields proposals the Council
decided that a further study should be undertaken to determine what alternative
strategies might be available while still delivering the overall ambitions of its Local Plan.
14
Section 4: Potential Strategies
Oakfields is a large site and makes a significant contribution to delivering the overall
Investment Area strategy as set out in the POR. If it is not redeveloped, another means of
providing the homes and facilities proposed for Oakfields will have to be found, or the
Council will need to deal with the consequences of not delivering them.
A number of representations acknowledged the borough’s need for new homes and
community facilities but expressed the view that these should be provided somewhere
else that did not entail the loss (in whole or part) of an important sporting and recreational
facility. However, as background evidence for the POR the Council undertook a number of
studies to identify all significant sites with realistic prospects of being redeveloped and
these have already been taken into consideration.
Since the POR was published the Greater London Authority has prepared a new Londonwide Strategic Housing Land Availability Assessment. This provides a very up to date
picture of all sites with development potential exceeding 0.25 ha in area across all the
boroughs. The stark reality in Redbridge is that there are no alternative, but previously
overlooked available sites, of sufficient size to substitute for Oakfields.
Sites outside Redbridge
In preparing its new Local Plan the Council has a statutory “duty to cooperate” with
neighbouring local authorities about cross-boundary strategic matters, of which the need
to provide housing is one of the most important. Such cooperation with other boroughs in
East London took place primarily through their involvement in the London wide Strategic
Housing Market Assessment and Strategic Housing Land Availability Assessment (2014),
which informs the London Plan (and any further alterations).
These studies confirmed that Redbridge is not alone in being unable to meet full housing
need. Indeed across London as a whole, need is running at about 49,000 homes per
annum, but identified supply is only 42,000 per annum based on the available sites. The
proposed London Plan housing targets for each borough reflect this shortfall as they are
based on housing land supply rather than housing need. Consequently, none of
Redbridge’s near neighbours in the East London housing market has spare capacity to
absorb the Redbridge shortfall. The Mayor has however indicated at the Examination in
Public (EiP) on his proposed Further Alterations to the London Plan, that he is confident
that any shortfall between housing supply and housing need can be made-up within
London. Additional alterations to the London Plan place an emphasis on individual
boroughs to seek to try to exceed their minimum London Plan housing target in order to
contribute to meeting any London-wide shortfall.
15
To the north of Redbridge, Epping Forest District Council (EFDC) is also in the process of
producing a new Local Plan and is grappling with a similar set of issues. Redbridge has
been holding discussions with this non-London Council about housing need and potential
sources of supply. EFDC is already the recipient of significant out-migration from
Redbridge and so functions as something of a pressure release valve for unmet housing
need within Redbridge.
There are uncertainties about how patterns of migration might change in the future;
however 94% of EFDC is Green Belt land which severely constrains its ability to find new
sites for housing. Discussions with EFDC and other districts in Essex will continue but
without a fundamental change in green belt policy, it does not appear that EFDC will be
able to absorb significantly more of the Redbridge housing shortfall.
The potential strategies
Considering all of the above, there are no easy options, but the Council has nevertheless
identified three alternative strategies which it believes to be credible and to embrace the
realistic range of approaches that are available. All involve difficult choices. They are not
necessarily mutually exclusive. The preferred option may involve a combination of two or
more. The three alternative strategies, along with the original Oakfields strategy are
outlined below and shown on Figure 6.
Strategy 1: Proceed with the proposals for Oakfields as set out in the original POR
This would deliver in the region of 800 new homes, schools and perhaps other community
facilities which are urgently needed in Redbridge. It would help demonstrate to any
examining Planning Inspector that the Council is doing all it reasonably can do to meet
Government planning policy by providing for the housing and infrastructure needs of a
fast growing population.
The site could be developed on a comprehensive basis and so provide a balanced range of
uses as a distinctive place of high housing quality. There would be an emphasis on family
sized housing in a garden suburb setting and significant open space could be re-provided
to cater for local residents. However, it is highly unlikely that the needs of current users
such as the Old Parkonians Cricket and Football Clubs could continue to be
accommodated. Nevertheless, following adoption of the revised Local Plan it would
require detailed master planning and phasing before such a large project could
commence. This time could be used to work with existing users with the aim of finding
alternative land that met their needs.
There are possible alternative locations nearby on Green Belt land which could be
explored and under the National Planning Policy Framework, open recreational sporting
facilities (unlike homes and schools) remain an acceptable use of such land.
16
Figure 6 - The pottential alte
ernative deevelopmen
nt strategie
es / option
ns
nd in and around Goodm
dmayes and King
Strategyy 2: Increasee the propossed developpment at lan
George hospitals an
nd the Ford
d Sports Grouund in Seven Kings / Ch
hadwell Heaath
It is difficult to identify sites
s
other than tho
ose already
y included as development
opportu
unity sites on
o the 2013
3 Preferred
d Options Re
eport (show
wn on Figu re 2). Only one site
alreadyy included in the POR
R could in theory be
e more inte
ensively deeveloped an
nd with
sufficient capacityy to offset Oakfields
O
no
ot being de
eveloped. This site com
mprises land
d in and
around the King George and Goodmaayes Hospittals, Seven Kings Parkk and Ford
d Sports
Ground
d at Goodm
mayes (also shown on Figure 2). Like
L Oakfields, this sitee is recomm
mended
for release from th
he Green Be
elt as it no llonger mee
ets Green Belt purposees, and with
h a total
area off 87.69 ha is the largest Develo
opment Opportunity Site
S in the borough. As with
Oakfield
ds, the POR proposed
d a major m
mixed-use redevelopm
ment deliveering new schools
and homes in a Gaarden Subu
urb setting.
17
Although a very large site it is subject to more constraints than Oakfields. Unlike Oakfields
the site is occupied by a number of individual landowners, which could make
comprehensive redevelopment more difficult to achieve.
The original Goodmayes Hospital buildings are locally listed which will require their
sensitive conversion to residential purposes. Some other hospital facilities will continue to
function on the site even after redevelopment. Seven Kings Water is a source of potential
flood risk and an important habitat corridor, but also a significant environmental asset
which should be a centrepiece of any redevelopment. Seven Kings Park is a highly used
park warranting retention. Demand for school places is strongest in the south of the
borough and consequently up to two schools are already envisaged for the site whilst also
retaining the existing hospitals. Because of these considerations, the site was considered
capable of delivering a similar number of homes to Oakfields (i.e. about 800).
Apart from Seven Kings Park (which would need to be retained as protected open space),
the only part of the site used for sport and recreation is the Ford Sports Ground. This is
privately owned land. It is not open to the public and is less well used than when the Ford
Motor Company was a major local employer. The POR proposals did not attract objection
from the landowner or local residents or sporting clubs.
The site is not as accessible as Oakfields and is relatively more car dependent. The POR
recognised that redevelopment should be accompanied by enhanced bus and cycle links
to town centres and stations along the Crossrail Corridor to the south and Central Line to
the north-west. It would be possible to achieve a more intense development outcome
from this site than that proposed in the POR. However, there could be negative
consequences as well.
Further intensification of the current proposals for this site would require a housing mix
with more flats at higher densities and with less retained open space, as to completely
offset the loss of Oakfields on this site alone would require a development yield twice that
currently envisaged (1,600 homes rather than 800), as well as three schools compared to
the two currently proposed. This is unlikely to be compatible with garden suburb
aspirations or with the overall planning strategy of locating the most intense and highest
density development near public transport nodes and town centres while delivering
mostly lower density family housing elsewhere. The character and setting of the locally
listed Goodmayes Hospital could also be threatened by the more intensive development
of the site.
18
Strategy 3: Designate a western corridor running from Woodford Broadway / Woodford to
South Woodford and Wanstead
This strategy is based on the concept of allowing for the intensification of development in
town centres and along transport corridors which are not currently subject to Area Action
Plans or part of the five Investment Areas.
Area Action Plans are in place for Ilford, Gants Hill and for the Crossrail Corridor running
east from llford through the town centres of Seven Kings and Goodmayes to Chadwell
Heath. These Area Action Plans were well researched, contain pro-growth policies and are
considered to embrace the reasonable development potential of these locations.
Area Action Plans have not been prepared for other town centres or transport corridors in
Redbridge, partly because they do not have a large supply of identified developable sites
and partly because many are not subject to the population growth pressures facing the
borough’s north and south. Nevertheless, additional development potential could be
unlocked in a western growth corridor running from Woodford Broadway / Woodford to
South Woodford District Centre (already part of an Investment Area) and on through
Wanstead.
Principally this could be achieved by raising building heights and density outcomes within
the town centres and along major corridors such as Woodford High Road. Expanded town
centre boundaries could also be considered.
As a rough illustration of what might be achieved, there are eight Development
Opportunity sites currently identified and adopted in this locality. Based on adopted
density policy they have a collective potential to deliver 216 homes (at an average density
of 75 dwellings per hectare) (refer Figure 7). If a higher density outcome for a more central
location such as Ilford Town Centre was assumed (say, 300 homes per hectare, or four
