Watford Junction draft supplementary planning document Statement in accordance with Regulation12 (a) of the Town and Country (Local Planning) (England) 2012

1

WATFORD BOROUGH COUNCIL

Planning and Compulsory Purchase Act 2004

The Town & Country Planning (Local Planning) (England) Regulations 2012

Watford Junction Development Brief

Supplementary Planning Document (SPD)

Consultation Statement

1.1 The Town and Country (Local Planning)(England) Regulations 2012 under Regulation 12(a) requires local planning authorities to prepare a statement, setting out:

i the persons the local planning authority consulted when preparing the supplementary planning document;

ii a summary of the main issues raised by those persons; iii how those issues have been addressed in the supplementary planning

document;

1.2 In accordance with this part, and Regulation 13 of the named regulations, the persons and organisations consulted as part of the process for preparing the Watford Junction masterplan supplementary planning document (SPD) are identified in Appendix A.

1.3 Public Consultation on the Draft SPD took place over six weeks from 18th August 2016 to 3rd October 2016.

1.4 Copies of the draft SPD were provided in Watford Library, North Watford Library and Watford Town Hall’s customer service centre. A press notice was issued in the Watford Observer on Friday 12th August 2016. Facebook and Twitter were also used to raise awareness of the draft SPG consultation. Details of the consultation can be found here:

https://watford.jdi-consult.net/localplan/

1.5 Appendix A lists details of all who were notified of the consultation.

1.6 Appendix B summarises the responses received, the key issues identified by the named consultees, and it explains how the council is addressing these issues.

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Appendix A – People / Organisations Consulted

The following list is of the 81 people or organisations who were sent consultation letters by post.

NAME

ORGANISATION

Estate Office Brasier Freeth LLP

Indigo Planning Ltd Indigo Planning Ltd

Ms Shirley Barlow Mrs Perline McFarlane Watford African Caribbean Association

Dr A G Saleh Watford Arabic School

Mr Greg Westover Legal & General Property

unknown

North Watford Church of the Nazerene

unknown Watford YMCA

Katherine Hill GL Hearn Limited

Mr Abraham D Hailey

Planning

Jones Lang LaSalle

Mrs C Daniels Cassiobury Infant and Nursery School

Mr M A Parker Draughtsman

Mr Leigh Hutchings Talking Newspaper

Mr Felix Augustin Waterfield Residents Association

Mr Alex O'Reilly Oceana/Woohoo Night Club

V Gurney Mr Richard Hunt

Mr Robert Caton Sherafae Taylor Mr J Koroma Hertfordshire African Association

Mr Norman Tyrwhitt Honary Freeman of the Borough

Mr Kevin Fontaine - Waldron Jehovah's Witnesses

Ms Janine Gordon Radlett Road Community Association

Mr Haji M Yaqoob Watford Mosque

Mr Henry Pryer Watford Rail Users' Group

Gemma Foster Barrat Homes

Mrs M Boon Mr S Woollatt Ellen Boyle Mr Adam Norton Primeplace Development Ltd

Mrs L Breach Mrs Carol Fisken Nick Tunley Mr Chris Taylor Leavesden Green Residents' Association

Mr Mohammed Aslam Khan Watford Muslim Elders Association

Unknown Unknown Unknown TFL Property Team

Ms Judith Kingsley Civil Aviation Civil Aviation

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Mrs Ann Edwards Mr John Baker Mr D K Burch Mrs Janet Burch Mr Mark Buxton Nick Guildford Terence O'Rourke

Mr Matthew Lard DLP LTD

Mr Geoffrey Simm Keay Homes Limited

Mrs Barbara Mott Suthergrey House Medical Centre

Mrs Karen Chase West Herts College

Miss S M Wood Mr Stroud Ms Joyce Bonnick Friends of Alban Wood

Inspector David Wheatley Hertfordshire Police

Mrs M T Woodcock Holyrood RC Infant School

Mr Andrew Ward RG+P

Mr Hemam Mistry Shree Prajapati Association

Halkin

Miss K Wetherell Mary Forsyth Mrs M Patterson K.A. Richardson Mrs Christine Betts Mr Steven Wiffen Ms Sheila Jordan Mrs Simmonds Mr Adam Wood Herts Prosperity

unknown

St Martins Church

Mr David Nicholls Wu Shu Kwan

Unknown Network Rail

Mrs PM Fabb Mr Thomas Carlisle R Navon

Mr John Sweeney Mr Arthur Pott

In addition to those letters that were sent by post (listed above) more than 500 notifications were

sent by e-mail. The following is a list of them, excluding internal e-mails to Council staff. To protect

the personal data of these consultees, parts of their e-mail addresses have been redacted.

XXX@horneassociates.com;

XXX@phase2planning.co.uk;

jedplan@XXX;

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XXX@abbotslangley-pc.gov.uk;

watford.ama@XXX;

admin@beechfield.herts.sch.uk;

XXX@bellway.co.uk;

peter.stephens@XXX;

peter.young7@XXX;

office@cpreherts.org.uk;

info@croxleygreen-pc.gov.uk;

essemach@XXX ;

harveymotorcare@XXX;

XXX@herts.pnn.police.uk;

dmiddlebrook@XXX;

roundaboutherts@XXX;

XXX@taylorwimpey.com;

jarmanm@XXX;

XXX@montagu-evans.co.uk;

n.garibaldi@XXX;

london@nlpplanning.com;

admin@oxhey.herts.sch.uk;

XXX@watfordfc.com;

XXX@welcomepromotions.co.uk;

XXX@whht.nhs.uk;

reidmary@XXX;

XXX@woodlandtrust.org.uk;

XXX@nationalgrid.com;

davidvcrees@XXX;

corrinreeves@XXX;

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sophielinington@XXX;

steve.j.fulton@XXX;

franmclark@XXX;

XXX@hirus.co.uk;

XXX@inlandplc.com;

kevin.ocallaghanXX@XXX;

carolineharrisX@XXX;

beryl.burford@XXX;

sylviamoring@XXX;

robcramp@XXX;

tim.brooks@XXX;

XXX@watfordmencap.org.uk;

renato.messere@XXX;

XXX@ssaplanning.co.uk;

sercangXXX@XXX;

nigel@kavanagh-brown.co.uk;

alex.mcdougallXXX@XXX;

XXX@objective.com;

tomparker@XXX;

eastplanningpolicy@historicengland.org.uk;

jenny_thomas@XXX;

XXX@cgms.co.uk;

XXX@andrewcurrey.co.uk;

XXX@highwaysengland.co.uk;

mikehooles@XXX;

vipul.kothiyal@XXX;

graham.carterXXX@XXX;

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XXX@bell-cornwell.co.uk;

XXX@firstplan.co.uk;

planning@peacockandsmith.co.uk;

XXX@pioneerps.co.uk;

XXX@affinitysutton.com;

XXX.headoffice@ageukherts.org.uk;

robertmbolt@XXX;

office@bgbaptist.org.uk;

admin@bromet.herts.sch.uk;

XXX @bucksmeadow.co.uk;

XXX @fieldinfants.herts.sch.uk;

XXX@hertfordshirelep.co.uk;

planning@hmwt.org;

m25planning@highways.gsi.gov.uk;

info@indigoplanning.com;

XXX@intu.co.uk;

XXX@sportengland.org;

clerk@ststephenparishcouncil.gov.uk;

XXX@sustrans.org.uk;

