Public Consultation Report - Waltham Forest · Andrew Gale Policy WTC4 - Unit Mix wtcpo178 PHCC supports the negotiation aspect of policy WTC4 taking a site by site approach to unit

Waltham Forest Local Plan Supporting Document Appendix F

Walthamstow Town Centre Area Action Plan Preferred Options

Public Consultation Report

December 2012

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INTRODUCTION

During the consultation on the Walthamstow Town Centre Area Action Plan Preferred Options from 22 August to 30 September 2011, there were 176 responses received from 24 consultees. This report is divided into two parts: Part I – Written Comments and Council Officers’ Response Part II – Questionnaire Outcomes (started from P.45)

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Part I

Walthamstow Town Centre Area Action Plan Preferred Options – Schedule of Written Comemnts and Officers’ Response

Consultee Consultation

Point Comments

ID Consultee Comments Council Officers' Response

Andrew Gale Chapter 1 Purpose of the document

wtcpo135 Drivers Jonas Deloitte act on behalf of PHCC (East London) Ltd and PHCC East London (Residential) Ltd (hereafter referred to as 'PHCC'), in respect of their interest at St James Health Centre, St James Street, Walthamstow. PHCC has been nominated as the developer of the St James site by Waltham Forest PCT, the existing health facility has been identified as requiring significant investment for a number of years. There is an identified substantial need for improved health provision for local population in the St James area. PHCC have been in dialogue with Waltham Forest Council concerning the development of the site for a number of years and towards the end of 2010 submitted two planning applications which proposed a new health centre with residential above and an enabling residential development together with a small commercial unit on an adjacent site. These proposals included for a landmark building and comprised a reasonably high-density of residential development, it had been understood that the Council would be supportive of this approach. Through the consultation process a number of concerns were raised by consultees and unfortunately the project has had to be placed under review, the determination of the two applications is currently in abeyance. It is interesting to note that the Council are now advocating a policy approach for the St James area which would comprise new mixed-use developments of a high-density, with flexibility on matters such as car parking standards and the provision of amenity space. On behalf of our clients, we hereby submit representations to the consultation on the Walthamstow Area Action Plan, which is currently out for consultation until 30th September. PHCC and the PCT maintain that the provision of new health facilities in the St James area should be treated as an absolute priority, and indeed a pre-cursor to any other significant new residential developments. Further they query whether the policies of the AAP might provide a basis for helping ensure the provision of the new health centre.

Noted - The Council fully support the redevelopment of the St James Street Heath Centre for mixed use development including health and residential uses. The Council would welcome further discussion on future proposals on this site.

Andrew Gale Chapter 23 WTCP 8 - Town Square and Gardens

wtcpo140 PHCC is supportive of the principle of this policy and the mixed use nature of proposals deemed suitable for this site. However, it is requested that greater clarity be given to the specific wording of this policy as it could currently be read as requiring the existing health centre building to be retained as part of any proposals. PHCC would not support the retention of the existing building on the site as it is out-dated and requires continual repair. Any redevelopment option requiring its retention would be unfeasible and unviable. A typing error is also noted at the heading of the policy where this refers to the site as 'South Grove Medical Centre ', where this should read,

Noted - The Council will amend to clearly state that a new health facility with the same level or more floorspace than the existing is provided on this site as part of any redevelopment plans.

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Point Comments


'St James Health Centre.' PHCC suggest the following replacement text for Policy WTCP19: "We propose a mixed use scheme, including social infrastructure (new health centre facility) and residential. Redevelopment proposals should seek to provide a replacement health centre on site. "

Andrew Gale Policy WTC 14 - Design and Place Making

wtcpo138 PHCC are supportive of promoting the principles of high quality design within the AAP area. However, PHCC objects to the preferred policy WTC 14 as it considers it to be too restrictive, particularly part 4 of this policy which limits building heights to 2-3 storeys, with taller buildings only focussed in certain locations. As mentioned above, the site of the St James Health Centre is considered to be a suitable location for a larger tall building to act as a gateway to the town centre area. The PHCC proposals for the replacement health centre as submitted in December 2010 included a building of 4 storeys with additional residential storeys above on the corner of St James Street and Brunner Road. Notwithstanding the concerns that were raised in respect of the submitted scheme, to ensure an efficient new health facility in this urban location it is probable that a development of at least 4 storeys will be required. Technical work submitted in support of the existing scheme demonstrate that this is eminently possible in this location. To allow for creative design solutions to maximise the development potential of sites, the policy should be flexible and not restrict developments to 2-3 storeys. In particular, the St James Health Centre should be identified as an area for a landmark tall building. PHCC therefore supports Alternative Option 1, which seeks to create a new character and context for the centre by creating land mark buildings, encouraging distinctive and contemporary design and establishing new building forms and character areas.

Noted - The Council will undertake a detailed analysis of building heights within the town centre. The Council will seek to apply the London Plan Density Matrix to any proposals on St James Street Health Centre Site.

Andrew Gale Policy WTC1 - Housing Growth

wtcpo136 PHCC welcomes the identification of specific opportunity sites for the development of new housing, including the St James Health Centre. The St James Health Centre is considered to be a key opportunity site, which could play an important role in the delivery of a new health centre facility but also new homes, helping the London Borough of Waltham Forest (LBWF) to achieve its housing target of 2,000 new homes in Walthamstow by 2026. PHCC, whilst supportive of the identification of housing growth, believe that the development of a new health centre facility should be prioritised. It has a crucial role in supporting new housing throughout the AAP area and the current facilit ies are woefully inadequate to support significant new patient numbers. PHCC does not support Alternative Option 1 which reduces the housing target in Walthamstow to 1,500. This will hinder LBWF in achieving the borough-wide housing target and the opportunity should be taken now to maximise new housing on available and suitable sites. PHCC supports the principle of Policy WTC2 in its aim to make the most efficient use of land,

Noted - Support is noted for the higher housing growth scenario and the contribution the St James Street Health Centre can make to this. We also note the support for the affordable and housing mix policies. The Council will apply the London Plan density matrix to all proposals in the AAP area in line with DM8. The Council note your concerns relating to the provision of family housing within the town centre. Whilst the Council recognise the difficultly with delivering such housing, this is balanced with the need to develop a sustainable mixed and balanced community providing housing

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Point Comments


and seeking densities in line with the Replacement London Plan (July 20 11 ). However, it is considered that further clarity is required with regard to part (b) of the policy, concerning the location of lower residential densities. It is felt that the wording, "near Leucha Road and Walthamstow St James Conservation Areas." is ambiguous and could restrict densities on sites, such as St James Health Centre, which is capable of providing high density development without impacting on the Conservation Areas. PHCC is in favour of Alternative Option 1 which seeks higher densities on all sites within the town centre. Alternative Option 2 for lower density housing is not supported as this will not allow a sufficient number of new homes to come forward to meet requirements. PHCC supports the approach taken to affordable housing provision in this policy, which allows for affordable housing to be negotiated on a site by site basis and to be subject to viability. PHCC supports the negotiation aspect of Policy WTC4 taking a site by site approach to unit mix. However, it does not agree with the policy requiring the provision of family housing to be focussed to the west of the AAP area and close to St James Street Station. Sites that are close to transport interchanges should make the most of their high accessibility levels and be developed to higher densities. Family size dwellings of 3-5 rooms require more space, not just internally, but in terms of amenity space, children's play space and car parking etc. This is not deemed to represent the most appropriate use of land and contradicts policies on maximising development of sites.

types for a range of people.

Andrew Gale Policy WTC12 - Car and Cycle Parking

wtcpo137 PHCC strongly supports the car free development principles of Policy WTC12 for residential developments, as wel l as parking provision for other uses sought in line with appendix 4 of the Development Management Policies Preferred Options document.

Support noted

Andrew Gale Policy WTC15 - Social Infrastructure

wtcpo139 PHCC is supportive of this policy and the aim to provide new social infrastructure. However, PHCC suggest that part 4 of this policy should be reworded as follows (new text in bold and underlined): "Where appropriate, contributions will be sought through planning obligations to support the provision of new social infrastructure, or the expansion or improvement of existing facilities to meet the needs of the community". Contributions secured through planning obligations should only be sought where they satisfy the requirements of the Community Infrastructure levy (ClL) Regulations 2010 (SI 2010 NO. 948), regulation 122, i.e. when they are: necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development. Inserting 'where appropriate' into this policy will ensure that this policy complies with Cil regulation 122. Support is also given

Agreed - The Council will amend policy broadly in line with the suggested text. Support is noted for prioritising health care in the centre.

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Point Comments


to the objectives of Alternative Option 1 in relation to prioritising health infrastructure.

Andrew Gale Policy WTC4 - Unit Mix

wtcpo178 PHCC supports the negotiation aspect of policy WTC4 taking a site by site approach to unit mix. However, it does not agree with policy requiring the provision for family housing to be focussed to the west of the AAP area and close to St James Street Station. Sites that are close to transport interchanges should make the most of their high accessibility levels and be developed to higher densities. Family size dwellings of 3-5 rooms require more space, not just internally, but in terms of amenity space, children's play space and car parking etc. This is not deemed to represent the most appropriate use of land and contradicts policies on maximising development of sites.

Noted - All sites within the AAP will have to make a contribution to the provision of family housing.

Carmelle Bell Thames Water Utilities Ltd

Chapter 1 Purpose of the document

wtcpo106 TWUL is the statutory water and sewerage for London Borough of Waltham Forest. Under the Water Industry Act, Thames Water has a duty to ensure that its area is effectively drained and to effectively deal with the contents of its sewers. That duty is mindful of available resources and requires the assistance of local planning authorities in ensuring that those resources are not overwhelmed in complying with those duties. Thames Water is aware that water and waste water infrastructure issues are covered in other Waltham Forest DPD documents and in particular the Development Management Policies Document. If the Council does not consider that coverage of water and waste water infrastructure issues is appropriate within the Walthamstow Town Center AAP a reference to Development Management Policy DM35 (Water) would be helpful to make it clear that development at the Key Sites will be expected to consider water and waste water infrastructure capacity issues. In relation to the provision of water and waste water infrastructure to support development it will be essential that developers demonstrate that adequate capacity exists both on and off site to serve development proposed and that development would not lead to problems for existing users. In some circumstances this may make it necessary for developers to carry out appropriate studies to ascertain whether the proposed development will lead to overloading of existing sewerage infrastructure. Where there is a capacity problem and no improvements are programmed by the water company, then the developer needs to contact the water authority to agree what improvements are required and how they will be funded prior to any occupation of the development. Where upgrades to existing infrastructure are identified as necessary to serve new development it is essential that these are in place ahead of occupation if adverse impacts such as sewer flooding to property and no/low water pressures are to be avoided. Thames Water would expect

Agree - The Council will include a reference in the document to Development Management Policy DM35 (Water) to make it clear that development on Key Sites within the centre will be expected to consider water and waste water infrastructure capacity issues.

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Point Comments


to be consulted on most major planning applications. Paragraph B4 of PPS12, states that "the adequacy of infrastructure can be a material consideration in deciding whether permission should be granted." The earlier Thames Water is able to be involved in the planning application process the greater the opportunity we have to make known our concerns regarding the ability of the local infrastructure to support development and to ensure any proposed development has no detrimental impact on our assets or the service we provide to existing customers. Furthermore, early consultation allows Thames Water to work with developers and other agencies to enable the issues caused by a development to be mitigated, or a compromise to be reached. When carrying out the necessary early consultations with Thames Water regarding the capacity of water and sewerage systems, adequate time should be allowed to consider development options and proposals so that an informed response can be formulated. It is not always possible to provide detailed responses within a matter of weeks; for example, the modelling of water and sewerage infrastructure systems will be important to many consultation responses and this can take a long time to carry out (e.g. modelling of sewerage systems can be dependent on waiting for storm periods when the sewers are at peak flows).



wtcpo107 Thames Water support both paragraphs 35.5 and 35.11. Thames Water encourages developers to make early contact with us so that we can understand the implications of their development on our network at the earliest opportunity possible. In the mentioned list of necessary infrastructure there is no reference to Utilities infrastructure, and in particular water and wastewater infrastructure.

Noted - The Council will include utilities in the implementation plan of the submission draft of the AAP.


Figure 15.1 Key Sites Designation

wtcpo108 Due to the complexities of water and sewerage networks it is difficult for Thames Water to comment on the impact of the proposed development without an exact understanding of the scale and phasing of development at the proposed locations. We would welcome the opportunity to work closely with Waltham Forest to better understand the infrastructure needs of the proposals.

Noted - The Council welcomes the opportunity to discuss with Thames Water the impacts of new development on the water and sewerage networks. The submission draft document will provide greater detail in relation to scale and phasing of development.