times the current average density envisaged for the sites), the collective development
potential would be 858 homes. That is an extra 642 homes, so this type of strategy may go
a long way towards making up for the loss of housing at Oakfields. A similar approach
would be applied to sites within the corridor not currently identified which come forward
for development within the plan period (i.e. ‘windfall’ sites).
19
Figure 7 - Indicative Housing Yields – previously identified development opportunity
sites (Western Corridor)
Site
Site Address /
Description
Area (ha)
Capacity based
on adopted
policy
Capacity
based on 300
dw/ha.
MO01
2-4 Charteris Road and Woodford
Station, Woodford
0.86
23
258
MO02
Hills of Woodford, 536-564 High Road,
Woodford Green
0.36
14
108
CE01
Station Estate, off George Lane in South
Woodford
0.76
76
228
CE03
73-75 Grove Road and 15-25 Carnavon
Road, South Woodford
0.23
14
69
CE07
38 Grove Hill, South Woodford
0.09
5
27
CE08
96 George Lane and 53-55
Marlborough Road, South Woodford
0.41
41
123
CE11
52 Travistock Road, South Woodford
0.08
5
24
CE16
Gordon House, 31 Woodford Road,
South Woodford
0.07
9
21
2.86
216
858
Total
The approach may be capable of delivering a significant number of new homes, but the
sites are generally too small to accommodate community facilities that require large
amounts of land such as schools. In any case, schools are most urgently required in other
parts of the borough where the child population is growing most strongly.
Higher densities means more flats and this approach may be less compatible with the
character of these locations which is generally that of lower density family housing.
Figure 8 depicts the nature of development that would be delivered at higher densities.
There are several Conservation Areas in this part of the borough which could be put at risk
by intensified development outcomes beyond that currently envisaged. These include
Wanstead Village, Wanstead Grove and Snaresbrook in Wanstead, George Lane and South
Woodford within South Woodford District Centre, and Woodford Green, Woodford Wells
and Woodford Broadway in the Woodford Area.
It is for such reasons to do with lack of large sites and impact on residential character and
conservation values that this area (which is generally free from environmental constraints
and is highly accessible), was not proposed for inclusion in an Investment Area in the
original Preferred Options Report. However, should Oakfields not come forward due to the
potential loss of playing fields, traffic and residential amenity issues, alternative site /
strategies are required to meet the borough’s housing target under the London Plan.
20
Figure 8 - Develo
opment at 300
3 dwellin
ngs per he
ectare
Typical d
developmen
nt outcomess:
TTypical exam
mple
Scale:
 Min: 5 storey
 Mid: 6/7 storey
 Maxx: 9 storey
Unit typees:
 Main
nly flatted. Small propo
ortion of
maissonettes/du
uplex units
 82%
% 1 and 2 bed
d
 18%
% 3+ bed
 Av 1
1.7 beds per unit
Mixed usse:
 Yes – mainly tow
wn centre lo
ocations
Car parkking (amount / type):
 52%
% car parking
g
 Majo
ority baseme
ent car park
Amenityy Provision (a
amount / typee):
 Balcconies – modest co
ommunal
gard
dens
Note: thee above figure
es were derived from an asssessment of nine develop
pment propossals (mostly in
n London)
built at d
densities rang
ging from 270
0 – 367 dwel lings per hecctare. They are provided too give an indication of
the nature of schemess built to a de
ensity of 300 d
dwelling per hectare.
h
ge parcels off green belt land.
Strategyy 4: Release further larg
This strrategy is disstinct from the limited
d release of green bellt land whicch the Cou
uncil has
endorseed as a ressult of the Redbridge
R
Green Beltt Review co
onducted inn 2010. Tha
at study
recomm
mended release of a number of ssites (includ
ding Oakfields) on the grounds th
hat they
no long
ger fulfil the
e functionss of green b
belt land as set out in Governmennt planning
g policy.
This altternative sttrategy wou
uld argue ffor the release of furth
her sites onn the groun
nds that
the bo
orough’s ne
eed for ho
ousing and
d commun
nity facilitie
es outweigghed the need
n
to
continu
ue to prote
ect green belt
b and th
hat the harrm arising from loss of green belt
b was
preferable to the harm thatt may arisee from oth
her strategiies, such aas higher densities
d
altering
g the characcter of established res idential are
eas.
21
Redbridge contains over 2,000ha of green belt and much of this land is relatively free from
other constraints and potentially developable if the policy restrictions associated with
green belt were removed. It contains many large sites and several of these have already
been advanced for housing in representations by developers on the original 2013
Preferred Options Report proposals. These sites include land to the south of Roding
Hospital, the ‘Nine Acre Site’ (Roding Lane North, Woodford Bridge), land at Tomswood
Hill, and land to the south of Billet Road, Little Heath), In response to these representations
the Council carried out an Addendum to the Green Belt review in 2013. Although it did not
recommend releasing these sites for housing on the basis that they genuinely fulfil
important green belt functions, it is also apparent that some sites are more critical to
green belt integrity than others.
There are also strong sustainability arguments in favour of developing some green belt
land. For example green belt sites to the immediate east of Barkingside and Fairlop
London Underground Central Line Stations could provide highly accessible locations for
new residential suburbs with reduced reliance on the private car.
A further potential location is Five Oaks Lane over which a Compulsory Purchase Order
(CPO) has now been confirmed (shown on Figure 2). The site has an area of 21.2ha
(comparable to Oakfields) and an existing permission for Countryside Homes to develop
425 dwellings. The land is in the Green Belt, but permission was granted on the basis that
redevelopment would eliminate a legacy of unlawful use and improve the local
environment.
The current scheme represents a low yield outcome for a site of this size, but this was
justified by the design and Green Belt designation. This concentrated development at the
western end of Five Oaks Lane, allowing the eastern part of the site to be returned to open
space and thus improve the functioning of the Green Belt locally. Work is about to start on
the approved scheme following the recent confirmation of the Compulsory Purchase
Order.
Expansion of the development area to the south could result in the scale needed to
provide greater support facilities but the area needed to compensate for Oakfields would
run counter to Green Belt policy and be inconsistent with the need to achieve sustainable
development because of its location in open countryside away from public transport
nodes and town centre services.
In general terms, this strategy would run counter to both national planning policy and the
Mayor’s London Plan because it would do harm to the functioning of the green belt in
Redbridge. The Local Government Minister in a written statement on 17 January 2014
noted “the Secretary of State’s policy position that unmet need, whether for traveller sites
or for conventional housing, is unlikely to outweigh harm to the green belt and other
harm to constitute the “very special circumstances” justifying inappropriate development
in the green belt.
22
While only a modest further release of green belt may be required to offset the
development proposed for the Oakfields site, this strategy could be seen as a precedent
for releasing other land that continues to meet green belt purposes because the demand
for housing land is almost insatiable. Nevertheless, in a borough experiencing such high
population growth and with so many competing demands on the limited available land, it
is important that this option is considered.
Doing nothing is not an option
Each of the potential options has its strengths and weaknesses. However, not selecting
any option is not considered a realistic option in the context of the Council’s national and
regional obligations in preparing its Local Plan.
National planning policy indicates the Council must plan to meet objectively assessed
housing need and this point will certainly be tested at Examination. The Mayor of London
may object and there is a risk that a Planning Inspector may find the Local Plan to be
‘unsound’ (i.e. reject the Plan) so that it could not be adopted.
In the meantime, developers may exploit the situation by advancing housing proposals on
unsustainable sites. This could lead to “planning by appeal” in which the Council’s refusal
of such applications are overturned at appeal because the Local Plan is not up to date and
does not contain a credible housing strategy to seek to meet housing need to the fullest
extent possible. Housing schemes may proceed anyway, but in an unplanned fashion on
sites not preferred and identified by the Council and public.
Even with the inclusion of Oakfields (or an alternative/s) the Council will not be able to
identify sufficient housing land to provide for full need, but including Oakfields (or an
alternative/s) will add significantly to capacity and help demonstrate that the Council is
doing everything it can to meet demand. The inclusion of Oakfields (or an alternative/s) is
required to meet the proposed London Plan housing target for Redbridge (1,123
dwellings per year); not meeting this target would in all likelihood mean the draft
Redbridge Local Plan 2015-2030 would be found unsound (i.e. rejected).
The Mayor’s proposed Further Alterations to the London Plan identifies a London-wide
shortfall of housing supply (42,000 homes per year) compared to need (49,000 homes per
year). The Alterations place significant obligations on boroughs at an individual level to
seek to address the shortfall at the local level. That is, in preparing their Local Plans, the
Mayor expects the boroughs to ‘do more’ and seek to exceed their London Plan housing
target. To do nothing with respect to Oakfields (i.e. neither proceeding with Oakfields nor
an alternative strategy to offset its loss and ensure the Council can meet its minimum
target) would be ‘doing less’ and would almost certainly attract objection from the Mayor.
23
24
Section 5: Selecting the Most Sustainable Strategy
To help identify which strategy represents the best way forward for the borough as a
whole a sustainability appraisal of the different options is attached at Appendix B. It is not
necessary to read the sustainability appraisal in order to comment on this report, but
readers may find that it clarifies some of the issues.
The appraisal examines the strengths and weaknesses of each strategy in meeting the
objectives of the Redbridge Model of Sustainable Development which was set out in the
POR and which received generally favourable comment in representations. It also
considers any measures which might be employed to mitigate negative consequences
arising from particular options.
The Council has not at this stage come to a view about which strategy (or strategies) is the
most appropriate. It wishes to know the views of residents and stakeholders before
coming to a decision. A response form is attached at Appendix C. This includes a number
of questions that the Council is especially keen to hear views about, but you are welcome
to include comments about any other aspects of this report that you think are warranted.
25
26
Appendix A: The Evidence Base