XXX@environment-agency.gov.uk;

info@waterwise.org.uk;

admin@knutsford.herts.sch.uk;

XXX@londonconcrete.com;

planning@lgtu.org.uk;

XXX@hertfordshire.gov.uk;

info@westwatford.org.uk;

office@woolfbond.co.uk;

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dutytocooperate@orr.gsi.gov.uk;

XXX@highways.gsi.gov.uk;

XXX@chaseportland.com;

sara_cook7@XXX;

alison.crofton@XXX;

gregor.mitchell@XXX;

roy.marshallX@XXX;

XXX@montagu-evans.co.uk;

mayor@london.gov.uk;

XXX@hertfordshire.gov.uk;

simon.milliken@XXX;

b.foxXX@XXX;

anne.rindl@XXX;

smbconsentsenvironme@tfl.gov.uk;

XXX@pendimo.co.uk;

john.blundell@XXX;

bigboymick@XXX;

colin.barry@XXX;

rupert.thacker@XXX;

dglgplan@XXX;

XXX@watfordutc.org;

watfordjack@XXX;

XXX@stivala.co.uk;

XXX@historicengland.org.uk;

phil.moss@XXX;

XXX@londonmidland.com;

XXX@watfordtcc.org;

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XXX@stjames.co.uk;

vankeena@XXX;

frankershaw@XXX;

peter.prosser@XXX;

emf.enquiries@ctil.co.uk;

kjpj@XXX;

XXX@nlpplanning.com;

XXX@framptons-planning.com;

liz.mayhew@XXX;

XXX@geraldeve.com;

XXX@highwaysengland.co.uk;

XXX@struttandparker.com;

tdawork@XXX;

XXX@firstplan.co.uk;

vwalsh@XXX;

XXX@indigoplanning.com;

oyeats@XXX;

XXX@bartonwillmore.co.uk;

XXX@consensusplanning.co.uk;

XX@daltonwd.co.uk;

XXX@rpsgroup.com;

admin@garstonmanor.herts.sch.uk;

XXX@glhearn.com;

gslane@XXX;

malcolm.dall@XXX;

XXX@johnlewis.co.uk;

enquiries@architectscorporation.co.uk;

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XXX@coal.gov.uk;

XXX@threerivers.gov.uk;

admin@leavesden.herts.sch.uk;

london@localdialogue.com;

XXX@hertfordshire.nhs.uk;

XXX@orchard.herts.sch.uk;

XXX@peacehospicecare.org.uk;

XXX@peacockandsmith.co.uk;

darolfe@XXX;

smithst.watford@XXX;

enquiries@wcht.org.uk;

admin@mcccwatford.co.uk;

jwba68@XXX;

XXX@watfordwomenscentre.org.uk;

yasmin@XXX;

XXX@cbre.com;

XXX@collinslaw.co.uk;

richard.harrington.mp@parliament.uk;

XXX@jdi-solutions.co.uk;

XXX@aphsherts.co.uk;

maz.e.lopez@XXX;

russells.export@XXX;

XXX@brasierfreeth.com;

audreypeattie@XXX;

XXX@persimmonhomes.com;

peterjeffree@XXX;

rowland.marshall@XXX;

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john.castleX@XXX;

XXX@warnerbros.com;

info@rienijoarchitecture.com;

bmwilcox9@XXX;

johnsonsXXX@XXX;

jennietXX@XXX;

XXX@nicols.co.uk;

joanna.chambersX@XXX;

XXX@lemariecentre.co.uk;

gordonboogordon@XXX;

philip_chown@XXX;

XXX@indigoplanning.com;

sandraXX@XXX;

XXX@peterbrett.com;

XXX@cushwake.com;

intyk@XXX;

XXX@quod.com;

pbak@XXX;

XXX@cityoflondon.gov.uk;

jjmalcolm@XXX;

vickimillward@XXX;

XXX@wakelin.co.uk;

XXX@accenture.com;

XXX@glhearn.com;

XXX@nlpplanning.com;

XXX @wakelin.co.uk;

XXX @affinitywater.co.uk;

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XXX @bidwells.co.uk;

colettebickham34@XXX ;

XXX @watford.camra.org.uk;

admin@cherrytree.herts.sch.uk;

ianfvturner@XXX;

nigelagar452@XXX;

XXX@hertfordshire.gov.uk;

XXX @hca.gsi.gov.uk;

info@jtp.co.uk;

admin@stanthonys.herts.sch.uk;

admin@stmichaels.herts.sch.uk;

XXX @taylorwimpey.com;

vicaragevillage@XXX;

XXX @hertsvalleysccg.nhs.uk;

XXX@mywatford.net;

.XXX@mineralproducts.org;

shopmobilitywatford@XXX;

brunijh@XXX;

admin@wenta.co.uk;

admin@westfield.herts.sch.uk;

XXX@soulsurvivorwatford.co.uk;

XXX@herts.pnn.police.uk;

XXX@cbre.com;

XXX@struttandparker.com;

XXX@argroup.co.uk;

martin.searle@XXX;

r.XXX@ucl.ac.uk;

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info@arcusconsulting.co.uk;

XXX@warnerbros.com;

mwood@XXX;

cllrbrandon@XXX;

kimscreationsuk@XXX;

caspanner@XXX;

XXX@vincent-gorbing.co.uk;

richard_kavan@XXX;

hisgloryandpraise@XXX;

zoe_mowbray@XXX;

thisismartinhere@XXX;

XXX@tfl.gov.uk;

XXX@weston-homes.com;

XXX@abbotslangley-pc.gov.uk;

dptmbr@XXX;

mail@robinbretherick.co.uk;

consultations@stratus- XXX.co.uk;

XXX@framptons-planning.com;

XXX@indigoplanning.com;

keneal.patel@XXX;

XXX@londonmidland.com;

XXX@warnerbros.com;

judithmoores@XXX;

ann_winkie@XXX;

naughtytadpole@XXX;

prowlandXX@XXX;

brennan_XX@XXX;

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XXX@tymconsult.com;

XXX@rpsgroup.com;

XXXstewartmaps.co.uk;

XXX@bartonwillmore.co.uk;

XXX@camra.org.uk;

XXX@canalrivertrust.org.uk;

XXXcra-sec@cassiobury.org.uk;

admin@chessbrook.herts.sch.uk;

XXX@collierscre.com;

XXX@decathlon.com;

admin@fieldjm.herts.sch.uk;

info@franciscombeacademy.org.uk;

eileen-cox@XXX;

XXX@hertfordshire.gov.uk;

XXX@hpcha.org.uk;

stephenrmooreX@XXX;

office@stmaryswatford.org.uk;

planning@theatrestrust.org.uk;

postbox@coresq.com;

kpambrose@XXX;

admin@nascotwoodinfants.herts.sch.uk;

andrew_filer@XXX;

admin@parkgateinfants.herts.sch.uk;

admin@parkgatejm.herts.sch.uk;

enquiries@shire-uk.com;

XXX@whht.nhs.uk;

office@watfordboys.herts.sch.uk;

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admin@watfordgirls.herts.sch.uk;

sach.seyan@XXX;

XXX@watfordrpc.co.uk;

XXX@westfieldshomes.co.uk;

XXX@turley.co.uk;

anita.parry@XXX;

dglgplanning@XXX;

neil.bearspice@XXX;

XXX@brasierfreeth.com;

XXX@arriva-shires.com;

XXX@optimis-consulting.co.uk;