Cllr Clare Coghill Junior Cabinet Member, Health, Adults and Social Care Waltham Forest Access Alliance

Chapter 8 Walthamstow Town Centre vision and objectives

wtcpo113 I organised a focus group with my residents on the AAP. I had a mixed group of people from Walthamstow who came along. I can provide details if necessary. I wanted to submit this as an additional response to the WF LDF Preferred Options Consultation Questionnaire which was the basis of the discussion. Residents agreed with the Vision which prompted the following discussion:

• The town centre is, at points, aesthetically horrific. St James Street

Noted - The Council recognise the need to improve the public realm in the centre. Policies WTC 13 and WTC 14 aim to provide a strategy for the town centres improvement. The Council seek to emphasis the need to improve the St James Street area. The Council is seeking to promote and enhance the

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Point Comments


is a slum;

• Walthamstow town centre is a horrible place to be in the evening. It's a dodgy, very male environment, and has a 'closed' feeling;

• People here spend money everywhere but Walthamstow;

• St James Street isn't supported; the top of the Market is. It feels like

them and us;

• The market seems to have a negative impact on opportunities to invest in the town centre;

• We need to improve the market as a priority; • Social Bonds for businesses and market traders based on

economic; environmental and social criteria should be explored as a serious option. If the business rates take in the town centre increases, the market traders could have a dividend;

• Other markets that were noted as reference points: Borough Market,

Southwark Chapel Street Market, Islington Broadway Market, Hackney;

• Inter-relation between market stalls, shops and flats needs to be

assessed and managed;

• There is too much duplication on the market; if there is going to be duplication we should make a feature of it with groups of haberdashers; fruiters and grocers; electrical goods and cooking utensils stalls grouped together to make an asset of the repetition;

• Disappointing that so many disreputable, dirty businesses operate

on the High Street with seeming impunity;

• If chains are to be reintroduced to the High Street they need to be the right ones: Islington has a good mix of independents and multiple retailers. More Sainsbury's not more ASDA / LIDL;

night-time economy within the centre. The Council recognise that the development of the night-time economy will only be successful if people are attracted to the area and feel safe and secure. The Council raise the importance of this issue by developing a policy specifically in relation to safety and security in the centre. The Council are seeking to bring a holistic change to the centre. The Council are therefore seeking to develop and enhance both ends of the High Street. The Council recognise that the unstructured nature of the market is dampening the centres potential (paragraph 12.19). The Council are seeking to reorganise (policy WTC 13) the market to improve pedestrian circulation and its integration with the rest of the High Street. The Council are seeking to improve the quality of the retail offer in the centre (Policy WTC 5). Walthamstow has a number of assets which make it attractive to a range of retailer (both commercial and independent) looking to invest. The Council is not seeking to compete with neighbouring centres such as Stratford City, rather seeking to develop a unique and alternative retail offer in the centre.

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Point Comments


• Farmers market and / or craft market at St James Street end of the market to take advantage of the resources of residents and the fact that people would like the opportunity to buy high quality good locally - we need high end and mid-range as well as bargain basement. 'A taste of Portobello' would be very welcome; and

• Walthamstow needs to be a unique alternative to Westfield.

• Careful consideration needs to be given to integrated transport

plans.


Policy WTC1 - Housing Growth

wtcpo115 Any decision to increase the number of housing units needs to be based firmly on having resources available for new schools and other amenities. Existing schools do not have capacity. An additional 2000 homes and the children living in them could not be supported by the existing schools, even if expanded beyond capacity. 2000 homes is unrealistic in the view of the focus group.

Noted - The Council's evidence base SHLAA (2009) demonstrates that the centre has the capacity to provide approximately 2,000 units. Walthamstow is to be an ideal location for new housing as it has excellent transport links and is close to a number of services. The Council agree that it is important that new housing development is supported with the appropriate level of social infrastructure. In accordance with WTC15 the Council will seek to prioritise of education and health social infrastructure.


Policy WTC6 - Hot Food Takeaways, Estate Agents, Betting Shops and Off Licences

wtcpo114 Add Money Shops to the list of premises Residents strongly agreed on both points: A and B Residents strongly agreed on both points: A and B

Noted – Such uses fall within the A2 use class. Where the Council can control such changes, such proposals should be in accordance with Development Management Policy DM26, which seeks to resist proliferation of particular uses within the centre. This would apply to ‘Money Shops’.

Giles Dolphin Planning Decisions Unit Greater London Authority


wtcpo164 Paragraphs 7.7, 93 and others make references to the draft replacement London Plan. Please note that all references to the London Plan should now relate to the adopted 2011 London Plan.

Agreed - The Council will amend where necessary

Giles Dolphin Planning Decisions Unit


wtcpo165 This chapter aims to demonstrate the Council's flexible approach to achieve the borough wide affordable housing target of 50% (which is to be specifically applied to town centre sites). Paragraph 9.5 states that "were a

Noted - The Council will highlight the contribution which Walthamtow (Waltham Forest) can make to housing in London.

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Point Comments


Greater London Authority

viability case is used to justify on affordable housing offer below 50%, the Council will require the shortfall to be treated as a deferred contribution. Another viability assessment will be required of a developer post development and occupancy stage, and should viability have improved, the Council will seek a further payment up to a maximum of the deferred sum. Whilst the GLA preference would be for a London Plan policy compliant approach whereby when viability is reassessed further on-site affordable units would be provided pragmatically, given the size of sites in the town centre, it is understood that this is not likely to be possible. It is understood that the main objective of this approach is town centre renewal in Outer London in line with London Plan 2011 policy 2.7 and on this basis it is accepted. The Council need to be mindful that London's housing market is unique and is generally considered as a single housing market area, with little regard to borough boundaries. Although the Council is correct to consider its own housing needs and challenges as a priority, the Council should also consider the impact of its approach on London as a whole. The Mayor recommends the Council acknowledge Waltham Forest's valuable contribution to housing in London and the need to consider housing from a strategic perspective, as well as a local one. A balance also has to be struck between realising the potential of residential conversions, especially to meet the needs of smaller households, and sustaining the residential quality of those neighbourhoods where pressure for conversions is particularly intense. Relating intensification to public transport accessibility is a good and more robust approach to protecting amenity and ensuring sustainable outcomes, rather than blanket, locally restrictive policies. Paragraph 9.7 suggests that this approach is to be applied by the Council and is supported by the GLA. The tenure split proposed is in line with London Plan Housing Policy. The support for HMOs above shops in the town centre is also supported. Paragraph 9.9 suggests that "an exemplary standard of design with an excellent standard of living accommodation" will only be sought of developments which exceed densities of 500 habitable rooms her hectare. The Council should refer to London Plan policy 3.5 which states that all new housing developments should be of the highest quality.

The Council notes the support for deferred contribution and HMOs within town centres. The Council will seek exemplary standards of design to all new development in the borough.


Chapter 18 WTCP 3 - Former Petrol Station Hoe Street

wtcpo175 All growth within the AAP area will be expected to be consistent with the accessibility and capacity of the surrounding public transport and highway networks. The package of mitigation measures, as outlined in Chapter 14 'Planning Obligations' is therefore welcomed, as is the reference to the future requirements of a borough-wide Community Infrastructure levy (ClL) and the Mayor's London wide CIL. The following matters should be secured in addition to the key projects that are expected to be provided through pooled

Noted - The Council will add the highway improvements, wayfinding, additional bus capacity and the re-provision of bus standing to CIL.

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Point Comments


developer contributions: highway improvements, wayfinding, additional bus capacity and the re-provision of bus standing.


Chapter 22 WTCP 7 - Arcade Site

wtcpo167 The GLA broadly supports the principles set out in the AAP, however it is prescriptive regarding the public space on the High Street and GLA officers do not support the approach set out. GLA officers are of the view that the public space should become wider on the corner of High Street and Hoe Street and that the buildings on the Arcade Site should provide a landmark for this junction. TfL supports the vision for Walthamstow Town Centre which seeks to build on its excellent transport links and encouraging the use of sustainable transport. The growth and regeneration of Walthamstow is promoted through policies 501 to 5010 which collectively promote high density mixed use development. The promotion of housing led mixed use developments in areas of high public transport accessibility levels (PTALs) is supported in line with London Plan policy 6.1, particularly considering the excellent bus, rail and underground connections at Walthamstow Central station and overground services at Walthamstow Queens Road station.

Support noted for the principle of high density housing led mixed use scheme. The submission draft document will provide greater detail in relation to the provision of public space and its relationship with the High Street and Hoe Street junction.


Chapter 26 WTCP 11 - Sainsbury's Supermarket

wtcpo173 WTCP 15 South Grove - the proposals for this site must include the provision of bus stands before the site at Courtney Place (WfCP 17) is developed. As a minimum, any replacement must be like-for-like. The operation of bus network is reliant on the continued availability of the bus stands and therefore any phasing issues must be resolved at the outset and where necessary, secured through the planning process. The design and provision of any bus stands must not incur additional mileage and improve connections with the town centre.

Noted


Chapter 30 WTCP 15 - South Grove

wtcpo174 WTCP 17 Courtney Place - As for South Grove, any proposals for this site must specify that the bus stands are currently protected in line with London Plan policy 6.2 and that development is dependent on their satisfactory relocation.

Noted - The Council will consult with TFL on any proposals or planning applications brought forward on this site or in relation to the future of the bus stands. The Council are not proposing to loss the bus stands. Â


Chapter 32 WTCP 17 - Courtney Place

wtcpo172 WTCP8 Town Square and Gardens - as stated above, any proposals for this site should acknowledge and protect the continued operation of the bus station. "WTC 14 - The options for improving the town square and gardens as well as extending Selborne Walk must emphasise that the bus station will be retained in any development in line with London Plan policy 6.2. This is a relatively new facility that is seen as key to the highly accessible nature of the town centre."

Noted - The Council will acknowledge the need to retain and protect the bus station.

Giles Dolphin Planning Decisions Unit

Chapter 8 Walthamstow Town Centre

wtcpo166 The vision to promote the unique retail offer by building on the historic market and with a high proportion of independent retailers is in line with London Plan policies 4.8 and 4.9.

Support noted.

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Point Comments


Greater London Authority

vision and objectives


Chapter 9 Town Centre Neighbourhood

wtcpo168 The Council's strategic vision is broadly welcomed as it supports improved accessibility through increased quality and frequency to the existing transport network. It should be noted however, that any changes to the bus network in terms of increasing frequency or creating new links will be subject to the usual TFL appraisal criteria. The land use planning implication of this objective will be to ensure the provision of sufficient land for an expanded transport system in accordance with London Plan policy 6.2. More specifically, this document should identify land that is safeguarded for transport functions and identify as well as safeguard sites, land and route alignments that are necessary to implement transport proposals in accordance with the London Plan SPG 'Land for Transport'. These include but are not limited to bus lanes, stands, stops, stations, interchange facilities and road proposals. Some of these are referred to specifically below. Strategic vision is also supported by TFL as the encouragement of walking and cycling is in line with London Plan policies 6.9 and 6.10. The accompanying proposals as set out in figure 11.2 provides a usual indication of improvements to town centre links. The proposals in figure 11.3 however, are considered too detailed for this AAP and the accompanying text should advise that they are indicative. TFL considers that reconfiguring individual junctions could reduce congestion in line with London Plan policy 6.11 (alongside demand management, kerb side controls/enforcement and promotion of sustainable travel). Any proposals must be tested and modelled at the local, corridor and more strategic level as deemed appropriate. The development of a town centre micro-simulation model linked to TFL strategic models has been used elsewhere to test development scenarios and highway interventions. This should be undertaken in line with TFL's Modelling Guidelines http://www.tfl.gov.uk/businessandpartners/publications/16845.aspx.

Noted - The Council will provide more detail in relation to land that is safeguarded for transport functions and identify as well as safeguard sites, land and route alignments that are necessary to implement transport proposals. Support noted for walking and cycling. The Council will amend figure 11.3. The Council will work with TFL in relation to the road reconfigurations in the centre.


Policy WTC 14 - Design and Place Making

wtcpo171 WTC 14 - The options for improving the town square and gardens as well as extending Selborne Walk must emphasise that the bus station will be retained in any development in line with London Plan policy 6.2. This is a relatively new facility that is seen as key to the highly accessible nature of the town centre.

Noted - The Council will retain the bus station as part of any proposals to extend Selborne Walk in line with London Plan Policy 6.2.


Policy WTC10 - Transport Improvements

wtcpo169 Improvements to public transport capacity are welcomed in principle; however any changes to the bus network in terms of increasing frequency or creating new links will be subject to the usual TfL appraisal criteria. Proposals to simplify the gyratory system are supported in principle, assuming that the proposals in figure 11.3 are indicative only. The proposals

Noted - The Council will work with TFL in relation to any proposed changes to the bus network. Support is noted for the simplification of the gyratory system. The Council will work closely with TFL on any

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Point Comments


could be interpreted to mean that bus routes serving the length of Hoe Street would not serve the bus station. The benefit to through passengers of such a change to the bus network would have to outweigh the disbenefit of those passengers whose destination is Walthamstow town centre and currently experience a high quality interchange with the station and the town centre itself. If the benefit was considered to outweigh the disbenefit, then bus stops on Hoe Street, close to the station, would be required. Bus stops are not shown on figure 11.3. TfL considers that an alternative option that should be explored is the creation of a northern vehicular entrance into the bus station. This would improve bus journey times for all passengers and reduce vehicle movements at Hoe St gyratory. Whilst proposals to improve certain pedestrian crossings are welcomed, the policy should also include proposals to provide a high quality connected pedestrian environment. Proposals should also ensure that the quality of interchange between bus and rail is protected and' enhanced. The package of proposed transport improvements should also include the promotion of the Legible London wayfinding system to encourage walking in accordance with London Plan policy 6.10. The requirement for new developments to provide financial contributions to enhance the transport network is supported. Development proposals should accordingly be accompanied by a transport assessment in accordance with TfL's Transport Assessment Best Practice Guidance 2010 and a travel plan. In accordance with London Plan policy 6.14, the document should consider the needs of freight and delivery and vehicular servicing. It could take a strategic approach (loading/restrictions, on-street/off-street, consolidation or co-ordination) and/or encourage best practice at individual sites securing delivery and service plans, consolidation centres and the use Freight Operator Recognition Scheme (FORS) accredited operators.

future proposals. Policy WTC13 seeks to improve the pedestrian environment through a range of measures including Walthamstow as part of the 'Legible London' wayfinding scheme. Support noted for developer contributions to enhancing the transport network. The Council will state that development proposals need to be accompanied by a transport assessment.


Policy WTC12 - Car and Cycle Parking

wtcpo170 In view of the highly accessible nature of Walthamstow town centre, TfL welcomes the car free approach to all new residential development within the AAP area. Given the advice in paragraph 11.16 that town centre car parks are generally underutilised, and given levels of traffic congestion, TfL questions why onsite parking will be required for non residential uses. In accordance with London Plan policy 6.13, 1 in 5 spaces that are provided (both active and passive) should have an electrical charging point to encourage the uptake of electric vehicles.

Support is noted for 'car free development'. The Council will seek to apply the parking standards as set out in its development management DPD. The Council will make specific reference to electrical charging points.