Green Belt Review (Colin Buchanan 2010) – This assessed the extent to which parcels of
green belt land in Redbridge were meeting the purposes of such land as set out in
Government planning policy. In a few cases it concluded they were not and that the
parcels of land should be removed from the green belt.

Strategic Flood Risk Assessment (AECOM 2011) – This study identifies and maps the risk of
flooding from all sources across the whole borough.

Community Infrastructure Plan (LBR, updated annually) – This plan provides an up-to-date
assessment of the amount and cost of essential community infrastructure (e.g. schools,
health clinics, leisure centres etc) needed to support growth in the borough and to make
up for existing shortfalls.

Open Space Assessment (LBR, 2012) – This assessment classifies the many parcels of
protected open space in the borough according to their size, quality and accessibility, and
identifies areas of deficiency.

East London Strategic Housing Market Assessment (ORS, 2010) – This provides information
on the level of need and demand for housing and the opportunities that exist to meet it
across boroughs in London’s east.

Redbridge Strategic Housing Land Availability Assessment (LBR, 2008) – This is a review of
land within Redbridge that is potentially available and suitable for housing.

Redbridge Strategic Housing Market Assessment (ORS, 2010) - This provides information
on the level of need and demand for housing and the opportunities that exist to meet it in
Redbridge.

London Strategic Housing Land Availability Assessment and Housing Capacity Study (GLA,
2009) – This is a review of land within the whole of greater London that is potentially
available and suitable for housing.

Greater London Strategic Housing Market Assessment (GLA, 2009) - This provides
information on the level of need and demand for housing and the opportunities that exist
to meet it across the whole of greater London.

Redbridge Gypsy and Traveller Accommodation Needs Study (LBR, 2012) – This identifies
the likely need for need accommodation pitches in Redbridge in the period to 2028.

Redbridge Retail, Leisure and Office Demand Study (Oxford Retail Consultants, 2012) – This
sets out the need for land and floor space to support retail, leisure and other commercial
activities in Redbridge.