XXXn@glhearn.com;

dio-XXX@mod.uk;

XXX@torltd.co.uk;

distanXX@XXX;

trevor.mason@XXX;

kpsliu@XXX;

jaford@XXX;

XXX@iceniprojects.com;

emma.cornberg@XXX;

alan.luto4@XXXX;

XXX @cgms.co.uk;

m.meerabux@XXX;

XXX @stephengeorge.co.uk;

avi@XXX;

XXX@peterbrett.com;

XXX@networkrail.co.uk;

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richardah@XXX;

peak_j@XXX;

johnmarg@XXX;

corsetis@XXX;

paul.donovan@XXX;

XXX@montagu-evans.co.uk;

XXX@savills.com;

XXX@blackfriars-uk.com;

XXX@bre.co.uk;

contact@carersinherts.org.uk;

admin@chaterinfants.herts.sch.uk;

XXX@watfordcab.cabnet.org.uk;

johnfredperry@XXX.com;

pgough@XXX.com;

patrick.mcloughlin@XXX;

admin@dlatownplan.com;

XXX@firstplan.co.uk;

XXX@gvagrimley.co.uk;

XXX@hansoncatering.co.uk;

XXX@heatonplanning.co.uk;

admin@holywell.herts.sch.uk;

pamhornswatford@XXX.com;

kervinafw@XXX.com;

admin@kingsway.herts.sch.uk;

jcaldis@XXX.com;

XXX.XXX@stalbans.gov.uk;

XXX@crystalstream.co.uk;

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XXX.XXX@theplanningbureau.ltd.uk;

kjemmons23@XXX.XXX;

ros.womack@XXX.com;

admin@nascotwoodjm.herts.sch.uk;

XXX.XXX@uk.ngrid.com;

XXX.XXX@networkrail.co.uk;

XXX@raineco.co.uk;

XXX@watford-chamber.co.uk;

XXX@watfordrfc.co.uk;

XXX@dollshouseonthehill.co.uk;

XXX.XXX@cbre.com;

XXX@kenhaslar.co.uk;

XXX @amec.com;

XXX @woolfbond.co.uk;

XXX @tfl.gov.uk;

andy.instone@ XXX;

XXX @dlpconsultants.co.uk;

XXX @tfl.gov.uk;

XXX @londonmidland.com;

XXX @naturalengland.org.uk;

tim.bracey@ XXX.com;

markreynolds262@ XXX.com;

john.britten@ XXX.com;

eoc@ XXX.com;

XXX @munden.co.uk;

stephanie.beardsworth@ XXX.com;

paultuffin@ XXX.com;

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XXX @dbschenker.com;

XXX @tfl.gov.uk;

hilary@rundell1. XXX ;

petra_klemm@ XXX;

davefish@ XXX.com;

stevecane65@ XXX.com;

bisherltd@ XXX.com;

XXX @wdsauk.co.uk;

XXX @tfl.gov.uk;

XXX @heronslea.net;

deniserees1@ XXX ;

mj2206@ XXX ;

marekbanasiak@ XXX ;

roundjanet@ XXX.co.uk;

tim.ludmila@ XXX.co.uk;

XXX @powerhausconsultancy.co.uk;

jane.evans@ XXX.co.uk;

XXX @alliance-plan.co.uk;

tina.batten@ XXX;

XXX @homecall.co.uk;

laura.wood@dacorum. XXX.uk;

XXX @herts.pnn.police.uk;

XXX @firstplan.co.uk;

XXX @montagu-evans.co.uk;

XXX @nlpplanning.com;

XXX @nlpplanning.com;

XXX @rapleys.co.uk;

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XXX @aldenham-pc.gov.uk;

bihca_herts@ XXX ;

XXX @cassioburyjm.herts.sch.uk;

XXX @central.herts.sch.uk;

XXX @chaterjm.herts.sch.uk;

XXX @chemistree.co.uk;

XXX @christhomasltd.co.uk;

XXX @ames-associates.co.uk;

XXX @environment-agency.gov.uk;

martin.hicks@ XXX. XXX.uk;

logan_rasiah@ XXX.com;

XXX @kingswood.herts.sch.uk;

sdavis@ XXX.co.uk;

XXX @monoconsultants.com;

XXX @naturalengland.org.uk;

XXX @naturalengland.org.uk;

gill1311@ XXX.co.uk;

XXX @intu.co.uk;

mdodds@ XXX.co.uk;

XXX @cbre.com;

XXX @stjames.co.uk;

XXX @bidwells.co.uk;

XXX @rg-p.co.uk;

XXX @argroup.co.uk;

XXX @tjxeurope.com;

michael.kirkwells@ XXX.com;

helenwright42@ XXX.com;

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XXX @londonmidland.com;

angela_duce@ XXX.co.uk;

jodal666@ XXX.com;

john.short07@ XXX.com;

nix_collins@ XXX.com;

speer304@ XXX.com;

lisa.cathro@ XXX. XXX.uk;

XXX @odysseymarkides.com;

owen_frith@ XXX.com;

adriana.pomella@ XXX.com;

XXX @rspb.org.uk;

XXX @nationalgrid.com;

annamaria.izzard@londonmidland.com;

XXX @busheyhallgarage.co.uk;

XXX @stwilliam.co.uk;

kevinsomerville@ XXX.com;

ted.maddex@ XXX.gov.uk;

beanbelinda@ XXX.com;

railwayterrace.association@ XXX.com;

dhordle@ XXX.com;

ianwilliams44@ XXX.co.uk;

kerrimc34@ XXX.com;

lizromek@ XXX.com;

michelle. XXX @networkrail.co.uk;

abraham. XXX @ingletonwood.co.uk;

tomotooleXX XXX.com;

XXX @foddyconsult.co.uk;

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stellaburns@ XXX.com;

jon. XXX @jdi-solutions.co.uk;

sacha. XXX - XXX @bnpparibas.com;

will. XXX @montagu-evans.co.uk;

XXX.thomas@theplanningbureau.ltd.uk;

XXX @albanwood.herts.sch.uk;

neil.levy@ XXX.gov.uk;

XXX @camra.org.uk;

chris. XXX @cgms.co.uk;

XXX @coatesway.herts.sch.uk;

daren.nathan@ XXX.co.uk;

david. XXX @ews-railway.co.uk;

bgkemp@ XXX.com;

brian.chisholm@ XXX.com;

graham.everett@ XXX.net;

mikemusk@ XXX.net;

XXX @goughcommercial.co.uk;

development. XXX @hertfordshire.gov.uk;

admin@holyrood.herts.sch.uk;

james. XXX @struttandparker.com;

jon. XXX @struttandparker.com;

matthew. XXX @valad.co.uk;

townplanningpolicy@thameswater.co.uk;

bharat. XXX @hertfordshire.nhs.uk;

ac.comserve@ XXX.com;

jaffer.bhimji1@ XXX.com;

XXX @lhaines.herts.sch.uk;

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XXX @marks-and-spencer.com;

admin@oxheyearlyyearscentre.herts.sch.uk;

ben. XXX @planware.co.uk;

XXX @rapleys.co.uk;

michael. XXX @rumballsedgwick.co.uk;

mheasman@ XXX.org;

s. XXX @welhat.gov.uk;

XXX@watfordbid.co.uk;

XXX@cbre.com;

XXX@naturalengland.org.uk;

n.grid@amecfw.com;

XX@stwilliam.co.uk;

public.affairs@ee.co.uk;