Helena Poldervaart

Chapter 16 WTCP1 - Snooker Hall at Junction of Hoe Street and

wtcpo10 I support the principle of developing this site. I would like to see a robust case made for additional restaurants, given the existence of many small restaurants in the immediate area. Is there a need and is there a risk that the existing restaurants could lose business? I oppose the suggestion of 'carefully considered taller element'. It would be out of scale with the

Support noted for the principle of development. Robust justification should be provided for additional retail and restaurants with any planning application. The Council seek to develop this area as

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Point Comments


Forest Road surrounding streets and change the character of this very important hub site. a leisure and entertainment hub and as such we would seek uses such as restaurants to be provided. The submission draft AAP will undertake a process of analysis where tall buildings are considered appropriate and establishing appropriate heights on these sites. This site is a designated as a 'landmark' as it is at a prominent corner towards the entrance to the centre.

Helena Poldervaart

Chapter 17 WTCP2 - Former Factory Tower Hamlets Road

wtcpo7 I agree this is an attractive building and should be retained. A more mixed use including artist workshops could also be considered and would add vibrancy.

Support noted for listed of the building. The site has now been Locally Listed. The Council will amend the site proposals to include commercial space as part of a mixed uses scheme.

Helena Poldervaart

Chapter 20 WTCP 5 - EMD Cinema

wtcpo6 This site does need to be tackled but I hope that 'landmark' building is not another way of saying 'tower block'. A tall building would be quite out of scale with the surrounding streets.

Noted - A landmark building is not necessarily one which is 'tall'. The submission draft AAP will undertake a process of analysis where tall buildings are considered appropriate and establishing appropriate heights on these sites. This site is a designated as a 'landmark' as it is at a prominent corner at an entrance into the centre.

Helena Poldervaart


wtcpo8 I trust that the Credit Union will be able to stay on the ground floor - this is a great location for them and they are an asset to the community. Rather than yet more retail, this building should be retained for other business use such as offices, workshops etc. Some low cost accommodation for local community groups and charities should also be included.

Noted - There are currently no plans to move the Credit Union. Community uses are not considered appropriate for this site. Community uses are included on other sites in the AAP to ensure appropriate provision is provided for local groups. Â

Helena Poldervaart


wtcpo9 I support these proposals. Support noted

Helena Poldervaart

Chapter 31 WTCP 16 - Brunner Road Industrial Units

wtcpo11 An immediate improvement to this area would be to take away the hideous, noisy and hardly ever watched TV screen. I have not yet come across anyone who likes it or watches it and hardly ever see anyone watching it when I walk through the area. The point about the effects of shading the area with any new development are well made and serious consideration should be given to this in relation to the scale and massing of any new

Noted - The sitting of the TV screen will be considered as part of any proposals to improve the town square and gardens. The Council will include the need to consider the effect of shading on the gardens with any new development

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buildings. proposals.

Kerry Churcher Policy WTC6 - Hot Food Takeaways, Estate Agents, Betting Shops and Off Licences

wtcpo86 and reducing the number of pound shops Noted

Kerry Churcher Policy WTC8 - Leisure, Entertainment, Culture and Tourism

wtcpo87 Very much in favour of a return of the cinema to its full glory Support noted

M Khan Policy WTC 14 - Design and Place Making

wtcpo155 Specifically Arcade site, Town Square and South Grove. You can have taller buildings with mix unit development. Extension to Selborne Walk development, improve town square.

Support noted for tall building on Arcade site, Town Square and South Grove.

M Khan Policy WTC1 - Housing Growth

wtcpo143 Try to develop new homes / flats on/ above shops, shopping centre. L.D was proposing to the Council to purchase the existing Cinema at Hoe Street and HSBC Bank, demolish it and develop it with Arcade development. There is still time, because construction start after Olympics have finished.

Noted - Support of housing above shops. The EMD Cinema is a Listed Building and cannot be knocked down. The uses on the EMD Cinema, HSBC site and Arcade will complement each other but not be linked. The Council will consider how best to progress leisure proposals on the EMD site. Â

M Khan Policy WTC10 - Transport Improvements

wtcpo151 To improving traffic flow, you should widen the width of Hoe Street, from Bell corner to Queens Road. Safety and security is not good enough around the centre. Many peoples have been killed during many years, lack of security. Especially after P.M

Noted - A road widening scheme on Hoe Street, at this stage, is not feasible. Policy WTC13 seeks to improve the public realm to make it safer and secure. The Council also recognise the importance of improving safety and security in the town centre particularly at night in order to improve the night time economy.

M Khan Policy WTC13 - High Quality Environment

wtcpo154 Already mentioned regarding reorganisation of the market it is very important the market stalls at town centre square has more customers than other areas of the market. Do something.

Noted – The Council considers that the market should contribute the vitality and viability of the whole centre. However, given its proximity to the centres transport ‘hub’, the market at near the town square will naturally have more ‘activity.

M Khan Policy WTC3 - Affordable

wtcpo145 This Council needs more housing / flats, try to develop the sites with mix development.

Noted

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Housing and Tenure Mix

M Khan Policy WTC5 - Retail

wtcpo147 Have more stalls near town centre. I suggest, until the Arcade starts construction. High Street market office, provide more stalls on Arcade site, fronting High Street, not on Arcade - pavement is free to put 10 stalls till construction of Arcade.

Noted - The Council are engaging on a reorganisation of the market. The current vacant Arcade site will continued to be used for events.

M Khan Policy WTC6 - Hot Food Takeaways, Estate Agents, Betting Shops and Off Licences

wtcpo148 Where they go, these businesses, this is part of the High Street. People come for shopping, they also eat as well. If no food, no good. Healthy pubs - are not healthy it is like smoking is banned. These pubs should be reduced.

Noted - The Council agree that a food offer is essential to support the development of the centre, However, It is the Council's view that there are to many hot food takeaways in the centre which is adversely affecting its vitality and viability.

M Khan Policy WTC8 - Leisure, Entertainment, Culture and Tourism

wtcpo149 You see, by resisting on Thursday to Saturday, market is full at western end, but empty or not many shopper at east end because most of shops and stores are not good or favourite. So you have to do something on this side of the High Street towards St James Street.

Noted - The Council is supporting the development of the St James Street end of the High Street by proposing a cultural quarter. This will provide an 'alternative offer' for this end of the high street in order to attract a larger footfall.

M Khan Table 1 wtcpo159 As mentioned, try to purchase EMD Cinema and HSBC site. With HSBC Bank you / Council can negotiate to give similar are back to bank at ground floor, than above mix unit / flat constructions this is best time to negotiate for this two sites. So whole of Arcade site will have one block development.

Noted - The Council will consider how best to progress a leisure use on the EMD Cinema site. Uses on the Arcade, HSBC and EMD will be complement each other in development the 'leisure and entertainment hub'.

Marie Jasper Barton Willmore The Mall Limited Partnership


wtcpo102 On behalf of The Mall Limited Partnership we make the following representations in relation to the Walthamstow Town Centre Area Action Plan consultation.

Noted


Chapter 23 WTCP 8 - Town Square and Gardens

wtcpo104 We support the proposal at Policies WTCP 8 and 9 to allow an extension to the Selborne walk shopping centre. We also note the need to establish the principle of retaining most of the Town Square and Gardens as existing. However in order to ensure the AAP is sufficiently flexible to allow for an appropriately designed shopping centre extension to be developed WTCP 9 paragraph 2 final sentence revised to read "The principles below will need to apply to any extension broadly within the zone of expansion detailed on figure 10.1 on page 33:" The above minor changes retain the principle of retaining most of the town square and gardens area as existing, but allow some flexibility for development to take place outside the figure 10.1 zone boundary, should this be required to achieve a viable, appropriately

Support noted - The Council will amend wording to provide flexibility.

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designed extension to the shopping centre without departing from the principles set out in the AAP. Â


Chapter 34 WTCP 19 - St James Street Health Centre

wtcpo103 We support the proposal at Policies WTCP 8 and 9 to allow an extension to the Selborne walk shopping centre. We also note the need to establish the principle of retaining most of the Town Square and Gardens as existing. However in order to ensure the AAP is sufficiently flexible to allow for an appropriately designed shopping centre extension to be developed ii) WTCP 8 paragraph 2 revised to read "The principles below will need to be addressed by an extension proposed broadly within the zone of expansion detailed in figure 10.1 on page 33:" The above minor changes retain the principle of retaining most of the town square and gardens area as existing, but allow some flexibility for development to take place outside the figure 10.1 zone boundary, should this be required to achieve a viable, appropriately designed extension to the shopping centre without departing from the principles set out in the AAP.

Support noted - The Council will amend wording to provide flexibility.


Figure 10.1 LBWF proposed 'Mall Zone of Potential Extension' - Image produced by MacCreanor Lavington

wtcpo105 Figure 10.1 to be re-titled "Mall Approximate Zone of Potential Extension". Agreed - The Council will amend figure title.

Michael Fearn Chapter 1 Purpose of the document

wtcpo160 We act as planning consultants for Barclays Bank PLC ("the Bank") in respect of the Local Development Framework (LDF) for the Borough and this letter forms the Bank's response to the above consultation. As a long-established business, the Bank has made a substantial contribution to the vitality and viability of the town centre over the years that it has traded and as a significant stakeholder it is therefore concerned that development plan policies should not fetter that important contribution. Through high attraction of footfall, financial services retailers generally (and the Bank in particular) play a key role in promoting the health of town centres and as a result, the provision of financial services should be allowed to improve and evolve alongside the improvements to shopping provision envisaged over the proposed plan period. Banks should not be subject to outmoded restrictive controls on their location, particularly as this is not supported by Government policy or by any evidence, so there is therefore a need to review existing policies that restrict such A2 uses in designated frontages or the Council will

Noted - The retail protection policy is not overly restrictive against Banks. It is an important planning objective to maintain a good balance between retail and non retail in both primary and secondary frontages. The A2 use class includes a range of non retail uses, so it is appropriate to include safeguards to give exception to those uses that are directly related to a shopping trip such as banks. The policy approach is not outmoded, but appropriate to control non retail uses generally.

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risk the Walthamstow Town Centre AAP being found unsound.

Michael Fearn Chapter 8 Walthamstow Town Centre vision and objectives

wtcpo161 In our representations on the Core Strategy and the Development Management Policies DPD we observed that the Strategic Objectives recognise the need to secure physical and economic regeneration, facilitate economic growth by meeting the demands of businesses, attract and retain high quality services, and strengthen the function of Walthamstow Town Centre as a vibrant and attractive place. We noted that each of the Strategic Objectives has a corresponding Core Strategy Policy "to demonstrate clearly how Waltham Forest will address these key issues through its spatial planning policies", but expressed serious concern that the town centre policies in both documents do not do so. We commented that the Council recognises the need for regeneration and has high ambitions in this respect but that there has been no consideration of whether existing policies need to be re-examined in order to achieve this. The acknowledged need for regeneration suggests that previous policies in the UDP and the IPPF have not been effective so there should be a firm intention to examine and review existing planning policies on designated frontages in subsequent DPDs. In our representations to the initial consultation on the Walthamstow Town Centre AAP in March 2011 we repeated the view taken by the Bank that one key issue is the urgent need to review out of date policy relating to shopping frontages, particularly as it is in conflict with Government policy. We said that together with the preparation of the Core Strategy and the Development Management Policies DPD, the preparation of Area Action Plans provides the opportunity to do so.

Noted - The performance of the Council's retail protection policy has been monitored over the years through the Annual Monitoring Report. With regard to this AAP, a review of the designated frontages has been undertaken. Proposed retail frontages are identified in Figure 10.2. The policy approach applied is not in conflict with national policy.

Michael Fearn Figure 10.2 Proposed Retail Frontages

wtcpo162 The preferred options document also states that "The AAP sets out our vision for the centre together with objectives, policies and site proposals to guide its future generation and growth" (para.1.4) but "policies" in the current document such as WTC5 are really little more than aspirations rather than the "more locally specific planning policies" intended to deliver growth and regeneration (para.2.4). For example, whilst the AAP sets out primary shopping frontages in Figure 10.2, the document contains no policies related to the operation of this or any recognition of the need to review out-of-date frontage policies. Paragraph 3.3 claims that the AAP is in conformity with national planning policy but as our previous representations on Waltham Forest's LDF documents have shown and as we set out again below, that is incorrect in respect of shopping frontage policies.

Noted - The policy approach applicable to primary and secondary frontages is set out under Policy DM26 of the Development Management Policies document. For better clarity and interpretation, it is proposed to include relevant cross referencing text in the plan document to make this point clear.