Industrial and Employment Sites Review (LBR, 2012) – This considers the need for industrial
land in Redbridge and the land available to meet that need.
These documents are available on the Council’s website http://www2.redbridge.gov.uk/cms/planning_land_and_buildings/planning_policy__regeneratio
n/local_development_framework/core_strategy_review.aspx
27
28
Appendix B: Sustainability Appraisal
Assessment Criteria
Sustainability appraisal is not an exact science. It is simply an organised way of helping us think about the implications of different policy choices. In this
case the Council has elected to consider how each of the four alternative strategies performs against a number of “sustainability criteria”. These criteria
have been drawn from the Redbridge Model of Sustainable Development, which was published in the Core Strategy / Redbridge Local Plan Review
Preferred Options Report (POR) in January 2013 and are set out below. Representations on the POR showed that the proposed Model was generally well
received by the public and stakeholders. Given this, the sustainability criteria proposed to be used to consider the four alternative strategies take the
form of a series of questions which distil its major features.
The Redbridge Model of Sustainable Development (as contained in the Preferred Options Report 2013)
Over the next 15 years the expected growth of the Redbridge population must be managed and harnessed in ways that improve the quality of life of all
residents, enhance the quality of its natural and built environment and drive a vigorous local economy. In order to achieve this, the Council will work
with its partners and the development industry to ensure that sufficient land becomes available to deliver quality homes and support the needs of all
types of business. In tandem with this, schools, health clinics, policing and leisure facilities and other essential community facilities must be delivered to
provide high quality services where and when they are needed.
Growth will be concentrated in the most accessible locations with available sites, the best public transport options and where the services and facilities
of town centres are readily available to support new residents and in turn to be reinvigorated by them. This will enable established residential areas and
Redbridge’s heritage assets to be protected from excessive development, to preserve their character and the identity of neighbourhoods. Areas at risk of
flooding must be avoided.
Every opportunity should be grasped to make an already good transport network truly excellent, safe and efficient, providing people with a wide range
of options and promoting modes of transport that minimise pollution and the production of greenhouse gasses. The threat of climate change will be
further addressed by locating development so as to minimise the need to travel and by ensuring that the existing building stock becomes more energy
efficient, new development is built to best practice sustainable design and construction standards, and renewable and low carbon forms of energy are
increasingly used. Impacts of the changing climate such as flood risk, water supply, and higher temperatures will be addressed to avoid increased
29
vulnerability of existing and new development.
Redbridge’s green spaces and natural areas are a highly valued resource which should become more accessible to more people. This will involve
opening additional spaces to the public and providing better facilities to promote their use. Wherever possible, development must improve the quality
of our natural landscape, its vegetation and waterways and the species that depend on them.
By 2030 there will be more Redbridge residents and they will come from more diverse backgrounds. They must all have the maximum opportunity to
lead rich and rewarding lives and to plan their own sustainable futures.
The criteria themselves are just a set of straight forward questions designed to tease out the main elements of the Redbridge Sustainability Model, which
have been highlighted above. For each of the seven alternative development strategies they ask:
1.
2.
3.
4.
5.
6.
7.
8.
How well would it meet housing need? (Numbers, type and tenure)
Would it deliver large sites required for community facilities?
Would it preserve open spaces and natural areas?
Will it deliver accessible development and sustainable transport?
How will it protect the character of residential areas and heritage assets?
Will it positively address climate change?
Is it deliverable?
Could negative impacts be addressed?
The whole POR document published in January 2013 was also subject to a sustainability appraisal6. The appraisal involved a framework of 15 objectives
grouped under social, environmental and economic headings. This framework was unnecessarily broad and complex for the consideration of the four
alternative strategies (three of which are focused on offsetting the potential loss of the fourth – Oakfields), but the table below shows how the criteria
above pick up on its objectives to the extent they are relevant to an assessment of the four alternative development strategies.
6
Refer: http://www2.redbridge.gov.uk/cms/planning_and_the_environment/planning_policy__regeneration/local_development_framework.aspx 30
Social Objectives
1.
2.
3
4.
5.
6.
To reduce poverty and social exclusion
None of the strategies are intended to directly address these issues, but they will do so indirectly because the ability to access satisfactory
housing at an affordable price is a key factor in determining whether people are poor or socially excluded. Consequently, criterion 1 above will
pick up on this.
To reduce and prevent crime and the fear of crime
None of the strategies are intended to directly address the issue of crime and it is difficult to think of how the choice of one strategy over
another would have a significant impact of crime levels. Consequently, this objective is not relevant to making the current choice between
strategies.
To meet local housing needs by ensuring that everyone has the opportunity to live in a decent, affordable home
Criterion 1 above responds directly to this objective.
To improve the education and skill of the population overall
The provision of school facilities is obviously a major factor in achieving this objective. Consequently, criterion 2 above reflects this objective to
the extent it is relevant to the current appraisal.
To provide accessible community services and leisure opportunities
Criterion 2 directly relates to providing community services, while criterion 3 relates to leisure opportunities through the provision of open
spaces and natural areas.
To promote healthy lifestyles
None of the strategies are intended to directly address the issue of healthy lifestyles. The availability of health clinics (which some of the four
strategies may be able to deliver) is of course a factor in people’s overall health, but somewhat marginal to the objective which is about
creating lifestyles that promote good health, not going to the doctor to receive treatment for ill health. Consequently, this objective is not
relevant to making the current choice between strategies.
Environmental Objectives
7.
8.
9.
10.
To maintain, enhance and where appropriate conserve the quality of landscapes and townscapes
Criteria 3 and 5 pick up the essence of this objective as it relates to the alternative strategies.
To maintain and enhance biodiversity, species and habitats
Criterion 3 picks up the essence of this objective as it relates to the alternative strategies.
To reduce the effect of traffic on the environment
Criterion 4 is directly relevant to this objective.
To reduce contributions to climate change and reduce vulnerability to climate change
31
11.
To minimise the production of waste and encourage recycling
None of the strategies is intended to directly address the issues of waste and recycling and it is difficult to think of how the choice of one
strategy over another would have a significant impact on these matters. Consequently, this objective is not relevant to making the current
choice between strategies.
Economic Objectives
12.
13.
14.
15.
To encourage sustained economic growth
None of the strategies is intended to directly address the issue of economic growth. The housing and wider construction industry is of course a
vital part of the local economy and so criteria 1 and 2 may have some indirect relevance to this objective.
To improve incomes and living standards
None of the strategies are intended to directly address the issues of incomes and living standards and it is difficult to think of how the choice of
one strategy over another would have a significant impact on these matters. Consequently, this objective is not relevant to making the current
choice between strategies.
To enhance the image of the area as a business location
The strategies all relate in one fashion or another to the provision of homes, community facilities and open space. The choice of one strategy
over another would have little if any impact on the image of local business areas. Consequently, this objective is not relevant to making the
current choice between strategies.
To provide a high quality, reliable transport network to support the development of the Borough
32
The Sustainability Appraisal Matrix
This symbol
means the strategy performs well. This symbol
means performance is mixed. This
means performance is poor.
Strategy 1: Proceed with the proposals for Oakfields as set out in the original POR.
Sustainability
Criteria
Discussion
How well
would it meet
housing need?
(numbers,
type and
tenure)
Initial indications are that the site if developed in a balanced way as proposed in the POR may deliver in the region of
800 homes during the lifetime of the plan (i.e. up until 2030). This is a significant number and would make Oakfields,
along with the hospitals site at Goodmayes, one of the two largest Development Opportunity Sites in Redbridge.
The number does need to be seen in perspective. Housing need is currently running at around 2,000 dwellings per