XXX@hertsmere.gov.uk;

peter.shipp@XXX;

sliceforms@XXX;

edward.seamanXX@XXX;

rhodespropertycompanyXXX@XXX;

leolikaho@XXX;

thurlowbuckley@XXX;

simon.fowle@XXX;

tonymanfredini@XXX;

XXX@montagu-evans.co.uk;

XXX@hertfordshire. XXX.uk;

noelcooperX@XXX;

XXX@changingcities.co.uk;

d.brackfield@XXX;

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XXX@dwdllp.com;

roccilife@XXX;

j_stockford@XXX;

XXX@douglasbrodie.co.uk;

mj.lawson@XXX;

richardreubin@XXX;

XXX@codaplanning.co.uk;

planning. XXX @3valleys.co.uk;

XXX@tfl.gov.uk;

pinkyslatter@XXX;

bendiroj@XXX;

fulneyajr@XXX;

aagie@XXX;

XXX@hertsvalleysccg.nhs.uk;

tdatwork@XXX

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Appendix B: Summary of issues raised by the consultation and how they are to be addressed

A draft version of the Watford Junction Development Brief supplementary planning document (SPD) was produced for Watford Borough Council in August

2016. This was published on the Council’s website and a public consultation on it was carried out for a six week period between Thursday 18th August 2016

and Monday 3rd October 2016.

56 representations were received.

The following table sets out a summary of the comments that were received, together with the Council’s response.

Points Raised Respondent Watford Council’s Response

Tall buildings / density / over-development

Several respondents raised concerns about high rise buildings. Some felt that the proposed heights are excessive and out of keeping with Watford’s established character, where low-rise houses with individual gardens would be more appropriate. A resident of the Nascot Conservation Area is unhappy that a “Milton Keynes arrangement” would be located next to the conservation area. Another writes disapprovingly about the “Manhattanisation” of Watford.

One respondent felt that the site is not suited for residential use at all, but should instead be redeveloped for retail, car parks and offices.

Another feels that uncontrolled immigration has caused the housing crisis, and that the solution should be tighter controls rather than erecting tall blocks of flats.

On the other hand, TJX Europe wrote that they understand the need for dense development including some tall buildings to meet the demand for new housing in a confined borough, and that they support the principle of clustering the tallest buildings around the station, then stepping them

Anselmo 2929 Harkin 3007 LaSalle Nixon 2939 Patel 2952 Simpson 2858 TJX Europe 2790

The need for new homes in Watford is acute. The Watford Local Plan Part 1, adopted in 2013, identified a need for 260 new homes per year. Subsequently in 2016 an objective SHMA study doubled that to 577 homes per year. Recently the government have consulted on a new standardised methodology, the result of which will be to increase Watford’s housing need further. Local Planning Authorities are obliged to plan to meet the objectively assessed housing need in their area. Watford is a tightly constrained borough without fields to build on, and therefore the dense redevelopment of under-used urban sites such as the masterplan site is the only way to solve the problem. Unable to build outwards, Watford can only meet its housing needs by building densely. While buildings over 10 storeys tall would be out of place in many parts of the borough, the Watford Junction Special Policy Area has been identified as one area in which tall buildings would be acceptable, given its location adjacent to the mainline station and close to the

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down to reduce their impacts on surrounding areas.

Comments:

Overshadowing and wind problems could arise around the tall buildings,

The tall buildings would be too close together

Amenity areas would not be large enough to be useable. It would be better to have just one or two medium sized pocket parks rather than several smaller open spaces.

Tall buildings are ugly and the area will become a “ghetto”.

Tall buildings are unnecessary in this area.

The train services are over-crowded, and more residents would make this worse.

A local resident suggests that buildings near the station should be taller, with more flats in them, because he considers that this will mitigate an existing problem of inadequate on-street parking space for residents in North Watford.

An objector notes that the tallest buildings will be set back from boundaries, but fears that this will not be enough to mitigate their impact on surrounding areas. They could still be unsightly.

LaSalle Investment Management manage the freehold of the land on either side of Clive Way, and they support the draft masterplan, agreeing that this is a good sustainable place for a high density residential-led regeneration project.

Clarendon Road office employment area and Watford Town Centre.

The masterplan does not propose specific designs, as those are to be decided upon at a later stage. Tall buildings are not necessarily ugly – it depends upon their design. Policy UD1 of the Watford Local Plan Part 1 states that a high quality of design is expected of any proposed development in Watford; and more detail is given in the Skyline: Watford’s Approach To Taller Buildings Supplementary Planning Document. Any planning application on the site will be assessed in accordance with the principles that are set out in that policy and in that SPD.

The Council adopted The Skyline Supplementary Planning Document in 2016, setting out the principles of good design that any applications for tall buildings should be assessed against. These include issues such as wind and overshadowing that some objectors have raised.

Housing (supportive comments)

There is a need for affordable housing

Provision of homes, services and shops is supported.

Pleased to see that appropriate community facilities (e.g. schools, open space) are proposed to support the large amount of housing. This will deliver a mixed use neighbourhood.

Nixon 2939 The purpose of the masterplan is to provide more detail in support of Policy SPA2 of the Watford Local Plan Part 1. That policy has already been adopted in 2013, having been found “sound” by an independent Planning Inspector at an Examination in Public. Policy SPA2 has already established that this site should be redeveloped as a high density mixed-

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use neighbourhood, with its main emphasis being on housing. Policy SPA2 envisaged 1,500 homes on the Watford Junction site; but subsequent calculations of housing need have significantly increased the need for new housing across the borough, and the Council must take those changes into account – hence the figure of 2,777 new homes that is mentioned in the draft masterplan.

The masterplan aims to provide open space and amenity areas for residents, and to open the site for the general public to pass through to access the station. 3D modelling has been undertaken to ensure that any adverse impacts are mitigated and that the density and heights are appropriate for the landscape.

The reason why Watford Council needs to plan for thousands of new homes has nothing to do with the European Union – it is simply because there are many people who need homes in Watford, and not enough homes for them. Repurposing empty buildings is already supported, and the law has been changed in recent years so that in some cases it does not require planning permission to change their use; but this alone will not be sufficient to solve Watford’s housing crisis. The fact that it takes time to plan and erect new residential buildings is not a reason for not building any.

Housing (critical comments)

Flats are unnecessary for the area. Smaller developments would be preferable: such as retail car parks and good office space.

The plot ratio approach to setting density is antiquated. This is a highly sustainable site that calls for a high density approach, which should be design-led, rather than constrained by plot ratios.

Small individual properties should be proposed, such as houses with gardens, rather than flats. This would be more in keeping with the local area.

Number of homes should be reduced

Negative landscape impacts as a result of buildings over 4 stories.

Plans are massive over development which will impact on the town's character.

Concern over anti-social behavior from high rise developments.

First time buyers do not want to buy flats in tall buildings. These will be owned by greedy landlords charging high rents.

It will take years to complete this project, and meanwhile nothing will have been done to solve the housing crisis. Instead of pursuing this masterplan, the law should be changed to encourage refurbishment and conversion of existing empty or neglected buildings. We do not have to do what the European Union dictates anymore.