Michael Fearn Policy WTC5 - Retail

wtcpo163 The Bank is in no doubt that one key issue for Council to address is the urgent need to review out of date policy relating to shopping frontages, particularly as it is in conflict with Government policy. The focus should be on the quality of the occupier, not on maintaining an arbitrary level of a

Noted - The Council acknowledges the positive contribution Banks and Building Societies in particular make to town centre vitality and viability. Under Policy

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particular use class. Chapter 10 of the AAP sets out the Council's objectives together with its perceived issues and opportunities for regeneration of Walthamstow Town Centre, recognising the need to cater for higher value businesses if vitality and viability is to be improved. Despite this there is no serious attempt to write policies that could help to achieve such regeneration initiatives. Keeping significant generators of footfall out of primary frontages will actively work against the achievement of the Council's strategic objectives and is inconsistent with national policy. We set out below the national policy background that necessitates a review of frontage policy if the Council is to produce a Strategy that is sound. On the matter of policy formulation PPS12 is clear that all DPDs must be: "founded on a robust and credible evidence base"; "the most appropriate strategy when considered against the reasonable alternatives':' and must be "consistent with national policy". The Council should recognise the positive impact that financial service retailers such as the Bank have upon vitality and viability. The preparation of the AAP provides an opportunity to examine new evidence and to revise out-of-date policy, particularly if it is not consistent with national policy. Limiting certain Part A uses in the primary frontage undermines the Council's intention to attract private sector investment in the town centre. The implication that only A 1 uses are appropriate derives from very outmoded and is credited thinking that other uses such as banks detract from the vitality and viability of town centres. By definition, uses that fall within Part A of the Use Classes Order are appropriate in town centres as they are "shopping area uses" and are acceptable without any need for restriction or qualification. This is particularly the case for the financial services sector. ODPM Circular 0312005 "Changes of Use of buildings And Land" which accompanied the last major revisions to the Use Classes Order specifically states in relation to the A2 Financial and Professional services use class (which was created to separate those uses "serving the public, from other office uses not directly serving the public" - paragraph 32), that the Class is also "designed to allow flexibility within a sector which is very much a part of the established shopping street scene, and which is expanding and diversifying". The uses within Class A2 are noted as being those "which the public now expects to find in shopping areas" (paragraph 38). The wider role played by town centres than a pure shopping function is recognised throughout Government policy on town centres. Government Policy in PPS4 "Planning for Sustainable Economic Growth" continues the thrust of policy in PPS6 relating to town centres but particularly emphasises the importance of economic growth. Policy EC3.1 c states that Planning Authorities should: "at the local level, define the extent of the centre and the

DM26(iii) of the Development Management Policies document, the Council grants exception to such uses however mindful of the need to maintain a good balance between retail and non retail in both primary and secondary frontages. The policy tests included under the policy gives due consideration to other factors - in particular, the contribution the proposed use makes to vitality and viability. The safeguards built into the policy are appropriate to control non retail uses generally and also takes into consideration the opportunities through the Use Classes Order for Banks and Buildings to set up and operate from other non retail premises without planning permission. Presently, site specific opportunities exist within Walthamstow Town Centre to accommodate a range of new town centre uses at appropriate locations. The Council does not consider its policies as a constraint against the Banks aspirations to set up a 'flagship' project in the borough. The Council considers that there is no need to include a policy on Primary and Secondary frontages in this document - as this is already covered in the Development Management Policies Document (Policy DM26).

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Point Comments


primary shopping area in their Adopted Proposals Map", following consideration of whether there is evidence of a need to designate "realistically defined primary and secondary frontages in designated centres". The strong emphasis upon the promotion of town centre vitality and viability remains in the current PPS and the Government is clear that there should be a positive attitude towards all development which generates wealth and creates employment. The "over-arching objective is sustainable economic growth" (paragraph 9). The Government wants economic growth to be focused in town centres offering "a wide range of services to communities in an attractive and safe environment and remedying deficiencies in provision in areas with poor access to facilities". There should be "enhanced consumer choice through the provision of innovative and efficient shopping, leisure, tourism and local services in town centres" (paragraph 10). Policy EC10.1 states that: "Local planning authorities should adopt a positive and constructive approach towards planning applications for economic development. Planning applications that secure sustainable economic growth should be treated favourably". There is nothing in Government policy that recommends or supports imposing restrictions upon acceptable town centre uses at all. Indeed Policy EC3.1 states that local planning authorities should "set flexible policies for their centres which are able to respond to changing economic circumstances'; making it essential that DPD policies should facilitate the positive approach required by PPS4. Further National Policy set out in the Ministerial Statement of 23'd March 2011 by The Rt Hon Greg Clark MP is very relevant to our representations and to the soundness or otherwise of Development Plan Documents. The Statement provides added emphasis to the Government's determination that planning policies and their implementation must facilitate economic investment and growth, a point we have consistently made in our representations to the Council on this and other LDF documents. The Minister said "Government's clear intention is that the answer to development and growth should wherever possible be yes' ... " with the message that local authorities should plan positively for such new developments: "Local planning authorities should therefore press ahead without delay in preparing up-to date development plans, and should use that opportunity to be proactive in driving and supporting the growth that this country needs". Promoting vitality and viability in town centres are objectives of the Government and the Council. To succeed, town centres need to provide a full range of services and these often need to be located in ground floor premises in accessible locations. Indeed, Class A2 retailers such as the Bank routinely experience very high levels of customer visitation, contributing significantly towards pedestrian movement and therefore the

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vitality and viability of town centres. The Bank has undertaken a number of comparative footfall surveys in connection with its current acquisitions programme at its branches in various towns and cities in the UK (copies are attached). These conclusively show that the level of footfall associated with Bank branches is commensurate with, and often higher than, the best known national multiple Class A1 traders. Banks also have moved away from the traditional style of frontage, preferring to have an open, visually interesting and attractive face to the 'high street'. The Bank has become increasingly retail in its presentation and has introduced an innovative 'flagship' branch design, which has been developed in association with its customers, to transform banking into what it terms as "a retail focused experience". The Bank estimates that some 10 million customers use its branches each week and through listening to their feedback, a design has been developed that meets their requirements for modern banking and provides branches similar in appearance and in operation to retail shops. This is an example of the "enhanced consumer choice through the provision of innovative and efficient shopping, leisure, tourism and local services in town centres" that PPS4 expects and to which all DPDs must also positively respond. Whilst the design of every new branch has to be flexible in order to be sensitive to the requirements of each building occupied, the aim is generally to ensure that over 70% of the internal space at ground floor is accessible to customers. The Bank's managers regularly report that upon the opening of a 'flagship' branch the customer visitation levels significantly increase and thus the level of activity helps to underpin pedestrian flows to the benefit of surrounding traders. It is therefore important that planning policy recognises the benefit of bank uses in fostering footfall and pedestrian activity and that it should not resist much needed investment by financial service retailers. The Bank's footfall surveys have been a key element in helping to change attitudes towards the presence of banks in core shopping areas and primary frontages. Even planning authorities that once strongly resisted Class A2 uses in their primary areas have granted permission for Barclays 'flagship' outlets. Examples of authorities that have recognised the wider benefits of the 'flagship' design (following receipt of applications which have been supported by evidence of high footfall), include Southampton, Reading, Manchester, Milton Keynes, Romford, Southend, Leicester, Plymouth, Sheffield, Kensington & Chelsea and Cambridge. Follow up surveys were carried out in 2010 at Milton Keynes, Southend, Reading and Southampton (copies are attached). In every case the new 'flagship' branch significantly increased footfall, confirming the Bank's beneficial effect on vitality and viability. The Council's objectives will require major commitment and substantial investment by the private sector. Pursuing restrictive policies to

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keep significant generators of footfall such as the Bank out of primary shopping frontages will actively work against the achievement of those objectives and is an outdated and discredited approach. The Bank therefore considers that, in the light of its evidence and the statements of Government Policy in March 2011 by the Chancellor of the Exchequer and the Minister of State for Decentralisation, it is imperative that the Council uses the opportunity of the preparation of the AAP to review retail frontage policies as they are neither consistent with National Policy nor justified. At point 36 the Walthamstow Town Centre Area Action Plan document asks whether the AAP has identified the main issues that it should address and whether there are any other challenges and opportunities that the Council needs to think about. The Council recognises the need for significant private sector investment in the town centre so the opportunity provided by the preparation of the main elements of the lDF should be used to give greater encouragement to appropriate Part A uses to invest and to improve the quality of their representation. The Bank's evidence of how it increases vitality and viability in primary frontages shows that there is considerable benefit in seeking to attract those A2 users such as banks who provide a high level of investment in and maintenance of their premises, resulting in active and attractive street frontages. This will foster very significant footfall and pedestrian activity and attract investment by others, helping to provide the confidence and commercial viability necessary for any programme of regeneration and investment. Restrictive planning policy designed to keep significant generators of footfall such as the Bank out of primary shopping areas will actively work against the achievement of the Council's strategic objectives and is inconsistent with national policy. It is important that the Council has a clear idea of the key issues for its ambitions and a key issue for the AAP is therefore the need to review existing out of date policies that restrict such Bank uses in designated frontages. If this is not done, the Council will risk the DPD being found unsound. Policy wording in the AAP should make it clear that financial services retailers such as the Bank are appropriate in all designated shopping frontages, without restriction. In response to the question "can you recommend any specific policy wording that the final document should include, "the Bank suggests that as a minimum the AAP should include a policy relating to the Primary Shopping Frontage stating: "Uses such as shops, banks and building societies which contribute to the vitality, viability and diversity of the town centre will be encouraged. Such active ground floor uses will be appropriate in designated primary frontages." This will help encourage investment and plan for growth by assisting in the creation of "a vibrant, attractive and competitive town centre" as envisaged in Strategic Objective 3 of the AAP. We urge the

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Council not to ignore the Bank's representations and evidence.

Miss Rachael A Bust Deputy Head of Planning and Local Authority Liaison The Coal Authority


wtcpo17 Thank you for consulting The Coal Authority on the above. Having reviewed your document, I confirm that we have no specific comments to make on this document at this stage. We look forward to receiving your emerging planning policy related documents; preferably in an electronic format. For your information, we can receive documents via our generic email address [email protected] , on a CD/DVD, or a simple hyperlink which is emailed to our generic email address and links to the document on your website. Alternatively, please mark all paper consultation documents and correspondence for the attention of Planning and Local Authority Liaison. Should you require any assistance please contact a member of Planning and Local Authority Liaison at The Coal Authority on our direct line (01623 637 119).

Noted

Mr Adrian Stannard Planning Watch Convenor Civic Society


wtcpo13 Not sure emphasising the good transport links is sensible. This means it is easy to get away from the area and the whole point of the AAP is to identify how we can keep people and their money in Walthamstow. For this section to be effective we need to show why people should come into the area from outside to spend their money here and why the good transport links will encourage that.

Noted - It is the Council's view that the centres excellent transport links are one it’s many assets. The Council recognises that one of the main reasons why people choose to live in an area is excellent transport links. The Council seek to emphasis this asset in order to attract people to live in the centre. The Council agree that we need to utilise this asset in encouraging people to visit the centre. The Council will seek to further emphasis the centres' 'positives' in order to encourage people to visit (and spend) in the centre. The implementation of the AAP will seek to achieve this.


Chapter 14 Planning Obligations

wtcpo15 Add Lea Valley Park after Epping Forest. Walthamstow is already crowded so attracting more people during the day to the current market makes no sense. An evening economy needs to be developed to attract people in the evenings - this is where the emphasis has to be. Improving the quality of the shopping is not really possible as there are too many nearby attractive shopping centres which cater for the occasional expensive shopping trip i.e. West End, Stratford City, Ilford, Lakeside, Brent Cross etc. It is vital any AAP should define Walthamstow as unique and not try to make it compete with larger shopping centres. Walthamstow is too small to compete with Stratford and the West End so it has to develop the existing small shops, market stalls and an evening economy based on what the local artist community can contribute. It cannot

Noted - The Council is seeking to promote and develop the evening economy as proposed in policies WTC 7 and WTC 8. It is the Council's view that it is possible to improve the quality of the retail offer in the centre despite the competition from other local centres. Walthamstow has a number of assets which make it attractive to a range of retailer (both commercial and independent) looking to invest. The Council is not seeking to compete with neighbouring centres such as Stratford

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Point Comments


support the large chain stores so no attempt should be made to attract them. Encourage local entrepreneurs as has happened in Walthamstow Village. Get away from the attitude that Walthamstow's salvation is John Lewis or Marks Spencer etc. It won't happen so let's find another solution by working with local traders and residents.

City, rather seeking to develop a unique and alternative retail offer in the centre. In addition the Council seek to develop the leisure and retail hub and the cultural quarter.


Chapter 16 WTCP1 - Snooker Hall at Junction of Hoe Street and Forest Road

wtcpo46 Add: Maximum height of any development should be 5 storeys to ensure it blends with the surrounding predominate Victorian architecture. If necessary a CPO should be issued to include all the land up to St James Street station and including the pub at the dog leg corner of St James Street. Once all this land is put together re-development should include rerouting St James Street to remove the dog leg bend. This is a massive opportunity to remove the dangerous corner and to bring life to this very run down part of Walthamstow.

Noted - The submission draft AAP will undertake a process of analysis where tall buildings are considered appropriate and establishing appropriate heights on these sites. There are currently no plans to CPO any sites in this area. Such an approach is considered time consuming and costly given the number of sites and costs of works. We will continue to work with TFL to improve traffic flows in this area.



wtcpo47 This site should be incorporated with the St James Street car park and all the land along the side of St James Street (CPO if necessary) so that the dog leg bend can be removed and a new road built to make this area much safer and more attractive. It would be a huge mistake to miss this opportunity of straightening out the road and developing the whole area in an holistic way.

Noted - There are currently no plans to CPO any sites in this area. Such an approach is considered time consuming and costly given the number of sites and costs of works. We will continue to work with TFL to improve traffic flows in this area.



wtcpo18 add to statement -" building height to be limited to 4 storeys" We don't want to see the street scene dominated by a new building when the Bell is the gateway building. Consideration also needs to be given to how the site could be accessed for construction vehicles and also ongoing to avoid delays at this very sensitive junction.

Noted - A landmark building is not necessarily one which is 'tall'. The submission draft AAP will undertake a process of analysis where tall buildings are appropriate and establishing appropriate heights on these sites. This site is a designated as a 'landmark' as it is at the entrance to the centre. The Council recognise the merits of the Bell and any proposal on this site will have to consider this context. It is agreed the access to the site is an importance consideration given its location.


Chapter 19 WTCP 4 - Tax Office on Corner of Church Hill and

wtcpo22 Change to this: We propose a leisure led arts complex with ancillary restaurant and bar. As a Grade II Listed Building development proposals must restore the facade to its original state. The internal structure should be sympathetically adapted to make the building viable for the 21st century.

Â Noted - The Council will add further details in relation to restoration in the submission draft document.

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Point Comments


Hoe Street


Chapter 21 WTCP 6 - HSBC Site

wtcpo20 Add "height to be no more than 5 storeys" Noted - The submission draft AAP will undertake a process of analysis where taller buildings are considered appropriate and establishing appropriate heights on these sites.



wtcpo27 The current approved plan is a disaster for this confined space. We believe it will create an unsustainable area and the community that live there will be transient and take "no ownership" of the area. Further housing would just exacerbate the problems that we expect. Therefore the remaining land should be designated as commercial and office blocks encouraged.