annum, so developing Oakfields will not (at least on its own) solve the housing shortfall, but failure to develop
Oakfields will add significantly to an already large housing deficit.
Would it
deliver large
sites for
community
facilities?
Yes. Oakfields is large enough to deliver sites for a school and for a health Polyclinic, along with housing and open
space (new and retained). Both Redbridge Children’s Services and the Redbridge NHS have indicated there is a need
for such facilities in this general area.
Would it
preserve open
spaces and
natural areas?
The site is currently open space used by sporting clubs, although it hosts some relatively small buildings which act as
clubhouse/changing room facilities. It is mostly grassed playing fields, but is not a natural area in the sense of having
strong biodiversity value. Most of the open space would be lost if the development as envisaged in the POR went
ahead. The stated intention is to retain significant areas of open space for recreation (including Redbridge Sports
and Leisure Centre) and to provide the setting for a “garden suburb”, but it does not appear likely that space
adequate within the Oakfields re-development for the needs of the football and cricket clubs which now use
Oakfields could be found, in addition to the land needed for 800 homes and community facilities. A new site would
therefore need to be found for these clubs
33
Performance
Sustainability
Criteria
Will it deliver
accessible
development
and
sustainable
transport?
Discussion
Oakfields is a highly accessible site. It is close to the retail facilities and other services of Barkingside Town Centre,
which is served by numerous bus routes. The 128, 150, 167, 169, 247,275 and 462 routes provide connections to
Walthamstow, Woodford, Loughton, Hainault, Romford, Beacontree Heath, Ilford and Gants Hill, while the N8 night
route provides a service to London Victoria. It is very near (around 200m at the closest point by walking) to Fairlop
London Underground Station. This Central Line station is currently located in the middle of largely undeveloped
green belt land. A significant residential development at Oakfields would be in accordance with the principle of
transit-oriented development and add to the sustainability of the public transport system.
The Redbridge Sports and Leisure Centre is adjacent to Oakfields and Fairlop Waters Country Park can be accessed
by a short walk (around 300m). Consequently, residents of any new development at Oakfields would have access to
excellent quality indoor and outdoor sporting facilities.
Some representations objecting to the proposals for Oakfields suggested that the local road network (especially
Fulwell Cross round-about) was already over-capacity and could not cope with additional traffic loadings. While
future residents of Oakfields may enjoy good public transport options, the reality is that many will want to own and
use cars. Consequently, some worsening of highways conditions would be expected unless measures could be put
in place to alleviate this.
How will it
protect the
character of
residential
areas and
heritage
assets?
Development at Oakfields would adjoin existing residential suburbs to the north and west. These are characterised
by family housing, but do not enjoy special status as Conservation Areas or Residential Precincts. There are no
adjacent heritage assets such as listed buildings. A development of mostly family housing in a garden suburb setting
as envisaged by the POR would be in keeping with the character of this surrounding residential area and would not
affect the setting of heritage assets. There are approximately 160 residential properties whose rear gardens adjoin
the Oakfields site. Any redevelopment scheme would have potential impacts on these properties. Directing housing
to large sites such as Oakfields would however enable the Council to seek to protect the character of existing
residential areas across the borough from infill flatted development.
Will it
positively
address
climate
The answer to this question would largely depend on decisions taken at a much later date when planning
permission is being sought, about the nature of the dwellings and other buildings which are constructed and the
standards they meet for CO2 emissions. These standards are likely to be applied consistently to all new buildings
across the borough and so would be the same for buildings constructed under all the alternative strategies.
34
Performance
Sustainability
Criteria
Discussion
change?
However, the site’s location means that it is highly accessible (see above) and by reducing the need to travel will
help minimise greenhouse gas emissions associated with transport. It is however, subject to surface water flooding
(generally flooding extends in a north to south direction through the middle of the site) and one of the predicted
effects of climate change is to exacerbate flood levels and frequency.
Is it
deliverable?
The whole site is owned by London Borough of Redbridge. There are some leases to the sporting clubs that currently
occupy the site, but there are no known major impediments to bringing it forward for redevelopment if this strategy
is adopted.
Could negative The main negative impact associated with this strategy is the loss of a large area of open space used by established
sporting clubs and valued by local residents. Some of this space would be reprovided within any resulting
impacts be
development, so the loss would not be complete and alternative extensive areas of open space exist nearby at
addressed?
Fairlop Waters Country Park and excellent indoor sporting facilities are available at the adjacent Redbridge Sports
and Leisure Centre. Nevertheless, the Old Parkonians Cricket and Football Clubs would likely lose the good quality
pitches and facilities they have developed at Oakfields over many years. In order to address this, another site would
need to be found.
Open sport and recreation and associated small scale clubhouse facilities are an acceptable use of green belt land
and extensive areas of green belt exist to the east of Oakfields across the London Underground Central Line
embankment. Following adoption of the revised Redbridge Local Plan, it would take at least several more years of
detailed planning to translate the proposals for Oakfields into reality. Consequently, there would be significant time
to explore whether an alternative parcel of land could be found which was (or could be made) suitable for the needs
of these clubs.
Prior to any final decision being made as to whether to include Oakfields as a development opportunity site in the
draft Redbridge Local Plan 2015-2030, the Council would engage consultants to undertake a traffic study which
would model the effects of the Oakfields and other proposals on the local highway network and intersections. The
study is yet to be carried out, but it would be expected to highlight any improvements required to allow local roads
to cope with the traffic volumes expected to be generated.
Any redevelopment would need to be designed so that it was especially sensitive to the approximately 160
residential properties which back onto the site. In principle this is achievable, but much would depend on the final
35
Performance
Sustainability
Criteria
Discussion
Performance
design for which planning permission was sought.
The site suffers from some surface water flooding. Subject to the “exception test”7 it may be feasible to locate flood
sensitive uses such as residential housing in Flood Zones 2 and 3a, but the functional flood plain (Zone 3b) would
need to be avoided. This land could be used for recreational open space and as an essential part of a sustainable
drainage system for the overall site.
Overall
Comment
The overall strength of this strategy is its ability to deliver homes and community facilities in a highly sustainable
location. This must be balanced against the loss of a major open space and outdoor sporting facility of regional
significance. It is possible that this loss could be partly or entirely off-set if another suitable site could be found on
nearby green belt land. There would appear to be sufficient time to explore this, given that it would take a number
of years to put the Oakfields proposals into practice, however there are no cast-iron guarantees that a positive result
would be achieved. The possibility has to be faced that this strategy could leave the Old Parkonians Cricket and
Football clubs without a home.
Strategy 2: Discontinue the proposals for Oakfields and increase outcomes on the Goodmayes / King George Hospitals / Ford Sports Ground
Major Development Opportunity site. Oakfields would continue to be used as it is now.
Sustainability
Criteria
Discussion
There is only one identified Major Development Opportunity site at which this strategy could potentially be
delivered –Goodmayes / King George Hospitals / Ford Sports Ground. The 2013 Preferred Options Report identified
the site as being potentially capable of accommodating up to 800 new homes, two new schools and potentially a
polyclinic, whilst retaining the existing hospitals. In the context of the current consideration of alternative options to
offset the potential loss of Oakfields as a development site, the Goodmayes / King George Hospitals / Ford Sports
Ground, has been identified as potentially capable of delivering an additional 800 homes and a further new school
How well
would it meet
housing need?
7
See National Planning Policy Framework (DCLG March 2012) paragraph 102. 36
Performance
Sustainability
Criteria
Discussion
(i.e. a total of 1,600 homes and three schools).
To allow for the significant increase in the number of homes to be delivered, site would see a greatly increased
density when compared to the proposals set out in the Preferred Options Report. This would result in a different
housing mix than that proposed in the POR, with more flats needed which would not meet the Council’s aspiration
for a garden suburb setting. This strategy would also fail to satisfy the requirement for more family size homes within
the Borough.
Would it
deliver large
sites for
community
facilities?