Affordable housing

A planning consultant representing Hille Holdings writes that they support the masterplan’s aspiration for development on their site, but they feel that it might not be viable to redevelop with the required 35% affordable housing provision. They note that the viability appraisal that was produced to accompany the draft masterplan concluded that it would be difficult for developers to provide all of the infrastructure that the masterplan envisages, plus 35% affordable housing, and still have a viable

Hille Holdings 2978

Policy HS3 of the Watford Local Plan Part 1 (adopted in 2013) requires that major residential developments in Watford should provide at least 35% of their homes as “affordable” units. This is a borough-wide policy that applies except in “exceptional circumstances” such as in cases where it is proved that the development would not be viable; but the onus is on the developer in such cases to prove that on a case by case basis. Unlike most parts of the borough, this

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scheme. They consider that a figure of 20% affordable housing should be the target rather than 35%. Alternatively external funding could be sought for the infrastructure.

Special Policy Area is exempt from having to pay the Community Infrastructure Levy (CIL) in recognition of the fact that development costs could be higher than normal here; so account has already been taken of the pressures on the profitability of developing this land.

Car Parking / road traffic / streets Some respondents felt that too many car parking spaces are proposed. This will attract more cars to the area, increasing congestion (which is already a problem) and air pollution. Instead the brief should be promoting environmentally sustainable transport such as cycles and public transport. One respondent took a contrary view, writing that the number of residents’ parking spaces proposed is inadequate, given that these days each household has one or two cars. She also commented that new developments these days tend to have narrow streets, making it difficult to drive past parked cars, and she hopes that the streets will be wide enough to avoid that problem in this case. If insufficient parking is provided on the site for residents, they are likely to park on nearby streets, exacerbating existing problems of parking congestion there.

Brading 2920 Curran 2882 Harkin 3007 Parsons 2963 Patel 2952 Green Party 3003

Watford Borough Council acknowledge the concerns that have been raised by this consultation about the harm that could be caused to congestion on the road network and to air quality if many of the new homes were to be provided with parking spaces for private cars. Environmental considerations aside, it would be unworkable for each of the 2,777 homes to have its own private parking space, as the site would be filled with parked cars, with little space left for the homes and open spaces. We now consider that the draft masterplan should be amended to make this a car-light scheme, so that the impact of the new homes on the town’s road network will be minimal. The masterplan also includes proposals for two new multistorey car parks for the station, one on either side of the Abbey Line, to compensate for the loss of the station’s existing surface level car park. The movement hierarchy plan in 2.7 uses red lines to show how those would be accessed: one from St Albans Road via Penn Road, the other from Colonial Way. This will solve the existing problem of traffic coming from the M1 having to loop around the town centre via the Ring Road, then pass south down St Albans Road or Clarendon Road to access the station’s car park. The developments that will make up this masterplan will each require planning permission. Watford Borough Council are the Local Planning Authority, and we routinely consult

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Hertfordshire County Council (the Highway Authority) on planning applications to ensure that any new streets or highways will be acceptable to them. Residents of the new homes would be unable legally to park on local streets that are covered by Controlled Parking Zones, where only permit holders may park. Nascot is already covered by a CPZ, and the streets to the north of the site could have a CPZ introduced if residents wanted one. Consultations there in the past have established that the idea was unpopular, but if sentiment in North Watford were to change another consultation could be held, and the developers would be expected to meet the costs of this, and of introducing a CPZ.

Rail aggregates depot / concrete batching plant / rail freight facility This is a valuable rail freight facility, which should be safeguarded because of its connection to the West Coast Mainline. Replacing it would cost £7m. It should not be developed for housing. Failing that, a replacement facility should be built within 5 miles.

The draft masterplan is flawed as it does not show or make any reference to the retained and safeguarded rail and aggregates depot and associated facilities, and it does not safeguard those uses. This is an operational facility.

It is not appropriate to introduce noise-sensitive uses (such as residential) in the adjoining area because those could prejudice the future operation of the safeguarded area. Adjoining land uses are currently employment uses - objections have previously been maintained to the inclusion of those employment areas within the SPA2 area for just this reason.

The site operator has made it clear that it is unlikely that an alternative suitable site will be available. It should be clear that the likelihood is that the facility will remain on site and will need to be fully safeguarded. This

Deutchebahn: Bryett 914 Herts County Council’s Waste & Minerals team 3 London Concrete Ltd & Aggregate Industries 2414

Apart from the relocation of the concrete batching plant, the masterplan does not propose any reduction in Watford Junction’s rail facilities. Any development on Network Rail’s land could only go ahead with the co-operation of Network Rail. The draft masterplan assumes that the facility would be relocated elsewhere. This is the most desirable outcome because the concrete batching plant gives rise to a certain amount of noise which, while not particularly loud, is constant and could cause a nuisance to residents, and because it is tall and unsightly, and because it occupies a large portion of the land where new buildings are envisaged. However, in view of the fact that it is safeguarded and could only be relocated if a suitable railhead were to be found for it elsewhere, Watford Borough Council now consider that it would be prudent to have an alternative plan included in the masterplan in case it proved impossible to relocate the facility. This alternative plan would require a different layout

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will require careful consideration to be given to the uses and design of development in the vicinity of the safeguarded site.

The draft brief’s introduction refers to the Watford Local Plan, but strictly speaking the Development Plan consists of that (which is produced by Watford Borough Council), plus the Hertfordshire Minerals Local Plan and the Hertfordshire Waste Local Plan, but no mention is made of those documents, which are produced by the County Council. These should have been mentioned, in accordance with paragraph 143 of the National Planning Policy Framework. The County Council’s Minerals Local Plan 2002-2016 (adopted 2007) is now being reviewed, but it contains Minerals Policy 10: Railheads and Wharfs, and its successor is likely to contain a similar policy.

That plan was supported by a Mineral Consultation Area supplementary planning document (adopted 2007) which shows this particular facility. Herts CC have safeguarded this facility as rail is a sustainable mode of transporting minerals over long distances, and as the concrete batching plant is an important local facility. It should be retained unless it can be relocated to a satisfactory location within the site or elsewhere.

Para 143 point 4 of the National Planning Policy Framework also states that existing concrete batching and aggregate transportation facilities at railheads should be safeguarded.

Furthermore, the draft masterplan is inconsistent with Watford Council’s own adopted Policy SPA2 which specifically states that: “The development scheme will be required to safeguard the existing Orphanage Way rail and aggregates depot and associated facilities, or re-provide a comparable facility on site which will also be subject to safeguarding, or ensure re-provision of a comparable facility within the local area… the redevelopment scheme shall be required to be sensitive to and respond to the operating parameters of the facility.” This wording was agreed by the Planning Inspector at the Examination in Public when the Watford Local Plan Part 1 was found “sound”. This is not fully reflected in the text of the draft masterplan in 3.4, where the only one of the three options

of building blocks to ensure that noise-sensitive uses (e.g. residential buildings) would be shielded by tall buildings that are not noise-sensitive (such as multi-storey car parks or air conditioned office buildings with windows fixed shut).

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mentioned is location in the local area – not retaining it nor relocating it within the site.

Because the draft masterplan is inconsistent with adopted Policy SPA2 and with the Hertfordshire Minerals Plan and with the NPPF, it cannot be regarded as a “sound” planning policy document.

London Concrete and Aggregate Industries write that they do not believe that there are any other suitable sites locally that their facility could be moved to, and they intend to resist any attempts to move them. They have successfully resisted similar attempts elsewhere through legal action, judicial review and resisting Compulsory Purchase Orders.