Noted - Given the sites location next to the train station, it is considered that this is a suitable site for housing and will complement the hotel led scheme on the neighbouring site.



wtcpo26 This is the wrong approach. With Stratford now a very large shopping magnet taking away the open space will not encourage shoppers to Selborne Walk. What is needed is for the open space to be made more exciting and attractive by providing a large play ground for children of all ages. Any expansion of the shopping centre should be further down the High Street. If more people are to come then more Â more space has to be provided for them to have a pleasant experience. "hard edge building line" is boring and counterproductive in making an area interesting. We do agree that cafes and restaurants facing the Town Square with seating outside would improve the current situation built not at the expense of building on the current open space.

Noted - The design of the shopping extension should encourage people towards the shopping centre and further re-enforce/improve the entrance into the town centre. Improvements to the green space will be provided as part of the extension proposals. Performance space will be considered as part of these proposals.


Chapter 24 WTCP 9 - Selborne Walk Shopping Centre

wtcpo19 We support this suggestion Support noted


Chapter 25 WTCP 10 - Station Car Park Phase Two

wtcpo21 Because of its location at the bottom of the hill add "height to be no more than 5 storeys".

Noted - The submission draft AAP will undertake a process of analysis where tall buildings are considered appropriate and establishing appropriate heights on these sites.


Chapter 25 WTCP 10 - Station Car Park Phase Two

wtcpo24 The current proposals are boring and the same as in many Town Centres. Walthamstow cannot compete with the surrounding shopping areas i.e. Stratford and Ilford. Therefore it needs a totally different approach. Assuming the EMD one day will become an arts centre the arcade site should be artist studios, restaurants, gyms, music venues, art gallery etc. Leisure activities that would complement the community uses the Rose and Crown pub provides. With a lot more housing being provided in the area the arcade site needs to attract people to the Town Centre by providing a night time

Noted - Proposals on this site a aim to enhance the centre and support its regeneration. It is hoped the Arcade site will be come a key attraction, attracting visitors to the centre and supporting the development of the night-time economy. A leisure proposal will allow for such suggested uses as restaurants, gyms and

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Point Comments


economy encouraging people to stay in the are and not go to the West End in the evenings.

music venues. Provision of community uses will be sought on other sites within the centre.



wtcpo25 This is fundamentally wrong. The Town Square is heavily used for leisure especially on warm days with people sitting on the grass. The children's play area is far too small and needs to be increased in size and more up to date play equipment provided. Any extension of the shopping centre should be further down the High Street onto the Sainsbury site. The council should be encouraging entertainers and small refreshment booths which would make the area inviting to residents. Open space is vital in a Town Centre and no attempt should be made to reduce the current provision. Buskers/musician should be encouraged to create a more attractive atmosphere. The council should remove many of the restrictions it has put in place for managing the area. The Big Screen should be removed as it serves no useful purpose with very few people bothering to take any notice of it.

Noted - The part of the town square and gardens which is identified for redevelopment is the least well used. Any redevelopment proposals will seek to improve and make better use of the remaining space such as the play space. The extension will include cafe uses to animate and activate the gardens. Space could be provided for 'live performance' as part of proposals.



wtcpo44 Add: The maximum height should relate to the surrounding buildings with no part of the site higher than 6 storeys.

Noted - The submission draft AAP will undertake a process of analysis where tall buildings are considered appropriate and establishing appropriate heights on these sites.


Chapter 32 WTCP 17 - Courtney Place

wtcpo43 Add: The maximum height of any development should be no higher than 5 storeys to ensure the surrounding terraces are not swamped and to maintain the feel of the predominant residential buildings in the vicinity.

Noted - The submission draft AAP will undertake a process of analysis where taller buildings are considered appropriate and establish appropriate heights on these sites.


Chapter 33 WTCP 18 - St James Street Car Park

wtcpo45 Add: Maximum height should be in keeping with the surrounding Victorian buildings and no higher than 5 storeys. Due to enclosed nature of this site flats should be proposed rather than houses. This is not a good area to bring up children but being so close to the station makes a good site for commuters.

Noted - This site will be removed from the AAP


Chapter 4 Location and local context

wtcpo16 Building high should be specifically excluded. The current Supplementary Design document makes it clear that Waltham Forest is largely made up of Victorian terraces and this theme should run through the Town Centre and not spoiled like Croydon with vast number of ugly tower blocks. The attraction of Walthamstow is that is does not have tower block dominating the street scene. The streets are narrow and can only accommodate a finite number of shoppers so allowing too many people to live in the Town Centre will make it over crowded and unattractive - the exact opposite of what the APP should be trying to achieve. Open space is just as important as housing the residents. A tower block is not a sustainable community - a sustainable

Noted - As proposed in WTC 14, the Council seeking new buildings to be sympathetic in scale to the predominant 2-3 story context. The Council will seek to focus taller buildings in key 'gateways' such as the Arcade site and South Grove. The Council will undertaken a design analysis to ensure building heights are carefully considered in AAP context.

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Point Comments


community needs far more than just housing.


Chapter 6 Area Action Plan boundary

wtcpo14 Should Walthamstow Village also be included? The success of the Village needs to feed into the Town Centre and the more affluent residents of the Village need to be encouraged to spend their money in the Town Centre.

Noted - The Council do not consider it appropriate to include the Walthamstow Village within the AAP boundary. An AAP is designated for an area which is expected to experience 'significant growth'. This will not happen in the Village. The AAP however, does seek to improve 'links' to and from the centre in order to improve access.


Chapter 6 Area Action Plan boundary

wtcpo23 A CPO should be issued so that the site can be incorporated into the arcade site or the EMD site. If left as a separate building it will spoil the street scene as it will be very difficult to design a building that would be compatible with the modern arcade blocks or the historic cinema.

Noted - The Council will give due consideration to how best to progress proposals for the site. The proposed uses on the EMD site and Arcade site should complement and support each other and support the development of the leisure and entertainment hub.



wtcpo12 Ensure the emphasis is on developing Walthamstow in a different way from its neighbours - encourage residents and traders to take an active part in the future of our Town instead of constantly ignoring resident's views by the council taking the view they know best - clearly they don't as that is one of the reasons why Walthamstow has not developed over the last 30 years.

The Council supports the emphasis on developing Walthamstow in a different way from its neighbours. As stated in paragraph 10.3, "we will build on the ethnic diversity of the local population and the high number of independent retailers, as well as the originality of the street market the offer to create a unique and alternative retail offer which will have wide ranging appeal." The Council has undertaken a number of consultation events over many years in relation to the future development of the town centre. The Council has actively engaged with local people and community groups. Their views have been incorporated into the development of this AAP.

Mr Barry Coidan Chapter 17 WTCP2 - Former Factory Tower Hamlets Road

wtcpo5 What happens to the existing car park? If it goes will there be replacement places close at hand?

Noted - The Council would expect development proposals to include a significant element of parking as part any future plans for this site.

Mr Barry Coidan Chapter 19 wtcpo4 In all seriousness, have you considered the Mall as a covered souk. Do Noted - There are no plans to change the

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Point Comments


WTCP 4 - Tax Office on Corner of Church Hill and Hoe Street

away with the boring, expensive, copy cat retailers that cluster around the Malls of Stratford, Bluewater etc. Why compete, in a retail arms race. Offer something unique, local which could attract visitors from all over London.

Mall into a covered souk. The Council is not seeking to compete with neighbouring centres such as Stratford City, rather seeking to develop a unique and alternative retail offer in the centre building on the historic market, high proportion of independent retailers and the young culturally diverse population. We are seeking to create a 'leisure and retail hub and the cultural quarter.

Mr Barry Coidan Chapter 23 WTCP 8 - Town Square and Gardens

wtcpo2 Yet another site for redevelopment as housing? There may be a housing shortage but that's no excuse for lack of imagination. Also in the current, and likely to continue, climate where's the funding coming from to build the housing. Finally, build quality is important, recent experience in Walthamstow isn't encouraging.

Noted - This site is considered to be suitable for housing given its location. The Council will consider redeveloping the site for a mix of uses. The cost of funding will need to be arranged by the owners/developers of the site. The Council will seek to ensure high build and design quality on this site.

Mr Barry Coidan Chapter 24 WTCP 9 - Selborne Walk Shopping Centre

wtcpo3 This isn't exactly what local opinion is calling for. It's a reinstated "proper" cinema, not some amorphous "leisure complex". Again massive failure of nerve and imagination.

Noted - The Council has designated this site for leisure a leisure led scheme. As such a "proper" cinema could be included as part of a mixed use scheme.

Mr Barry Coidan Chapter 33 WTCP 18 - St James Street Car Park

wtcpo1 I certainly agree the build should be listed, but housing? Isn't one of the problems in Waltham Forest high unemployment? Has the Council looked at this being used for light industry - for example I know someone who is starting up a weaving business - selling to the Far East. It's an ideal site for his historic looms.

Support noted for listed of the building. This site has now been Locally Listed. The Council will amend the site proposals to include commercial uses as part of the of a mixed uses scheme given its existing use and the sites ability to meet other objectives such as job creation etc.

Mr Jason O'Malley

Chapter 10 High Quality Shopping, Business and Visitor Centre

wtcpo54 My real concern is that another wood green is created. These soulless places attract a narrow range of individuals. Those of us who like to have town centres that are full of character and lots of different things to do would be put off by the town centre being too dense, modern and without character.

Noted - The centre has a number of assets which make it attractive to a range of retailers (both commercial and independent) looking to invest. The Council is not seeking to compete with neighbouring centres such as StratfordCity, rather seeking to develop a unique and alternative retail offer in the centre. It is agreed that it is important that the centre retains its character and

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Point Comments


uniqueness and builds on this.

Mr Jason O'Malley


wtcpo50 the sooner the better -it is an eyesore Support noted

Mr Jason O'Malley


wtcpo52 I just don't think this site is appropriate for housing - it is incredibly busy. I think it is better being used as it is than flats

Noted

Mr Jason O'Malley


wtcpo51 I just don't think this site is appropriate for housing - it is incredibly busy. I think it is better being used as it is than flats

Noted

Mr Jason O'Malley


wtcpo57 I am really really concerned about this end of the high street. It is a bit of a no go area at night and walking out from the train station is a horrible experience frankly. I believe this area desperately needs some premium flats to diversify the area but appreciate this might be difficult to achieve.,

Support noted for residential development on this site. The Council is also seeking to develop a cultural quarter at this end of the High Street which will encourage more activity and natural surveillance particularly late at night.

Mr Jason O'Malley


wtcpo55 the sooner the better! Support noted

Mr Jason O'Malley


wtcpo49 Definitely has to stay in some shape or form. I believe it could be a good place for regular markets or alternative shopping

Noted - It is the Council's view that this site should be developed as a mixed use scheme including housing and commercial space. It is located away from the centre so retail is not considered appropriate.

Mr John Smith CgMs Consulting

Chapter Glossary

wtcpo132 I write on behalf of our client, the Metropolitan Police Authority (MPA)/ Metropolitan Police Service (MPS) with regards to the above documents. The MPA/MPS provide a vital community service to the Borough of Waltham Forest and policing is recognised within the 2011 London Plan as being an integral part of social infrastructure. The MPA/MPS have previously made

Noted

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Point Comments


representations to the Walthamstow Town Centre and Blackhorse Lane AAP Notices of Preparation on 24th March 2011 (copy attached) and to the Core Strategy and Development Management Polices DPD at each stage of consultation. Relevant Planning Policy The provision of effective policing is of crucial importance across London to ensure safe places to live are created as part of a sustainable community consistent with planning policy. National Policy PPS1 -paragraph 27 (iii) In development plan preparation the need to promote communities which are healthy, safe and crime free is highlighted. PPS12 -requires emerging development plan policy to be consistent with the adopted development plan and 'soundness' requires DPD policies to be consistent with national policy. One of the objectives of the Draft National Planning Policy Framework (NPPF ) July 2011 is to deliver the right community facilities, schools, hospitals and services to meet local needs (para 124). London Plan Policies At strategic level, paragraph 1.40 of the London Plan (July 2011) states 'a growing and increasingly diverse population will create demand for more social infrastructure' which, by definition, includes policing and other criminal justice or community safety facilities. This is reflected in Policy 3.16 Protection and Enhancement of Social Infrastructure which states that 'London requires additional and enhanced social infrastructure provision to meet the needs of its growing and diverse population'. Paragraph 3.89 further notes that existing or new developments should, wherever possible, extend the use of facilities to serve the wider community, especially within regeneration and other major development schemes. Mindful of the background at strategic level, a number of representations are hereby set out below which take into consideration the policy context and PA's/MPS's objectives.

Mr John Smith CgMs Consulting

Policy WTC12 - Car and Cycle Parking

wtcpo133 Previous representations to the Notices of Preparation requested that parking should be considered on a site by site basis with operational requirements taken into account. However, both of these policies continue to refer to the standards in Development Management Appendix 4. On this point we would note that representations submitted to the Development Management DPD Preferred Options in February 2011 also requested that car parking provision should be considered on a site by site basis, in order to take into account operational requirements. The Proposed Submission is due out for consultation Nov/Dec 2011 so it is unclear at this stage whether this has been taken on board. However, we would stress that London Plan (2011) Parking Addendum to Chapter 6 'Parking for emergency services facilities', para 6A.l0 states that 'Provision for parking at ambulance, fire and policing facilities will be assessed on their own merits.'

Noted – This issues will be dealt with through the adoption of the Development Management DPD.