The POR proposals for Goodmayes Hospital site include the provision of new primary and secondary schools as well
as a Polyclinic, demonstrating the sites ability to deliver community facilities. However, whether or not the site could
accommodate an additional school originally intended for Oakfields is uncertain given the size of the site and
existing and previously proposed uses. It would also result in a significant concentration of schools in one area,
rather than being distributed throughout the borough.
Would it
preserve open
spaces and
natural areas?
The 2013 Preferred Options Report proposed a lower density scheme this site in order to provide predominantly
family sized housing in a garden suburb setting and also due to the constraints presented by Seven Kings Water
such as flooding and it’s designation as a Site of Nature Conservation Importance. If housing yield was to be doubled
as is proposed by this strategy (to offset the potential loss of Oakfields as a development opportunity site), less open
space could be preserved than anticipated in the original POR. Regardless of how many homes were delivered on
this site, Seven Kings Park would be retained due to its status as Protected Open Space.
Will it deliver
accessible
development
and
sustainable
transport?
Whilst being relatively accessible, the site at Goodmayes and King George Hospitals and Ford Sports Group does not
compare favourably with Oakfields with regards to both access to public transport and distance to town centre
amenities. The closest point of the proposed site to Newbury Park Underground Station is approximately 1 km
walking distance, whilst Oakfields is within 200 m of Fairlop Underground Station. Goodmayes Station is
approximately 1 km from the south eastern corner of the site with services due to improve in 2018 following the
commencement of Crossrail. This will allow for much of the site to be within 15 minutes walking distance of direct
rail services to Central and West London. Local bus routes to the Borough’s town centres are quite limited,
particularly to the east of the site. The POR proposed to improve these as well as cycle links to town centres and
stations along the Crossrail Corridor which may go some way towards reducing reliance on private cars.
37
Performance
Sustainability
Criteria
Discussion
How will it
protect the
character of
residential
areas and
heritage
assets?
Any development at the hospital sites in Goodmayes would need to be highly sympathetic to the character of the
surrounding area. Sensitive design would also be required to ensure no damage to the character of the locally listed
Goodmayes Hospital buildings. With a higher density scheme as is proposed by this strategy, this will be increasingly
difficult to achieve particularly with regards to the scale of buildings and the retention of all the buildings with
identified heritage values. Due to the site constraints, increased building heights would likely be needed to achieve
the housing yield of 1,600 therefore making the Council’s ‘garden suburb’ aspirations difficult to realise.
Will it
positively
address
climate
change?
As this strategy would see a large number of dwellings being delivered on one site, there is likely to be a better
outcome with regards to Code for Sustainable Homes and energy conservation than if these homes were delivered
through infill developments and conversions. Dwellings and community facilities built prior to 2016 would be
required to achieve a 35% reduction of carbon emission above Part L of the 2013 Building Regulations. Those built
between 2016 and 2031 would be required to be zero carbon developments. However, residents at this site are
more likely to be reliant on private cars than those of Oakfields due to it being further away from public transport
nodes.
Similarly to Oakfields, the Goodmayes site is subject to surface water flooding (in this case along the course of Seven
Kings Water). As one of the predicted effects of climate change is to exacerbate both flood levels and frequency and
this will need to be mitigated through a comprehensive sustainable drainage system (SuDS).
Is it
deliverable?
The site at Goodmayes Hospital is controlled by multiple landowners which may make any development on the site
difficult to deliver. The risks presented by Seven Kings Water such as flooding and the potential for damage to
habitats are likely to be more difficult to mitigate with a more intense development proposal.
Could negative This strategy presents a number of potential negative impacts that could be difficult to mitigate without reducing
housing outcomes (particularly size and type). Due to the nature of this strategy, if adopted, proposed densities
impacts be
would need to be significantly increased to achieve the housing yields required to compensate for the loss of
addressed?
Oakfields.
The significantly increased densities proposed by this strategy could also result in damage to the existing character
38
Performance
Sustainability
Criteria
Discussion
Performance
of the residential areas bordering the Goodmayes Hospital site. Existing dwellings nearby are primarily low density
family homes, yet to achieve a yield of 1,600 homes on the site substantially higher densities would be required
including the significant use of flats. Due to other constraints on site, such as those presented by Seven Kings Water,
it would be difficult to mitigate the negative effect on the residential character that delivering 1,600 homes on this
site would present.
It is proposed that public transport issues at the Goodmayes Hospital site would be mitigated through the provision
of additional pedestrian and cycle routes to the closest rail and London Underground stations to the site.
Overall
Comment
The delivery of 1,600 homes and additional community facilities at the Goodmayes Hospital site is likely achievable
with increased densities. However, the site has a number of constraints owing both to the natural and built
environment that may difficult to mitigate. The Council’s garden suburb aspirations for the site are likely to be
unachievable if this strategy were to be adopted, but the need for housing within the Borough must be considered
against this.
Strategy 3: Western corridor – Woodford Broadway / Woodford, South Woodford and Wanstead
Sustainability
Criteria
Discussion
How well
would it meet
housing need?
As there are relatively few development opportunity sites available along the identified potential development
corridor of Woodford Broadway – South Woodford District Centre – Wanstead, development would need to be
delivered primarily through increased building heights and density in order to achieve the number of dwellings
envisaged for the Oakfields site at Barkingside. This would allow for a significant amount of housing to be
constructed, however higher densities would mean this being delivered as flatted development. This contrasts with
the Council’s aspirations / identified housing need for Oakfields for family homes to be delivered in low to medium
density developments. As population growth is being driven primarily by a growing birth rate, family sized homes
39
Performance
Sustainability
Criteria
Discussion
have an important role in meeting the housing needs of the Borough.
Would it
deliver large
sites for
community
facilities?
The sites available along this corridor are able to accommodate residential development but are not large enough to
accommodate community facilities such as new schools. New schools demand a considerable amount of land,
making such a development difficult along the proposed corridor. The demand for school places is highest in other
areas of the Borough where the birth rate is growing most strongly, meaning that even if schools were delivered
along this corridor they would not be helping address Redbridge’s shortfall in the most needed locations.
Any site identified would also likely be too small to support enhanced sport and leisure facilities.
Would it
preserve open
spaces and
natural areas?
This strategy would prevent the loss of open space at Oakfields by diverting development to town centres and
established residential areas in the west of the borough. Due to the lack of large sites within the proposed corridor,
the few identified development opportunity sites would need to be developed at higher densities than envisaged
under the current Redbridge Local Development Framework. The high densities required to deliver housing along
this corridor, would make it practically difficult to require additional areas of public open space as part of any
approved development. This issue is particularly pertinent to this strategy as many of the areas incorporated in the
proposed corridor have been identified as being deficient in public open space i.e. children’s playgrounds.
Will it deliver
accessible
development
and
sustainable
transport?
This strategy would see development delivered along the transport corridor defined by the London Underground
Central Line and the network of town centres in the west of the borough. Therefore, any development along this
corridor would benefit from good access to public transport, with three Central Line stations providing direct links to
Central London in approximately 20 minutes.
Woodford Broadway, South Woodford and Wanstead Town Centres provide a number of amenities including retail,
pharmacies and banks. Developments along the proposed corridor would generally be located within walking
distance of one of the above centres to reduce the reliance of future residents on private cars. Wanstead is
particularly well served by bus routes, connecting the area to much of East London. Routes 101, 145, 308, W13 and
W14 provide connections to Manor Park, East Ham, Beckon, Leyton, Leytonstone, Stratford and Clapton. Wanstead
Town Centre is also served by night buses N8 and N55, providing connections to Oxford Circus, Shoreditch and
Hackney.
Owing to the high densities of any proposed developments and their proximity to transport nodes and district
40
Performance
Sustainability
Criteria
Discussion
centres, there is potential for car free developments. This would mean that additional pressures on the existing road