The draft masterplan identifies this facility as a “weakness” in the SWOT analysis in section 2.1, but actually it should be regarded as a strength because a supply of concrete is needed to support development. The SWOT analysis refers to a “lack of clarity” about the safeguarding of the site, but actually the position is very clear, and it is set out in Watford Council’s own adopted Policy SPA2.

The document should include a plan showing the boundary of the safeguarded concrete batching plant.

The draft masterplan does not go into detail about what would happen to the concrete batching facility, but it is clear from section 3.4 that the masterplan supposes that it would no longer be there. It should have given details about where it would be relocated to – which would have to be somewhere along the railway. This should be mentioned in 4.1. Herts CC are willing to work with Borough Council on this issue, but 3.4 should also mention the need to work with Network Rail on this.

Page 6, 1.1, Introduction, Planning Policy & Status: this section fails to refer to Minerals Local Plan, which forms part of the Development Plan.

Section 2.3 under title Land Use and Activity there should be mention of the three options in Policy SPA2 for the safeguarded facility: retaining it and protecting noise sensitive uses from it, or relocating on site, or relocating it locally as agreed with Herts CC and the operator.

2.4 Illustrative Masterplan should show the safeguarded batching plant.

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Same on p18, 2.5.

Noise sensitive uses (e.g. residential) should not be proposed near the concrete plant, such as in Station Quarter West or East, as they would jeopardise its operation.

Cycling

Cycle parking at the station should be improved.

Secure cycle parking should be provided for the new residents.

The masterplan should include safe through-routes for cyclists.

This site, being close to the station and the Town Centre, should be car-light, with an emphasis on walking, cycling and buses, rather than on car use. Too many car parking spaces are proposed.

Curran 2882 Reading 2920 Green Party 3003 Willis & Melia 2991 Anselmo 2929 Haywood

Cycling will play an integral part of the masterplan. Sustainable development is a core aim of the Council and it is important that the Watford Junction scheme looks comprehensively at the access and storage of cycling at the station. Since the draft masterplan was published for consultation in 2016 the Council has adopted a Supplementary Planning Document on the subject of cycle parking that is to be required in new developments across the whole borough, including on this site.

See above for our response on the suggestion that the number of parking spaces should be reduced.

Station capacity / improvements

When HS2 opens more fast trains will stop at Watford, and the Metropolitan Line Extension will also increase passenger numbers, in what is already a crowded station. Two members of the public objected to the draft Brief because they are concerned that developing around the station will hem it in with new buildings, whereas it needs to be expanded to increase its capacity, with additional platforms. A number of detailed suggestions are made for new or reinstated platforms, one of which would entail demolishing Iveco House.

More detail is needed on bus interchanges, dropping off points and how congestion of the forecourt would be solved.

The masterplan proposals need to consider improving station capacity as it is busier than ever and becoming congested. Additional platforms, capacity and lines are a necessity due to current and future capacity

Allen 2997 Burgess 2998 Arazi 2990 Anselmo 2929 Thompson 2909 Central Town Residents Assoc 2264 Forsyth 855 Harrington MP 1008 Nascot Residents Assoc 2424

Watford Council, Hertfordshire County Council and Network Rail all recognise that Watford Junction Station requires improvement, and they meet regularly to discuss this. Network rail have undertaken capacity studies and are aware of the draft masterplan and its potential to increase passenger numbers. Since the draft masterplan was published in 2016 a planning application (17/00790/GPDO18) has been approved by Watford Borough Council for a two storey front extension to the station building (occupying an underused service yard) which will create a new main entrance and ticket concourse, with escalators to the platforms, and some ancillary retail space. This will improve access to the station, relieve congestion, and cater for the needs of passengers. The draft masterplan shows a proposal for a broad open

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issues. Improved access between platforms is needed.

New housing will lead to greater impacts on train services; Watford Junction Station cannot accommodate extra passenger demand from this size of development.

More details are required about the station improvements including access from those approaching from the North, cover on all platforms, access between main line and platform 11, platforms 1-4. Taxi ranks should be addressed.

In recent years attempts were made to improve the functionality of the station’s forecourt, taxi and dropping off areas, and access to the station’s car park and dropping off area; but these changes have not solved the problems, and the issues should now be reconsidered, as is proposed by Objection 1 in section 2.2.

Network Rail write that, although they support the proposals in principle, if the Council use a Compulsory Purchase Order then NR may, as is their custom, object to it seeking a Deed of Undertaking whereby their objection would be withdrawn in return for the Council’s agreement to railway protections that they deem necessary.

Transport for London, being mindful of the proposed Metropolitan Line Extension which would connect with Watford Junction, write that they should be consulted on any reconfiguration of the station’s facilities.

TJX Europe wrote that they had been discussing their plans for a major new office development opposite the front of the station. They support the plans to improve the station as a major multi-modal transport interchange with adequate parking, as set out in Objective 1. Improving accessibility to the area by sustainable means will improve traffic flows, air quality, and the desirability of the area to businesses.

Warner Bros note the importance of the station and its forecourt for visitors to the Leavesden Studio Tour, and they would welcome improvements to these facilities that would improve the station’s quality, legibility and sense of arrival.

Network Rail 2832 Nixon 2939 Thompson 2909 TfL 2980 TJX Europe 2790 Warner Bros 2541 Wray 2848 758

landscaped pedestrian bridge over the Abbey Line to connect the two halves of the site. This idea is being revised for the final version of the masterplan so that the pedestrian bridge could serve a dual purpose: serving the needs of residents passing from one half of the site to the other, and also serving the station itself by providing direct access to platforms via ticket gates, lifts and stairs, and thus reducing congestion in the existing passenger tunnel that is the sole connection between the platforms at the moment.

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Abbey Line

A member of the public notes that the Abbey Line is a barrier bisecting the site; but he is worried by mention in the Brief of the idea of converting the Abbey Line to light rail. He considers that it should remain as heavy rail, since then it could be continued to connect with a proposed new freight facility at Radlett and elsewhere.

Suggestion: bury the Abbey Line in a shallow tunnel, so that it will no longer be a barrier bisecting the site; this would also facilitate a future connection to the London Overground tracks on the opposite side of the station in future, creating a single through route. However he notes that the tunnel would have to pass under Orphanage Road, which would be challenging.

Several people have written to say that they support the scheme, provided that the Abbey Line platform is brought closer to, and is accessible from, the rest of the station e.g. using Platform 10. It could be joined to the mainline London bound services back along its original alignment where heavy rail could aid regional growth.

Objections were raised to the idea of replacement of the existing service with a Bus Rapid Transit system or with Light Rail or tram services.

A passing loop is needed on the Abbey Line to increase frequency of trains. Also ticket machines are needed on all Abbey Line stations.

Passenger entrances need to be built on the north east side of the station so that Abbey Line passengers do not need to walk over the railway line and to the front of the station to gain access. Extra Lifts and stairs should be provided.

Allen 2997 Burgess 2998 Arazi 2990 Burke 3006 Davies 2994 Lavin 2995 Logan 2988 O’Connor 3004 Spicer 2999 Taylor 2996 Thompson 2909 Webb 2992 Winstone 3005

It is not within the remit of this masterplan to determine the future of the Abbey Line. However we must recognise that it acts as a constraint upon the regeneration of the site because it bisects it, forming a barrier that is difficult and expensive to cross. As a minimum a pedestrian bridge is required. The suggestion that it be buried in a tunnel would also be difficult and expensive. Comments are welcomed and will be discussed in ongoing meetings, especially in terms of the detail regarding stairs and lifts.