Mr John Smith Policy WTC15 - wtcpo134 This Policy states that the loss of existing social infrastructure in the Centre Agreed - Proposals for loss of social

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Point Comments


CgMs Consulting Social Infrastructure

will be resisted, and no exceptions are given in the policy or supporting text. The MPA/ MPS object to this on the basis that it is wholly inconsistent with the Policies within the Core Strategy and Development Management DPO. One of the Core Strategy Post Publication Changes is that Policy CS4 point A) is amended to read as follows: "A) promoting the enhancement of existing social infrastructure and resisting its loss unless it meets the criteria as set out in Policy DM18 Social Infrastructure." Development Management Policy DM18 clearly sets out the circumstances in which the loss of social infrastructure would be permitted: Policy DM18 (A) Resisting the Loss of Social Infrastructure The Council will resist the loss of social infrastructure facilities unless all of the following conditions are met: a) No shortfall in provision will be created by the loss; b).Adequate alternative facilities are already available in the area; c) A replacement facility that meets the needs of the local population is provided, with a preference for on-site provision; and d. The specific social infrastructure facility is no longer required in its current use. Where this is the case, evidence will be required to show that the loss would not create, or add to, a shortfall in provision for the specific infrastructure type and demonstrate that there is no demand for any other suitable community use on the site. Recommendation: The MPA/MPS therefore recommends that Policy WTC15 is amended to reflect the approach to the loss of social infrastructure contained within the Core Strategy and Development Management DPDs.

infrastructure will need to be in accordance with Development Management Policy DM18 and Core Strategy policy CS3. These policies will loss of social infrastructure.

Mr Louis Gavriel, New Business Manager Islington & Shoreditch Housing Association

Policy WTC1 - Housing Growth

wtcpo61 What is the reasoning to support HMOs above shops? The Council will support HMOs in the town centre, particularly above shops as it will; 1) make best use of often empty or underutilised space, 2) provide natural overlooking thus improving safety and security, 3) provide additional activity, particularly in the evening 4) in accessible location and so reduce parking needs and 4) provide additional customers for local business.


Policy WTC3 - Affordable Housing and Tenure MixÂ Â Â Â Â Â

wtcpo63 Cascade approach described under B above is only really suited to long term phased schemes. Should not apply to small/medium sized projects.

Noted - The aim of the Council is to maximise the amount of affordable housing developed in the borough. The 'cascade approach' is aimed at maximising the number of quality affordable homes in the borough no matter how long they take to develop or size of development. Â

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Point Comments



Policy WTC4 - Unit Mix

wtcpo64 This appears to recognise the fact that desired percentage ofÂ larger family dwellings (60%) will not be suitable for higher density schemes around the Station etc.

Noted

Mr Scott Davies Chapter 34 WTCP 19 - St Jame Street Health Centre

wtcpo48 Regarding the Arcade Site: I support the provision of additional housing, as it will contribute to housing affordability. The location, with its high degree of accessibility to both public transport and community and retail facilities suggests a much higher density than would normally be tolerated. I also support the proposed car-free nature of the development for the same reason. (Additional car-club bays for the area may be necessary). The inclusion of some 3-4 bedroom homes is fine, but these should be limited to the proposed terrace houses facing the Cleveland Park Rd frontage. A house of this size would indicate a high probability of families with children being accommodated, and would therefore have a greater need for dedicated private open space. The proposed height of 5-6 stories, though suggested in the masterplan, seems underwhelming given the town centre location. If carefully designed, I think a height of up to 10 stories on part of the site could be tolerated without unreasonable impacts on the surrounds. The straight lines of the indicative form of the building are disappointingly bland. In particular, the sharp corner at the Hoe st/High St intersection is a wasted opportunity. A curved or truncated corner at this intersection would be a better and more sympathetic response to the site characteristics, because it would: - Be less of an impediment to the existing busy pedestrian route from the bus terminal/High St to Hoe St and northwards- one of Walthamstow's busiest desire lines; - Echo the curved corner of the buildings at the south-western and south-eastern corners of this intersection, and therefore better reflect local character; - Provide a visually more interesting building form for this important location; - Better 'introduce' the nearby shopping hub (as seems to be required by the May 2011 masterplan); - Better reflect the successful temporary public space currently at the site. Additionally, and importantly, a curved/truncated corner would allow the proposed public space to be located at the intersection, rather than along the High St frontage of the building. This would be a better location for the public space, because: - It would be located further from the Town Square (and therefore represent a better distribution of valuable local public space in a busy area). - Space Syntax research has identified that the most successful public spaces have multi-directional views into the surrounding area over

Support noted for the general principles of development. The Council also notes your detailed comments on design of this site

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Point Comments


and above that which is typically found in the surrounding street network. A public space directly at the intersection of Hoe and High streets would provide views in four directions, and would better fulfil this criteria than the public space as proposed; - The configuration of the public space as proposed would be limited in its adaptability for a variety of uses due to its elongated shape; - As proposed, the open space would read as a semi-public area which is 'owned' by the adjacent shops rather than as truly public space, and would therefore not be well-defined. It would simply appear as a building which is set-back from the street slightly further than other nearby buildings, and would therefore seem unexceptional in comparison to a ‘normal' street space. The 'pure / clean and straight building line' championed is not a necessary prerequisite for a well-defined public space, and has more to do with current urban design fashion than it does with the site's characteristics.

Mr Simon Banks Planning Liaison Officer Environment Agency


wtcpo116 We understand that the above document has been made available for public consultation. However, we have no record of being formally consulted by your Authority, but were made aware of the consultation by another means. Please ensure that we are directly consulted on all future Local Development Framework (LDF) consultations to ensure we have sufficient time to review the documents and to allow our comments can be considered.

Noted

Mr Simon Banks Planning Liaison Officer Environment Agency


wtcpo117 Having reviewed the Area Action Plan (AAP) and associated documents, we are concerned that our comments on the previous iteration of the document have not been taken into account in the preparation of the Preferred Options. We remain concerned that there is no specific mention of reducing surface water runoff through new development. Although paragraph 13.9 of the AAP states that "New development should be built in accordance with Development Management policy 35 which relates to flood risk management", this policy does not support achieving greenfield runoff rates from new development. As this is a key objective of the London Plan (Policy 5.13), we would expect it to be more prominent in the AAP. Parts of this area are within Groundwater Source Protection Zone 2, therefore sensitivity of groundwater beneath these areas is increased. Depending on the site history and the details of the proposed development, planning constraints may be imposed on development in these areas in order to protect controlled waters. These issues should be referred to in the AAP, as it is responsible for identifying constraints to development as well as opportunities. We also note that despite our previous comments encouraging the inclusion of support for green/brown roofs in new development (again, a key objective of the London Plan), there is no reference to these in the AAP. Your Authority may consider it more appropriate to address these issues in the supporting

Agreed - The Council will refer to reducing surface water runoff through new development the groundwater Source Protection Zone 2 and support for green/brown roofs in new development in to the justification of chapter 13.

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Point Comments


text, rather than explicitly through policies, or that these issues are sufficiently covered by other LDF documents or in the London Plan itself. However, we consider that it is important that they are at least referred to within the AAP to ensure users of the plan, in particular developers, are fully informed.

Mr Will Vote Strategy Manager NHS North East London


wtcpo78 In light of the recent consultation request for the above mentioned Area Action Plan (AAP), NHS Outer North East London would like to comment on 3 issues arising. Firstly, we believe that the redevelopment of St James Street Health Centre should be listed as a project as part of the plans to adopt a Community Infrastructure Levy (CIL) in LBWF. Whilst the site is listed as WTCP19 later in the AAP, it is unclear whether this automatically entitles it to funds as part of CIL. We are proposing this so that the project can be the recipient of levy funds. Secondly, as a general point, we support the inclusion of the St James Street Health Centre site in the document, as we believe that the site has an important part to play in health care provision in Walthamstow. Thirdly, in relation to Policy Option WTC15, NHS Outer North East London would prefer to see alternative option 1 used. Clearly such a policy approach would favour the provision of healthcare facilities in Waltham Forest and would be in accordance with the London Plan. This alternative policy would reflect the needs and the strong policy case for better health (and presumably education) premises in line with population growth.

Noted - The Council will seek contributions to health through planning obligations and use future CIL. The in principle, the health element of the site could be allocated monies. This decision would be made though other mechanisms Support noted for sites inclusion in the AAP and development option.

Mrs Samantha de Lotz Area Manager Bus Operations, London Buses, Transport for London

Chapter 10 High Quality Shopping, Business and Visitor Centre

wtcpo35 Section 10 refers to increasing retail space, including extending Selborne Walk shopping centre. Buses sometimes experience delays on Selborne Road at the weekends caused by vehicles queuing for the car parks and this is particularly bad during the run up to Christmas. I have a concern that unless additional car park space is provided, this problem could get worse.

Noted - The Council are aware of the issues relating to congestion within the town centre, particularly at peak times during the day. It is the Council's view that this is largely related to the road configuration at the gyratory system and the entrance and exists to the bus station. Policy WTC10 seeks to simplify this configuration in order to improve traffic flow and reduce congestion. Policy WTC11 promotes sustainable forms of transport. The Council will seek that new retail, employment, leisure and community uses meet the parking standards in the development management DPD. The Council is seeking 'car free' housing development which should help reduce congestion.

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Point Comments



Chapter 11 Movement and Accessibility

wtcpo32 Section 10 refers to increasing retail space, including extending Selborne Walk shopping centre. Buses sometimes experience delays on Selborne Road at the weekends caused by vehicles queuing for the car parks and this is particularly bad during the run up to Christmas. On behalf of the Bus Opeations team at London Buses, I have a concern that unless additional car park space is provided, this problem could get worse.

Noted - The Council are aware of the issues relating to congestion within the town centre, particularly at peak times during the day. It is the Council's view that this is largely related to the road configuration at the gyratory system and the entrance and exists to the bus station. Policy WTC10 seeks to simplify this configuration in order to improve traffic flow and reduce congestion. Policy WTC11 promotes sustainable forms of transport. The Council will seek that new retail, employment, leisure and community uses meet the parking standards in the development management DPD. The Council is seeking 'car free' housing development which should help reduce congestion.



wtcpo42 This car park is utilised by London Buses Rail Replacement team under an agreement with LBWF parking dept during LULÂ Victoria Line closures to provide necessary stand space for the Rail Replacement Bus Service. Prior to gaining approval the buses used to stand on Selborne Road which resulted in traffic delays affecting other road users as well as the other bus services. The loss of this space would make it difficult to run the service and alternative stand space would be need to be found.

Noted - The Council will consult with TFL on any proposals or planning applications brought forward on this site.


Chapter 21 WTCP 6 - HSBC Site

wtcpo40 On behalf of TfL's Bus Operations team I am concerned that enlarging the shopping centre will result in traffic delays on Selborne Road. Buses already experience delays on Selborne Road especially in the run up to Christmas caused by cars queuing for the car park.




wtcpo41 On behalf of TfL's Bus Operations team I wish to object to the relocation of the Bus Stand to South Grove as I do not believe that there will be sufficient space to provide like for like bus stand space and driver facilities in addition to the existing bus stands on South Grove all of which are essential to maintain for the smooth running of the bus services. Relocating the stand would also break the existing bus/rail interchange with St James's Street station and therefore be a dis-benefit to passengers.

Noted - As a result of your objection and given its limited redevelopment potential, the Council has removed the site as an opportunity site in the AAP.

Mrs Samantha de Chapter 32 wtcpo39 On behalf of TfL's Bus Operations team, I would like to understand the Noted - The Council will consult with TFL

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Point Comments


Lotz Area Manager Bus Operations, London Buses, Transport for London

WTCP 17 - Courtney Place

potential impact that this could have on the bus station and would like to be included in the consultation process.

on any proposals or planning applications brought forward on this site.


Figure 12.1 Urban Design Analysis - East Architects

wtcpo38 On behalf of TfL's Bus Operations team I am concerned about the impact that changing the pedestrian crossing at the Church Hill / Hoe Street junction to a straight crossing would have on bus journey times.

Noted - The Council are seeking to improve the pedestrian environment in the centre. Junction improvements are part of this aim. The Council also seek to improve traffic flows though a number of measure. Analysis of the impacts on traffic flows will be undertaken with any proposed junction improvements.



wtcpo33 On behalf of TfL's Bus Operation team I would welcome any improvements to traffic flows which would improve bus journey times, especially for the north-south bus routes which have to negotiate the gyratory twice in each direction in order to serve the bus station on Selborne Road. I am concerned that improvements to pedestrian crossings could be to the detriment of buses by adding delays because of additional traffic signals or longer pedestrian phases.

Noted - The Council is seeking to improve the pedestrian environment in the centre. Junction improvements are part of this aim. The Council also seeks to improve traffic flows though a number of measures. Analysis of the impacts on traffic flows will be undertaken with any proposed junction improvements.



wtcpo36 On behalf of TfL's Bus Operation team I would welcome any improvements to traffic flows which would improve bus journey times, especially for the north-south bus routes which have to negotiate the gyratory twice in each direction in order to serve the bus station on Selborne Road. I am concerned that improvements to pedestrian crossings could be to the detriment of buses by adding delays because of additional traffic signals or longer pedestrian phases.

Noted - The Council is seeking to improve the pedestrian environment in the centre. Junction improvements are part of this aim. The Council also seeks to improve traffic flows though a number of measures. Analysis of the impacts on traffic flows will be undertaken with any proposed junction improvements.


Policy WTC11 - Sustainable Transport

wtcpo34 On behalf of TfL Bus Operations team I am concerned that the improvements for pedestrians and cyclists could be to the detriment of the buses and that traffic calming measures could increase bus journey times and passenger discomfort. I would like to understand more the impact this would have on buses before I agree.

Noted - The Council is committed to encouraging a modal shift away from private car use to more sustainable forms of transport which includes taking advantage of the excellent transport links in the centre, particularly bus services. While traffic calming measure may reduce the speed of traffic, this is aimed at making roads safer and more attractive to road users as opposed to slowing traffic

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Point Comments


to increase journey times.


Policy WTC11 - Sustainable Transport

wtcpo37 On behalf of TfL'sÂ Bus Operations team I am concerned that the improvements for pedestrians and cyclists could be to the detriment of bus journey times and passenger comfort if traffic calming measures are added and if cyclists and pedestrians are given the priority at traffic signals.

Noted - The Council is promoting a modal shift away from the private car towards more sustainable forms of transport. This will help reduce congestion and improve traffic flows and thus, it is hoped, improve bus journey times.