network could be avoided.
How will it
protect the
character of
residential
areas and
heritage
assets?
If significant residential development were to be delivered along the proposed corridor, the character of areas could
be significantly impacted, particularly where an increase in housing yield is achieved through the raising of building
heights or the expansion of town centre boundaries. Any development within Woodford Broadway, South
Woodford and Wanstead Town Centres must be sympathetic to the character of the areas and not negatively affect
their heritage assets. Woodford Broadway itself is a designated Conservation Area meaning that building heights
and densities beyond that currently envisaged under the Council’s LDF are most likely inappropriate. George Lane
Conservation Area in South Woodford could also be vulnerable to intensified development outcomes, as could the
many Statutory Listed Buildings in the vicinity. Snaresbrook, Wanstead Village and Wanstead Grove Conservation
Areas could also be negatively affected by densities above that currently permitted in the area.
The areas adjacent to the centres are predominantly residential in nature, consisting primarily of low density family
homes. Therefore, any expansion of town centre boundaries may negatively impact upon these areas if high density
apartment developments with increased building heights are permitted.
Will it
positively
address
climate
change?
By locating residential development within or near town centres and along transport corridors, the need to travel is
reduced thus lessening the reliance of future residents on private cars. This is preferable to developments proposed
in more remote locations where access to services and public transport is limited necessitating travel by car.
Developments along the proposed corridor have the potential to be designated ‘car free’, minimising any increase in
carbon emissions associated with the development.
Any development delivering five residential units or above must achieve Code for Sustainable Homes ‘ Level 4’, or
‘Level 6’ if planning permission is granted from 2016 onwards. As the Development Opportunity sites identified
within the locality of the proposed corridor each have a yield of over five units, they would need to achieve the
above standards. By achieving Level 6, the developments would comply with a number of challenging sustainability
standards, addressing water consumption, drainage, energy emissions, waste, pollution and ecology. Code for
Sustainable Homes Level 6 requires developments to be ‘zero carbon’, in line with the aspirations of the Council, the
Mayor of London and the Government. However, considering the potential high density of the developments, it may
be difficult to achieve zero carbon due to a lack of available space for renewable energy technologies. For example, a
41
Performance
Sustainability
Criteria
Discussion
lower density development of family homes would have roof space available for solar photovoltaic panels on each
unit whilst a high density apartment development would have very limited space.
Is it
deliverable?
This strategy could face difficulties with regards to deliverability. Although the sites along the corridor generally
have relatively few environmental constraints, there are a number of heritage concerns that would need to be
satisfactorily addressed to deliver this strategy successfully. There may also be issues with landownership as
development would be distributed over a number of sites, the majority of which are not Council owned.
Furthermore, it is likely that to achieve the densities proposed would mean that any car parking provided would
need to be in basements in order to maximise the extent of site available for buildings / amenity space. Basement
car parking is more expensive than surface car parking and would therefore affect the viability of development
schemes, meaning they may not be developed.
Could negative The primary concern raised by this strategy is its potential impact upon the heritage assets and character of the
areas along the proposed corridor. Although the adopted Wanstead Village Enhancement Scheme (for example)
impacts be
states that well designed contemporary development would be acceptable within the Conservation Area, it states
addressed?
that the heights of existing heritage assets must be respected. This would likely be the greatest difficulty for this
strategy to overcome owing to the small sites identified and the 300 dwellings per hectare densities required to
deliver sufficient additional housing to offset the potential loss of housing at Oakfields. Even with good design and
selection of materials, to achieve a density of 300 dw/ha tall buildings would be needed which would negatively
impact upon some conservation areas.
If this strategy were adopted, any development delivered would be unlikely to have ample private amenity space.
Although this would be difficult to mitigate without reducing the housing yield, the homes would benefit from
relatively easy access to both Epping Forest and Wanstead Flats. The areas are also served by playing fields and golf
courses.
Overall
Comment
The main strength of this strategy is its ability to deliver a large number of homes with good access to public
transport links and local centres. A lack of available space and proximity to amenities and Central Line stations offers
a clear opportunity for car free developments, avoiding additional strain on the local road networks and available
parking. However, the heritage assets within the proposed corridor present a significant constraint to development
42
Performance
Sustainability
Criteria
Discussion
Performance
in the area. New development in the vicinity of listed buildings and conservation areas needs to be designed as to
not have an unacceptable impact on these assets, but due to the high density proposed this may prove extremely
challenging. Furthermore, this strategies inability to deliver community facilities is a major weakness when
compared to strategies focused on developing larger opportunity sites.
Strategy 4: Release further large parcels of green belt land.
Sustainability
Criteria
Discussion
How well
would it meet
housing need?
The Borough has over 2,000ha of Green Belt land which has the potential to provide a large amount of homes. Only
a small amount of this land would be required to offset the housing proposed at Oakfields but as this would set a
precedent further amounts could in theory be released for development to allow the Borough to fully meet its future
housing need. To meet Redbridge’s housing need to 2030, approximately 2,000 dwellings would need to be built
annually – this could only be fully achieved through the release of large parcels of land.
Would it
deliver large
sites for
community
facilities?
Similarly to Oakfields, the sites that could be released by this strategy would be sufficiently large enough to deliver a
variety of community facilities. However, depending on the yield of the individual sites and their location, there may
not be a large enough population to make the delivery of facilities such as schools and health clinics feasible.
Would it
preserve open
All land that is currently designated as green belt is open space, with the rare exception of land that is being used
unlawfully. Developing this land would negatively affect the integrity of the green belt and possibly interfere with
Although the area to the south of Five Oaks Lane is large enough to provide community facilities, due to the
remoteness of the site it would be difficult to justify the provision of schools and other facilities without an even
higher housing yield than proposed in this strategy. The density of the site would need to be greatly increased,
causing further damage to the Green Belt. It is therefore unlikely that community facilities could be feasibly
delivered on this site.
43
Performance
Sustainability
Criteria
spaces and
natural areas?
Discussion
the open character of the land.
Much of the Green Belt land within Redbridge is subject to designations including Sites of Nature Conservation
Importance and Green Corridors and development should be deemed inappropriate on these sites if it would have a
negative impact on these designations. However, developers may be able to employ suitable mitigation measures to
avoid the destruction of any habitats.
There is an existing planning consent on Five Oaks Lane permitting the development of 425 homes in a low density
scheme. This scheme was deemed acceptable as the site is currently under unlawful use and the development
could enhance the functioning of the Green Belt locally through the returning of the east of the site to open space. If
an extra 800 homes were to be provided to the south of the site, a large amount of open space would be lost as this
would extend onto sensitive Green Belt land.
Will it deliver
accessible
development
and
sustainable
transport?
How will it
protect the
character of
residential
areas and
heritage
This would vary depending on site location. Development on the green belt land near to Fairlop and Barkingside
London Underground Stations would allow for future residents to have highly convenient access to Central London
via the Central Line. The existing amenities of Barkingside Town Centre would be a short distance from the sites, as
would a number of bus routes, reducing reliance on private cars.
However, most areas of green belt land are relatively remote with poor access to both public transport and
amenities. An expansion of development at Five Oaks Lane to the south, for example, could be inappropriate for this
reason as residents would be highly reliant on cars as sustainable transport options (i.e. public transport) in the area
are relatively limited. As well as increasing carbon emissions, the significant increase of residential units would put
pressure on the local road network and the existing very limited bus service. Many sites located on green belt land
would require significant investment in local infrastructure to overcome the constraints presented when locating