Link road from Penn Road to Colonial Way

Some respondents wrote that a road bridge should be constructed over the Abbey line, connecting Penn Road to Colonial Way as a relief road. Without such a link, anyone trying to access one of the two new multi-storey station carparks and finding it closed or full would have a long drive

Burke 3006 Foot 2874 Haywood

A road bridge to continue Penn Road over the Abbey Line, connecting St Albans Road with Colonial Way is an idea that has been considered, and it has been an aspiration of Hertfordshire County Council (the Local Highway Authority) for some years. However Watford Borough Council (the Local Planning Authority) considers that it would be difficult

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around town to get to the other one.

Another respondent writes that the movement hierarchy plan in section 2.7 shows that traffic will be accessing the site from Colonial Way / Imperial Way, and he worries about the impact that this could have on traffic flows on Radlett Road. He worries that heavy commercial traffic might use Colonial Way, where there is a school.

to achieve. One problem is that the concrete batching plant is currently blocking the way. Another problem is the height needed for the trains to pass beneath the bridge: the shallow gradient required for road safety would mean that bridge would need to have long approach ramps, making it expensive, obtrusive, and wasteful of space. The alternative of excavating and lowering the rail tracks would be extremely expensive and disruptive. If a road bridge were to be built, there is a risk that the link road would attract large volumes of traffic through the new residential neighbourhood that the masterplan is seeking to create, and also through Colonial Way, which is an industrial estate, not a main road, and Watford Borough Council are not convinced that this would be desirable. If the link road were restricted to certain types of traffic only, that would raise the question of whether an expensive road bridge was worth building. The masterplan requires that Penn Road will be retained, and that a new street will be created opposite it, so that there would be an opportunity to connect them in future if the Abbey Line were ever to be converted to a bus, guided-bus or tram service, since a surface crossing would then be possible. Watford Borough Council acknowledge the concerns that have been raised by this consultation about the harm that could be caused to congestion on the road network and to air quality if many of the new homes were to be provided with parking spaces for private cars. The Council are reviewing the number of car parking spaces provided within the scheme, based on experience of similar schemes and on take-up rates of car-share clubs, with a view to minimising the number of private cars associated with the new homes. The masterplan also includes two proposed new multistorey

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car parks for the railway station users, one on either side of the Abbey Line, to compensate for the loss of the station’s existing surface level car park. The movement hierarchy plan in 2.7 uses red lines to show how those would be accessed: one from St Albans Road via Penn Road, the other from Colonial Way. This will solve the existing problem of traffic coming from the M1 having to loop around the town centre via the Ring Road, then pass south down St Albans Road or Clarendon Road to access the station’s car park. On the point that was raised about commercial vehicles being unacceptable on Colonial Way where there is a school, it is worth bearing in mind that Colonial Way is a purpose-built industrial estate that is intended for commercial vehicles. The school is a recent addition there – it was converted from a former commercial building.

Metropolitan Line Extension / Croxley Rail Link A member of the public writes that the document fails to mention the proposed Metropolitan Line Extension (MLX previously called the Croxley Rail Link) in section 1.2. Transport for London note that the document mentions MLX, which will connect to the station, and they write that they should be consulted on any reconfiguration plans for the station.

T. Bracey 1038 TfL 565

MLX is mentioned in section 1.1 of the document. There is an identified shortfall in funding; but the regeneration of the Watford Junction area as a new neighbourhood would be sustainable even without the MLX because the existing station is well connected to London Euston by existing services (albeit the proposed additional connection to London Baker Street is desirable as it would bring additional benefits of connectivity).

Crime prevention Buildings overlooking the public realm should be designed with active edges to ensure natural surveillance. Buildings should have appropriate defensible space. CCTV should cover the public realm, including the proposed pedestrian bridge. Decked car parks should comply with the standards of the Safer Parking Award. Underground car parks should be accessed controlled.

Herts Constabulary 3148 Jermyn 3009

Designing out crime is an element of good design that will be assessed when planning applications are received. Herts Constabulary are routinely consulted on major planning applications to ensure that developments are designed with security in mind. The masterplan includes proposals for new infrastructure to support the new neighbourhood. There is no reason to suppose that antisocial behaviour will arise simply because

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Because there will be more people living here than Watford’s infrastructure was designed for, the result will be antisocial behaviour.

more people will be living here. Good design can discourage crime and antisocial behaviour.

Schools

Any new school on the site will need to incorporate a nursery class and pre-school provision on site to meet the additional demand for free early education and childcare in this area.

Until details of the phasing, house type and tenure are known, Herts County Council cannot calculate the yield and peak demand that will arise from the development to be able to confirm when the primary schools would need to be provided.

Greater clarity should be provided on the location and criteria of the school and consideration should be given to appropriateness of individual sites for school use.

The inclusion of two school sites is supported by Herts County Council.

The proposed site size of the primary schools is smaller than HCC would consider the minimum, and there is no off site detached playing field provision within 400 metres of either site.

A formula should be provided for calculating the contributions that will be required of developers towards the provision of schools.

A local resident wrote to support the proposal for a new primary school, but wondered whether secondary school places in the area are sufficient to cope with the extra demand.

HSBC Pensions write that they should not be expected to make any contributions towards the provision of schools because they would like to be the first to develop their land, and therefore the homes that they build will not include so many children as would justify the building of a new school. Instead, other developers who build in later phases should have to fund the building of new schools. Also because they consider that new homes in this area should be mainly for professional couples rather than for families.

Herts County Council HSBC Pensions 3033

At this stage the details of school places required are not finalised. It is clear that the level of development proposed will generate demand for school places. It would be an oversight not to plan the schools into the masterplan. Further details will be updated as and when they are available on the scheme. The Council do not accept the argument made by HSBC Pensions that they should be excused from having to make any contributions towards the provision of school places, and that other developers should have to pay for them instead at a later stage. Regardless of which land owner is the first to develop their land, the point of a masterplan is that these will not be isolated housing developments, but rather pieces of a whole new residential neighbourhood with thousands of new residents, including families with children.

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Doctors surgery

There is a need for a doctors’ surgery in the area.

Harkin 3007

The Council will work with the NHS Clinical Commissioning Group on appropriate provisions for medical facilities within the masterplan area.

The key to the plan in Section 2.5 is to be amended to include areas for new medical facilities.

Cultural and community facilities The scheme should include cultural and community buildings e.g. a museum, cinema, theatre and a park.

Anselmo 2929

The site is within easy walking or cycling distance of the Town Centre which already has a museum, two theatres (the Palace and the Colosseum) and the award-winning and very large Cassiobury Park. A new multiscreen cinema is currently under construction as part of the Intu Shopping Centre extension.

Retail and leisure

A resident of Nascot feels that the area does not need any more shops or restaurants. Those will be provided in the town centre instead where the INTU Shopping Centre is being extended.

A resident of the Reeds Estate is of the opposite opinion: she feels that the area would benefit from some convenience shops, which would be helpful not only to residents of the new development but also to existing residents of the Reeds Estate.

Nixon 2939 Rushton 2895

If several thousand new residents are to live on this site they will need easy access on foot to grocery and convenience shops. However the Council are mindful that any new retail units on this site should only amount to what is necessary to provide for the daily needs of new residents, and to cater for the needs of commuters at the station (who are currently poorly provided for) and that they should not be such as would dilute the attraction of the Town Centre as Watford’s main retail destination, or draw custom away from it.