Ms Kerri Cheek Senior Borough Programmes Officer Transport for London - Better Routes & Places

Monitoring Table 1 - Policies/Objectives

wtcpo31 Objectives 5 and 6 - Alterations are required to the targets quoted (cycling, walking and CO2 reduction) in order to align them with changes made to the draft LIP2 document. Please contact WF Borough officers - Kevin Burke or Neil Bullen for the final targets.

Noted - The Council will check with stated officers and amend final draft as necessary.



wtcpo28 LB Waltham Forest will need to ensure they work with Transport for London and in particular London Buses in order to achieve any changes to the configuration of the bus station especially if the Borough are seeking changes to bus operations. Please ensure TfL are fully engaged at the start of any proposals so that full discussions can take place with all options considered.

Noted - The Council will fully involved and consult with TFL and London Buses when considering proposals for the reconfiguration of the gyratory system and bus station.


Chapter 11 Movement and Accessibility

wtcpo30 No mention is made of providing Electric Vehicle charging points or car club bays and we would encourage LB Waltham Forest to consider these in any changes to Walthamstow Town Centre and future schemes.

Agreed - The Council will include details of car clubs and electric car charging points in the submission draft



wtcpo29 TfL broadly support the aspirations and development at the Arcade Site, however please speak to us about the impacts of any changes in bus services at the gyratory and how these changes in traffic may affect the Arcade site or vice versa. It appears that this is an ambitious pedestrianised area or shared space scheme in the High Street and the impacts on traffic generally and bus services in particular will need to be fully explored.


Ms Rachel Livings Associate Director Pollard Thomas Edwards

Chapter 34 WTCP 19 - St Jame Street Health Centre

wtcpo56 In terms of new building heights our view would be that there are a number of factors to be considered in determining appropriate heights. With particular reference to the Arcade Site, we suggest that a taller element is not the only suitable solution. For this important town centre site, in its

Noted - The submission draft AAP will undertake a process of analysis where tall buildings are considered appropriate and establishing appropriate heights on these

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Point Comments


architects gateway location an overall height of about six storeys with appropriate articulation, such as breaks and set-backs or varied parapet, eave, and roof lines, could be employed to deliver a memorable building that sits well within its context. Our view on building heights is as commented on above. We query the PTAL rating referred to on page 86. The document lists the Arcade site at 5, but according to the "Tell Planning Information Database," the site is rated at 6A. Â

sites. This site is considered a 'landmark' as it is at a prominent corner towards the entrance to the centre. The Council also notes your detailed comments on design. The Council will take this into consideration when developing the detailed proposals on this site. The Council will amend the PTAL rating in the submission draft of the AAP.

Ms Rachel Livings Associate Director Pollard Thomas Edwards architects


wtcpo53 In terms of new building heights our view would be that there are a number of factors to be considered in determining appropriate heights. With particular reference to the Arcade Site, we suggest that a taller element is not the only suitable solution. For this important town centre site, in its gateway location an overall height of about six storeys with appropriate articulation, such as breaks and set-backs or varied parapet, eave, and roof lines, could be employed to deliver a memorable building that sits well within its context.

Noted - The Council will undertake a design analysis and consider a range of factors including accessibility to transport, quality of design and architecture, materials, impact of privacy and amenity of adjacent properties, site context, topography and impact on micro climate when determining appropriate building heights.

Ms Rachel Livings Associate Director Pollard Thomas Edwards architects


wtcpo58 In terms of new building heights our view would be that there are a number of factors to be considered in determining appropriate heights. With particular reference to the Arcade Site, we suggest that a taller element is not the only suitable solution. For this important town centre site, in its gateway location an overall height of about six storeys with appropriate articulation, such as breaks and set-backs or varied parapet, eave, and roof lines, could be employed to deliver a memorable building that sits well within its context.

Noted - The Council will consider a range of factors including accessibility to transport, quality of design and architecture, materials, impact of privacy and amenity of adjacent properties, site context, topography and surrounding land forms and impact on micro climate when determining appropriate building heights.

Nicholas Bishop Regional Planning Advisor - London Region English Heritage

Chapter Appendix 2 - Evidance Base

wtcpo131 It might be worth including a definition of heritage assets (see PPS5) which has a specific meaning in the context of PPS5.

Agreed - The Council will include this definition in NPPF



wtcpo119 7 Policy Context: National Policy (page 18): The national policy section does not currently provide a review of PPS5. This is important since the AAP seeks to provide guidance on the management of heritage assets within the AAP area. We therefore suggest that PPS5 should be identified and reviewed here to set the context for the AAP policies which follow. In addition, historic environment policies from the London Plan could be identified within the regional policy context, after paragraph 7.5.

Agreed - The Council will include reference to the NPPF policies related to the historic environment in the London Plan

Nicholas Bishop Regional

Chapter 12 Design and

wtcpo129 We welcome the monitoring indicators suggested regarding the historic environment, particularly the production of a conservation area appraisal for

Support noted

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Point Comments


Planning Advisor - London Region English Heritage

Place Making Walthamstow Village.


Chapter 13 A Sustainable Centre

wtcpo118 Thank you for the opportunity to comment on the above document. As the Government's adviser on the historic environment English Heritage is keen to ensure that the protection of the historic environment is fully taken into account at all stages in the development of the local planning process and we welcome the opportunity to comment on this Area Action Plan (AAP). We welcome the production of this AAP which will help manage change in Walthamstow Town Centre and ensure high quality design. Planning Policy Statement 5: Planning for the Historic Environment (PPS5) (2010) requires that, through their Local Development Frameworks (LDFs), local authorities set out a "positive, proactive strategy for the conservation and enjoyment of the historic environment" (HE 3.1). This AAP provides an opportunity to meet this requirement of PPS5. In particular, the AAP can respond to PPS5 by helping ensure that new development is appropriate to its local and historic context. English Heritage has published Understanding Place (2010) to provide further guidance on how this can be achieved. We hope these comments help strengthen the Walthamstow Town Centre AAP and we look forward to viewing the next iteration of the document in due course. English Heritage would strongly advise that staff with expertise in heritage matters are closely involved throughout the preparation of the LDF, as they are often best placed to advise on local historic environment issues and priorities, sources of data and consideration of options relating to the historic environment. Finally, we should like to stress that this opinion is based on the information provided by you. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

Noted


Chapter 14 Planning Obligations

wtcpo128 Planning Obligations (page 74): Planning obligations are an important source of investment for the historic environment, which we suggest should be identified as a possible recipient here.

Agreed - The Council will include the historic environment in the list of areas where they may seek a contribution.



wtcpo125 We welcome the proposal to conserve this Grade II listed building. Support noted

Nicholas Bishop Chapter 20 wtcpo123 We welcome the proposal to retain this building Support noted - The site has been locally

39


Point Comments


Regional Planning Advisor - London Region English Heritage

WTCP 5 - EMD Cinema

listed.



wtcpo124 There is also an opportunity to repair the frontage to Hoe Street and ensure that the site complements the existing Victorian and Edwardian residential development which surrounds the site.

Noted



wtcpo122 The point could be made that a landmark building at this site need not be a tall building.

Agreed - In the submission draft document the Council will include more detail in relation to the definition of a landmark building on this site.



wtcpo126 It should be noted that this site sits within the setting of the Grade II listed EMD cinema.

Noted - The Council will add to the justification the need to consider the local context and in particular the neighbouring Grade II listed building.



wtcpo127 The justification for building heights suggested in the policy should be made clear within the supporting text. Regarding the potential for a taller element on Hoe Street, the policy should provide a clear upper limit to discourage excessively tall schemes which could sit uncomfortably within the local context. It should be noted that this site falls within an archaeological priority zone.

Noted - The submission draft AAP will undertake a process of analysis where tall buildings are considered appropriate and establishing appropriate heights on these sites. This site is considered a 'landmark' as it is at a prominent corner towards the entrance to the centre. The Council also notes your detailed comments on design. The Council will make a general reference in the document that parts of the AAP are in an archaeological priority zone.


Chapter 36 Monitoring

wtcpo130 We are pleased to see that the Waltham Forest Characterisation Study has been included here. We suggest that it would also be worth including PPS5 and the Walthamstow Village Conservation Area leaflet.

Agreed - The Council will include these documents in the evidence base list.


Chapter 7 Policy context

wtcpo121 12 Design and Place making: We welcome the identification of heritage assets within the design and place making chapter (along with their presentation on a plan) (page 56) and the discussion of townscape character. This approach could be strengthened further with a brief discussion of the contribution these heritage assets make (particularly the

Noted - The Council will strengthen chapter with reference to contribution heritage assets make to the town centre. The Council will set out a Plan wide building heights parameter. We will

40


Point Comments


conservation area) to the local character, and the corresponding need for historically contextual design (paragraph 12.12 as a component of quality in new design. Policy WTC14 (page 64): We broadly support policy WTC14, particularly regarding the proposal to set a framework for building heights (paragraph 4), which we believe is the most effective way to manage tall buildings within the AAP area. However, we question why area-wide building heights parameters have not been specified in this iteration of the AAP, where they have for the individual sites. The current wording, that building heights should "be sympathetic in scale to..." is insufficiently robust to cover the many infill sites where no building heights are specified. We suggest that building heights parameters should be established for the area as a whole. Given that many of the individual sites covered are infill, we suggest that an additional policy should be added to ensure that new development is designed to integrate well with the wider local context (composed to a large extent of Victorian terraces). The Waltham Forest characterisation study should be drawn on as a source to aid this. Finally, we suggest that paragraph 5 could be strengthened in regard of PPS 5 with an explicit reference to enhancing heritage assets, as well as buildings of character.

include in the policy the need for infill development to integrate well with the wider local context.



wtcpo120 Walthamstow Town Centre Vision and Objectives (page 23): To fully reflect PPS5 paragraph HE 3.1 the vision could give greater emphasis to conservation of the Town Centre's historic environment and its potential to be a catalyst for regeneration and a stimulus to inspire high quality new development.

Agreed - The Council will amend the vision to give greater emphasis to conservation of the Town Centre's historic environment.

Richard Anderson


wtcpo110 As has been recognised in your draft AAP, my client still has significant additional land interests at and around Walthamstow Central station. Building on works already commenced my client does wish to confirm and make clear the following: The site is currently a publicly available surface level car park. The opportunity for redevelopment and more efficient use of this land is recognised. The site would be appropriate for mixed use development where residential could be a prominent feature complimented by active frontages especially at ground floor level. Given rail-related agreements currently in place a significant number of parking spaces will be required to be maintained either in current form or as part of any future redevelopment. Given the town centre location of the site and its proximity to railway operations any development proposed must respect these sensitivities. Given the size of the site and in order to deliver a vibrant community which embraces the development already coming forward (Phase 1), a full range of residential and where appropriate commercial uses will be considered. Pedestrian access to/from Queens Road station and Walthamstow Central station which has been enabled and will be

Noted - The Council welcome the opportunity to work with Solum Regeneration in order to bring this site forward for redevelopment.

41


Point Comments


significantly improved as part of the Phase 1 redevelopment will be maintained in any future redevelopment of Phase 2. The site area is 0.498 ha. The revised site area reflects inclusion of land-take adjacent to the station buildings as part of the Phase 1 development now underway. Please find attached a revised site plan. Overall, the site is in a suitable location for housing development, within a town centre. Further development by Solum Regeneration at Walthamstow station will meet Government objectives of creating mixed and sustainable communities, and ensuring that housing is developed in suitable locations which offer good access to jobs, key services and infrastructure. Solum Regeneration will continue to work with the Council as they prepare the Walthamstow Area Action Plan by promoting the site as a major opportunity which can not only contribute towards housing but to the improvement of the town centre as a whole.

Richard Anderson

Chapter 35 Implementation

wtcpo112 Solum Regeneration is a partnership formed between Network Rail and Kier Property, to bring forward station improvements and regenerate surrounding underused station assets and property, primarily through mixed use development. As you are no doubt aware, Solum Regeneration is already bringing forward significant improvements in Walthamstow having been granted planning permission to regenerate the eastern portion of their land interests (Phase 1) on March 25 th 2011. Already work has commenced to deliver a new hotel, new retail units, new private and affordable homes as well as a new public station realm to the area. Walthamstow is one of several prominent locations in the south-east where planning permission has been granted and work has also commenced or where regeneration plans are at a less advanced stage.

Noted

Rose Freeman Planning Policy Officer The Theatres Trust (for arts & culture issues only)


wtcpo98 The Theatres Trust is The National Advisory Public Body for Theatres. The Theatres Trust Act 1976 states that 'The Theatres Trust exists to promote the better protection of theatres. It currently delivers statutory planning advice on theatre buildings and theatre use through the Town & Country Planning (General Development Procedure) (England) Order 2010 (DMPO), Articles 16 & 17, Schedule 5, para.(w) that requires the Trust to be consulted by local authorities on planning applications which include 'development involving any land on which there is a theatre.' Due to the specific nature of the Trust's remit we are concerned with the protection and promotion of theatres and therefore anticipate matters relating to cultural facilities.'

Noted

Rose Freeman Planning Policy Officer The Theatres Trust (for arts & culture

Policy WTC6 - Hot Food Takeaways, Estate Agents, Betting Shops

wtcpo101 WTC7 Pubs - Pubs can be transformed as additional leisure venues to provide a range of performance spaces, for new plays and dance, and live music and comedy, to make a vibrant contribution to the evening economy and to help ensure their survival.

Noted - The Council recognise that well managed pubs can help enhance and promote the evening economy in the borough.