development in rural areas.
The impact on the character of surrounding areas would be dependent both on the nature of the development and
the existing homes adjacent to the site. Sites in more remote locations are likely to damage the character of rural
areas even at low densities. These areas will also be those presenting the highest risk of causing damage to the
functioning of the green belt as a result of major development.
A low density development has been approved at Five Oaks Lane on the grounds that such a scheme could enhance
44
Performance
Sustainability
Criteria
Discussion
assets?
the functioning of the Green Belt by removing existing unlawful uses and consolidating built footprint. The scheme
would allow for a large area of land to the east of the site to be returned to the Green Belt as open space, whilst still
delivering 425 dwellings. If Strategy 4 were to be adopted, it would be necessary to extend development
southwards causing unacceptable damage to the Green Belt.
Will it
positively
address
climate
change?
It would be difficult to predict the effect developments on green belt land would have on climate change as it could
be influenced by a number of variables. Those sites located close to a public transport node will have less of a
negative effect on climate change locally than those located in remote areas with poor access to bus and rail
services. Sites such as to the east of Barkingside Station have the potential to be highly sustainable due to their
proximity to town centre amenities and London Underground Stations. The provision of facilities such as schools
and health clinics on site would also help create sustainable sites by reducing the need to travel thus limiting CO2
emissions.
Areas of green belt land within the Borough are within identified Flood Risk Zones and have also be identified as
being at risk of surface water flooding. Flooding is predicted to be exacerbated as a result of climate change and
therefore any development proposed on land identified as being as risk of flooding would need to incorporate
mitigation measures such as a Sustainable Drainage System (SuDS).
As any development sites on green belt land would be large, each home would be required to achieve Code for
Sustainable Homes Level 6 and Zero Carbon if an application for planning permission were submitted from 2016
onwards.
Is it
deliverable?
Sites within the green belt are owned by a number of parties, potentially causing barriers to delivery if this strategy
were adopted. However, several large Green Belt sites have been advanced for housing in representations by
developers so there is clearly land-owner motivation for these sites to be released for development.
The Compulsory Purchase Order for the site at Five Oaks Lane has been confirmed and work is due to commence on
site shortly to implement the planning permission obtained by Countryside Homes. Therefore it is possible that work
at the site will be too far advanced to accommodate the additional dwellings proposed in this strategy and
consequently development would need to be delivered on land to the south of the site.
45
Performance
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Criteria
Discussion
Could negative With the exception of the sites adjacent to Barkingside and Fairlop London Underground stations and those
generally put forward by developers, the majority of green belt land within the Borough is located in rural areas with
impacts be
poor highway and public transport infrastructure. Access roads to potential sites are often narrow and would not be
addressed?
sufficient to support the additional traffic of 800 homes. Roads leading to any such site delivering a major residential
scheme would require enhancement and improvement works, most likely funded through developer contributions.
Additionally, it may be possible to negotiate enhancements to existing bus services if demand can be demonstrated
to Transport for London. Nonetheless, the distance from amenities such as schools, shops and workplaces mean that
residents would be most likely to travel frequently by car increasing carbon emissions locally and negatively
impacting air quality.
The most significant and contentious impact of this strategy would be the significant negative impact on large areas
of green belt land. The Government has confirmed that meeting housing need is not sufficient reason to justify the
release of green belt land for development and there would therefore be substantial difficulties for any such
proposal in the draft Local Plan being found sound by the Planning Inspectorate. Major residential developments on
green belt land would likely permanently harm the functioning of the green belt and it is not clear if there is any way
that this could be addressed.
Further development of the proposed development at Five Oaks Lane would harm the functioning of the Green Belt
as additional land would need to be released. As the additional land currently meets Green Belt purposes, this would
conflict with Green Belt policy that states “unmet housing need is unlikely to outweigh the harm to the Green Belt
and other harm to constitute the “very special circumstances” justifying inappropriate development on a site within
the Green Belt”. As work is due to commence at Five Oaks Lane to implement the existing planning permission, if
this strategy were adopted it could only be delivered through the release of further land to the south. Therefore,
there is no clear way in which this negative impact could be mitigated.
Overall
Comment
If this strategy was adopted, it could potentially deliver enough housing to fully satisfy the Borough’s identified
housing need to 2030. However, investment would be required to local infrastructure and this could render some
sites either unfeasible or unattractive to developers.
Destruction of functioning green belt land to meet housing need has been deemed unacceptable by the
Government and therefore including this strategy in the draft Local Plan could face significant difficulties when the
46
Performance
Sustainability
Criteria
Discussion
Performance
Plan is considered by Planning Inspectorate. Any proposals for development on functioning green belt land would
be expected to encounter considerable objections from residents as well as from various other bodies.
Summary Table
Strategy 1 - Proceed
with the original
Oakfields option
Strategy 2 –increase
proposed
development at land
in and around the
hospitals site
Strategy 3 - Western
corridor
Strategy 4 – Develop
on Green Belt
Summary
How well would it
meet housing need?
Strategies 1 and 4
would best achieve
this criteria
Would it deliver sites
for community
facilities?
Strategy 1 would best
achieve this criteria,
although strategies 2
and 4 also represent
sites large enough to
deliver community
facilities
Would it preserve
open spaces and
natural areas?
achieve this criteria as
it would be located in
established residential
areas
47
with the original
Oakfields option
proposed
development at land
in and around the
hospitals site
corridor
on Green Belt
Summary
Will it deliver
accessible
development and
sustainable
transport?
Strategies 1 and 3
could both achieve
highly sustainable
development owing to
their sites proximities
to London
Underground Central
Line stations
How will it protect
the character of
residential areas and
heritage assets?
achieve this criteria by
delivering housing that
is in keeping with the
existing dwellings
adjacent to Oakfields
Will it positively
address climate
change?
achieve this criteria,
due to its potential to
deliver car-free
developments on
brown field sites
Is it deliverable?
Strategies 1 and 3
would best achieve
this criteria
48
with the original
Oakfields option
proposed
development at land
in and around the
hospitals site
corridor
on Green Belt
Summary
All strategies present
negative impacts that
may not be possible to
mitigate. However,
these would be
considered further at a
design stage at which
point solutions may be
realised.
Could negative
impacts be
addressed?
49
50
Appendix C: Response Form
51
52
Preferred Options Report Extension – Alternative Development Strategies Response Form
If you wish to discuss the options directly with us before responding, a programme of consultation
events will be held during November and December 2014. Details are available on Redbridge-i
(www.redbridge.gov.uk/ldf) or by phoning 020 8708 2748.
This response form can also be completed online at Redbridge i.
Please respond by 22 December 2014.
1. Do you have any general comments on the planning challenges facing the Borough?
2. What do you think about Option 1 – proceed with Oakfields?
3. What do you think about Option 2 – Find another site - increase the proposed development
at land in and around Goodmayes and King George hospitals and the Ford Sports Ground in
Seven Kings / Chadwell Heath?
4. What do you think about Option 3 – Western Corridor - Woodford Broadway / Woodford,
South Woodford and Wanstead?
5. What do you think about Option 4 – Develop Green Belt land?
6. Overall, which option do you think is best for the borough and why?
7. Are there any other realistic alternatives that the Council should consider? If so please state below:
Feel free to attach additional pages explaining your answers above.
8. Please provide your name and address details below:
Name:
Address:
Post Code:
Email:
Please note that survey forms where no post code is given will not be accepted.
9. If you are responding on behalf on an organisation, please give the organisation’s name and
your position below:
Submitting this form:
There are a number of ways to send your completed form to us:
Complete online:
Scan and e-mail:
www.redbridge.gov.uk
[email protected]
Fax:
Freepost:
Preferred Options Report Extension
Alternative Development Strategies
Planning and Regeneration Service,
London Borough of Redbridge,
Freepost RSLR – JACE – HSUG
Ilford IG1 1DD
0208 708 2062
By hand:
Planning Policy Team – Room A1,
Redbridge Town Hall
128-142 High Road, Ilford

Redbridge Local Plan 2015-2030

Transcription

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