42


Point Comments


issues only) and Off Licences

Rose Freeman Planning Policy Officer The Theatres Trust (for arts & culture issues only)

Policy WTC8 - Leisure, Entertainment, Culture and Tourism

wtcpo100 WTC8 Leisure, Entertainment, Culture and Tourism - We support the four aims in this policy option - sites for new leisure attractions - new Leisure Zone - Cultural Cafe Quarter - support for the evening economy. If urban renaissance is to succeed, a balance needs to be found between the main function of the town centre as a shopping and employment destination, the amenity of the residential population, and the opportunities for everyone to enjoy an evening out. Evening and night-time activities are a fundamental part of urban renaissance because they ensure the vitality of an area beyond normal working hours. However, there could be concern for the collective impact of drink-related and takeaway uses on the environment and on the ambience experienced by other night-time visitors to town centres who may be discouraged from extending their town centre trip for a meal out which contributes to the atmosphere and night-time economy. The town centre should act as an important cultural hub for the arts, tourism and education. It should also make a significant contribution to the liveliness of the town by attracting large numbers of people, especially at weekends. The challenge therefore should be to build on existing strengths and broaden the appeal of the centre to encourage a wider range of ages and social groups including families and older people. When contemplating suitable sites for new leisure venues, the refurbishment and re-use of existing buildings usually requires significantly less energy than building new ones and therefore supports the aims of sustainable development. This option should be seriously considered for sustainable town centres particularly where the existing building makes a positive contribution to local character or where it can form the basic building block of a new development.

Support noted - The Council recognise the concerns raised in relation to poorly managed pubs and the proliferation of hot food takeaways and the need for careful management. Policy WTC6 seeks to resist new Hot Food Takeaway locating in the centre. The Council seeks to build on existing strengths and broaden the appeal of the centre to encourage a wider range of ages and social groups including families and older people. Policy WTC8 seeks to develop a strong leisure, entertainment and cultural offer in the centre. The Council will add a reference to the document stating the need to reuse buildings, particularly where it makes a positive. We also note you comments in relation to reuse of existing buildings within the AAP boundary as a sustainable option.

43

Part II - Questionnaire Outcomes Walthamstow Town Centre Area Action Plan Preferred Options

Do you agree with the proposed boundary for the AAP? Yes 4

No 1

Options Strongly Agree

Agree Neutral Disagree Strongly Disagree

Do you agree with the vision? 3 2 0 0 0

Objective 1 - Promoting Walthamstow's unique retail offer. 4 0 0 0 0

Objective 2 - Improving the Quality of Walthamstow's retail offer.

3 1 0 0 0

Objective 3 - Creating a vibrant, attractive and competitive town centre.

3 1 0 0 0

Objective 4 - Creating and establishing a sustainable neighbourhood.

3 1 0 0 0

Objective 5 - Improving accessibility to the centre. 3 1 0 0 0

Objective 6 - Creating a more sustainable centre. 3 1 0 0 0

Objective 7 - Creating a high quality accessible and inclusive environment.

3 1 0 0 0

Objective 8 - Creating an attractive and distinctive centre. 3 1 0 0 0

Objective 9 - Diversifying and balancing the centres economy.

2 2 0 0 0

Objective 10 - Supporting growth with the appropriate level of social infrastructure.

3 1 0 0 0

WTC1 – Housing Growth

A) Delivering up to 2000 new homes in the centre; 2 1 0 0 0

B) Delivering these new homes on designated 'key opportunity sites' (see proposals in chapter 16 - 35);

1 2 0 0 0

C) As part of mixed use development; 2 0 1 0 0

D) Through infill development; and 2 0 1 0 0

E) Promoting housing above shops, in particular Houses in Multiple Occupation.

1 0 2 0 0

WTC2 – Housing Density

A) Housing densities of between 200 - 700 hr ha; 1 1 1 0 0

B) Concentrate higher density development around Walthamstow Central;

2 0 1 0 0

C) Lower density development located near lower density residential areas and near conservation areas.

1 2 0 0 0

WTC3 – Affordable Housing and Tenure Mix

A) Provide at least 50% affordable housing negotiated on a site by site basis subject to viability;

2 1 0 0 0

B) Where a viability case is used to justify an affordable housing offer below 50%, we will require the shortfall to be treated as a deferred contribution;

0 3 0 0 0

C) Provide a tenure split of 60% affordable rent and 40% Shared Ownership.

2 1 0 0 0

WTC4 – Unit Mix

A) Negotiate the unit mix on a site by site basis taking a flexible approach to the provision of family housing;

2 0 1 0 0

B) Where family housing is provided, locating it on the ground floor where it has access to private usable amenity space.

2 0 1 0 0

WTC5 - Retail

44



A) Develop 'opportunity sites' for additional retail floorspace (see proposals in chapter 16 – 35);

0 3 0 0 0

B) Where appropriate, allow the extension of sites to increase retail floorspace;

0 3 0 0 0

C) Consolidate retail development within the core of the centre in the designated primary and secondary retail frontages;

0 3 0 0 0

D) Upgrade and further diversifying the overall range, mix and quality of uses within the centre; and

0 3 0 0 0

E) Promote, support and enhance the development of Walthamstow Market.

2 1 0 0 0

WTC6 – Hot Food Takeaways, Estate Agents, Betting Shops and Off Licences

A) Resist the development of any new Hot Food Takeaway, Estate Agent, Betting Shop or Off Licence; and

2 0 0 0 1

B) Seek to reduce the number which already exist within the centre.

1 2 0 0 0

WTC7 - Pubs

A) Resist the loss of any existing pubs within the centre; and

2 1 0 0 0

B) seek to promote healthy pubs. 2 1 0 1 0

WTC8 – Leisure, Entertainment, Culture and Tourism

A) Developing opportunity sites for additional leisure, entertainment, culture and tourism floorspace (see proposals chapter 16 - 35);

2 0 1 0 0

B) Support the development of a 'Leisure Zone and Entertainment ' at the eastern end of the High Street;

1 2 0 0 0

C) Support the creation of a 'Cultural Café Quarter' at the western end of the High Street; and

1 1 0 1 0

D) Facilitate and support the growth of the evening economy, with particular focus in the 'Leisure and Entertainment Zone' and 'Cultural Cafe Quarter'.

2 1 0 0 0

WTC9 - Employment

A) Protect existing employment uses within the centre on Hatherley Mews and East London Office centre;

0 3 0 0 0

B) Further diversify the range of employment generating uses within the centre;

0 3 0 0 0

C) Develop opportunity sites for additional employment floorspace (see proposals in chapter 16 - 35);

1 2 0 0 0

D) Encourage the development of creative and cultural industries; and

1 1 1 0 0

E) Support the development of a Business Improvements District.

1 2 0 0 0

WTC10 – Transport Improvements

A) Work with TFL and other transport providers to ensure there is sufficient transport capacity on the existing bus and rail transport system;

5 0 0 0 0

B) Simplify the layout of the gyratory system on Hoe Street to reduce traffic congestion and improve traffic flows within the centre;

5 0 0 0 0

C) Improve pedestrian crossings at a) High Street/Hoe Street, b) Hoe Street/Selborne Road c) Walthamstow Central exit/Selborne Road/Bus Station and d) Palmerston Road/High Street;

3 0 2 0 0

D) Establish a pedestrian and cycle link between key transport interchanges at Walthamstow Queens Road and Walthamstow Central;

3 1 1 0 0

E) Create a new walkway(s) under the Liverpool Street to Chingford line to improve connectivity between the centre and communities to the north and south at South Grove and Queens Road Station;

2 3 0 0 0

F) Improve north/south links throughout the town centre; 3 2 0 0 0

45



G) Remove unnecessary obstacles, barriers and street clutter within the public realm;

3 2 0 0 0

H) Improve the lighting in and around the centre to improve safety and security; and

4 1 0 0 0

I) Requiring new development to provide financial contributions towards projects that enhance the transport network in the centre.

3 1 1 0 0

WTC11 – Sustainable Transport

A) Support a range of improvements to promote and enhance the environment for pedestrians and cyclists; and

2 1 0 2 0

B) Improve the cycle network in the centre. 2 0 2 1 0

WTC12 – Car and Cycle Parking

A) Ensure that all new residential development within the centre is 'car free' incorporating the appropriate level of cycle parking; and

2 0 0 0 0

B) Ensure that all new retail, leisure, community and cultural uses provide appropriate levels of car and cycle parking in accordance with DM appendix 4.

2 0 0 0 0

WTC13 – High Quality Environment

A) Support the reorganisation of the market to improve the appearance and function of the market and pedestrian circulation;

3 0 0 0 0

B) Incorporate the principles of 'High Street Life Strategy' to new shop fronts on Hoe Street, High Street and St James Street;

3 0 0 0 0

C) Designate Hoe Street as an 'Area of Public Realm Improvement';

3 0 0 0 0

D) Improve the pedestrian environment through a range of public realm improvements and by including Walthamstow as part of the 'Legible London' wayfinding scheme;

3 0 0 0 0

E) Protect and enhance the heritage of the centre; 1 1 1 0 0

F) Remove unnecessary obstacles, barriers and street clutter within the public realm;

2 1 0 0 0

G) Enhance and improve the quality of green spaces throughout the centre;

3 0 0 0 0

Provide play facilities in the centre, particularly in areas of deficiency;

3 0 0 0 0

H) Incorporate improvements to the public realm in order to make the centre more active and secure; and

3 0 0 0 0

I) Require new development to provide financial contributions towards projects that enhance the existing public realm.

2 1 0 0 0

WTC14 – Design and Place Making

A) Creating, improving and reinforcing convenient and safe pedestrian and cycle routes to the town centre, particularly north-south from Selborne Road and further south from the railway line;

2 0 1 0 0

B) Improving the key 'arrival' points into the centre for residents and visitors via public realm, landscaping, signage, public art and other environmental improvements;

2 1 0 0 0

C) Significantly raising the quality of architectural and urban design in the area with development that positively responds to its context whilst encouraging the very best in contemporary design;

2 1 0 0 0

D) Setting a framework for building heights of new development to be sympathetic in scale to the predominant 2-3 storey context, whilst focussing taller buildings in key 'gateway' sites such as the Arcade site, the Town Square and South Grove;

1 2 0 2 0

46



E) Encouraging the restoration and ongoing improvement of existing buildings of character within the centre, including via shopfront and/or building grants where available;

1 1 1 0 0

F) Bringing forward a range of options for improving the town square and gardens, including the possibility of extending the Selborne Walk development and potential redevelopment of the bus station;

1 2 0 0 0

G) Developing and implementing a new public space strategy which provides comfortable, convenient and safe places for people to sit, relax and enjoy a variety of experiences within the town centre;

1 2 0 0 0

H) Incorporating 'active building frontages' in all new development to provide increased vitality, interest and safety at ground floor level for shoppers and visitors; and

1 2 0 0 0

I) Improving and developing a clear and robust management regime for the area encompassing cleaning, maintenance, partnership working, promotion and activities etc to reinforce the town centre offer for shoppers and visitors.

2 1 0 0 0

WTC15 – Social Infrastructure

A) Resisting the loss of existing social infrastructure in the centre;

1 1 1 0 0

B) Developing site for new social infrastructure (see proposals in chapters 16 - 35);

2 1 0 0 0

C) Incorporating social infrastructure as part of mixed-use development;

1 2 0 0 0

D) Contributions will be sought through planning obligations to support the provision of new social infrastructure or the expansion or improvement of existing facilities to meet the needs of the community and;

0 2 1 0 0

D) Wherever possible, new facilities should be a multi-use and be accessible by all members of the community.

2 1 0 0 0

WTC16 – Decentralised Energy

A) Requiring developments in the area to contribute towards establishing the system;

0 3 0 0 0

B) Connecting public sector buildings and redeveloped Council properties to the network in order to provide sufficient anchor loads;

0 2 1 0 0

C) Requiring all new development to link to the system, subject to viability;

0 2 1 0 0

D) Requiring all development which comes forward before the system is established to be 'connection ready'; and

0 3 0 0 0

E) Safeguarding routes for pipelines. 0 3 0 0 0

WTC17 - Access to Sites of Nature

A) Creating, improving and enhancing links to sites of nature conservation importance; and

2 0 1 0 0

B) Seeking developer contributions to create, improve and enhance links to sites of nature conservation importance.

1 0 2 0 0

Key Opportunity Sites

For Community Infrastructure Levy, do you agree with the list of 'Key Projects' needed for Walthamstow Town Centre?

0 1 1 0 0

Site WTCP1 - Snooker Hall - Housing led social infrastructure.

1 0 1 0 0

Site WTCP2 -Factory, corner of Tower Hamlets Road -Housing.

1 1 0 0 0

Site WTCP3 -Vacant Petrol Station, Hoe Street -Housing. 1 1 0 0 0

Site WTCP4 -Tax Office -Housing led with retail and office. 1 1 0 0 0

Site WTCP5 - EMD Cinema -Leisure. 2 0 0 0 0

47



Site WTCP6 -HSBC Site -Leisure and cultural. 2 0 0 0 0

SiteWTCP7 -Arcade Site -Housing led with leisure (cinema), ancillary restaurant and retail and extension to the public realm.

2 0 0 0 0

Site WTCP8 -Town Square and Gardens - Accommodation of retail extension of Selborne Walk Shopping Centre and improvement and enhancement of existing open space.

2 0 0 0 0

Site WTCP9 -Selborne Walk Shopping Centre - Extension of retail floorspace with housing on upper floors.

1 1 0 0 0

Site (WTCP10 - Station Car Park Phase II -Housing. 1 1 0 0 0

Site WTCP11 – Sainsbury’s Site -Retail and Housing. 1 1 0 0 0

Site WTCP12 - Osborne Mews -Housing. 1 1 0 0 0

Site WTCP13 - Buxton Road Bingo Hall -Housing, commercial and social infrastructure.

1 1 0 0 0

Site WTCP14 - 8 Buxton Road -Social Infrastructure (education).

1 1 0 0 0

Site WTCP15 - South Grove -Retail (superstore) and housing.

1 1 0 0 0

Site WTCP16 - Commercial (offices) led with housing. 1 1 0 0 0

Site WTCP17 - Courtney Place - Housing 1 1 0 0 0

Site WTCP18 - St James Street Car Park -Housing led with retail and social infrastructure.

1 1 0 0 0

Site WTCP19 -St James Street Health Centre -Social infrastructure and housing.

1 1 0 0 0