Water supply and waste water Thames Water point out that the National Planning Policy Framework stresses the need to consider the impact that development would have on water and waste water infrastructure. They provide some text that they suggest should be included in the Brief, which states that developers should engage in discussions with Thames Water at an early stage to discuss their requirements.

Thames Water 2379

Section 4.1 of the draft masterplan states that an infrastructure delivery plan should be produced. Section 4.2 of the draft masterplan states that the Council will expect to see details of services and infrastructure accompanying planning applications. Thames Water are routinely consulted on major planning applications.

Sustainable design Green Party The Council is committed to ensuring sustainable

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Watford Green Party write that new buildings should be sustainable, including measures to reduce carbon emissions.

TJX Europe support Objective 6 as a high standard of design and environmental quality will help make this area a positive gateway to Watford as a whole. They support the principle that the tallest buildings should be located beside the station, stepping down as they get closer to the surrounding area to reduce their impacts on key views and vistas.

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development is integral to this regeneration masterplan. The Skyline supplementary planning document on tall buildings details minimum standards that are expected.

Historic Environment

Historic England are concerned that the draft masterplan does not mention the positive contribution that heritage assets make to the character of the area. A successful development should draw on the area’s history, such as through recognising distinctive historic street patterns, as well as by respecting historic buildings and conservation areas. The masterplan should map the locations of listed buildings on or near the site, including the former London Orphan Asylum at Reeds Crescent. The masterplan should reflect the information contained within the Watford Conservation Areas Management Plan 2013. The SWOT analysis should reflect the importance of conservation of historic features and buildings. The conservation of the Grade II Listed former station building should be an aim of the masterplan. An additional objective should be added: to draw on the contributions of the historic environment to produce a locally distinctive place.

The masterplan’s Area 21 is the part of the site that lies within the Nascot Conservation Area, but little information is given as to how it would be developed or what quantum of development would go there. It omitted from the four “quarters” that are described. This area would benefit from sensitive regeneration.

The masterplan should use Historic England’s guidance as a resource.

It should clarify that the site contains two designated heritage assets (the Grade II listed Old Station House and the Nascot Conservation Area) as well as being sited in close proximity to areas of the same Conservation

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There may be historic street patterns on surrounding areas, but there are none on the site itself. The only part of the site that falls within a Conservation Area is the relatively small triangular section to the west of St Albans Road, and the only Listed Building on the site is a small former station building on that same part of the site. Applications on that part of the site to the west of St Albans Road will be expected to treat that Listed Building sensitively, to protect it and to respect its setting; and similarly they will be expected to respect the character of Bedford Street, where the edge of the site will face Victorian terraced houses.

Otherwise there are no historic buildings or features on the site. The former London Orphan Asylum is a complex of listed buildings (now converted to flats) that is located nearby, but it is on higher ground, which will help to mitigate the impact of tall buildings on its setting.

The draft masterplan should be revised to make these issues more explicit. The locations of heritage assets on or adjacent to the site should be marked. The document should make it clear that any planning application for a development that has the potential to impact upon the setting of a heritage asset should be accompanied by a Heritage Statement.

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Area and other listed and locally listed buildings. All these features should be mapped.

Employment TJX Europe write that they support the principle of including new office space within the development to augment that which is provided nearby on Clarendon Road, where their own new headquarters are to be built. This will confirm the status of Clarendon Road and its environs as an important office employment area. They support the aim of a mixed use office and residential development as this will create a vibrant and successful area. Watford Chamber of Commerce are disappointed that the proposed development does not contain more commercial and office space, rather than being mainly residential-led. They feel that Watford needs more commercial space, particularly around the Clarendon Road area, to allow local firms to expand and to attract new businesses. Space uses need to be considered in the context of market demand, and the dispersal of commercial floor-space throughout each quarter of the masterplan may not be appropriate. There should be some flexibility on this.

TJX Europe 2790 Watford Chamber of Commerce 493

The masterplan already sets floorspace requirements of 73,920 sqm of employment which takes up 15% of the total area. The area is constrained and in order to deliver all the required uses on site the employment allocation is felt appropriate. Further work on the layout of uses will be undertaken.

Previous planning brief in 2004 Local residents were consulted on a previous brief in 2004, but that came to nothing, and so their time was wasted.

Forsyth 855 In March 2004 a Watford Junction Planning Brief was adopted by the Council as a supplementary planning document. The draft masterplan that we published for consultation in 2016 is intended to replace that adopted 2004 masterplan.

In 2008 a development consortium prepared an application for outline planning permission for a major development on the site. They discussed their plans with the Council, but the financial crash of that year and the ensuing changes to the housing and office markets meant that the application was never submitted.

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HSBC Pensions Trust’s land 1. HSBCP own the land occupied by TK Maxx, Staples and Range

stores and their car parks, which are trading well. They write that they have planning permission for 11,855 sq m of retail floor-space, of which 2,316 sq m is not yet built.

2. HSBC wish to increase the value of their land, but any residential-led redevelopment would have to be substantially in excess of the existing value, which is already substantial.

3. Paras 173 and 174 of the National Planning Policy Framework state that demands for contributions should not be so onerous as to make developments unviable.

4. “It is absolutely critical for the Council to recognise that there will need to be a strong commercial justification for the HSBP and other landowners to redevelop their sites; otherwise the masterplan will not be delivered.”

5. Meetings between the Council and agents of HSBC have taken place, but the aspirations of HSBC have not been reflected in the draft masterplan. The Council should therefore reconsider the masterplan, and produce a more realistic version that would generate a more profitable development opportunity for HSBCP, without burdening them with upfront costs for funding infrastructure. Significant public monies should be invested in the infrastructure, rather than requiring land owning developers to fund it.

6. HSBCP fundamentally disagree with the findings of the Viability Appraisal that was produced to accompany the draft masterplan, and therefore they doubt whether agreement between HSBCP and the Council will be possible. They disagree with the £3m per net hectare figure for the benchmark existing land value – they consider that the actual value should be 5 times that. They also consider that the Viability Appraisal underestimates build costs and pays too little attention to land remediation costs.

7. The brief should be amended throughout to reflect the fact that

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1. The planning permission that is referred to is 15/00051/FULM which was granted in March 2015, and which is valid until March 2018: for a double storey side extension to the existing Range retail unit (formerly Homebase). No work has yet commenced on the development, and the permission is now 5 months away from expiring.

2. It is understandable that land owners wish to increase the value of their land; but the Local Planning Authority’s duty is to plan for the future with the public interest in mind.

3. This is noted. It is worth bearing in mind that the Watford Junction Special Policy Area has been exempted from the Community Infrastructure Levy (CIL) Charging Schedule specifically so as to help to make redevelopment schemes there viable.

4. Watford Council hope that land owners will recognise the opportunities that this masterplan presents to redevelop their sites in profitable ways. In cases where uncooperative landowners are obstructing access to strategically important land the Council will consider using its powers to seek Compulsory Purchase Orders to unlock sites that are needed to meet the borough’s pressing housing and infrastructure needs.

5. The Council do not accept that land owners should be able to reap all the profits, and that others should be required to pay for the necessary infrastructure to support the new homes that they would be building. The principle that sustainable neighbourhoods require supporting infrastructure, and that developers should contribute to that, is a fundamental and long established principle of the

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development would be phased, with the HSBC site being one of the first.

8. A 20% affordable housing requirement would be more realistic than 35%. A claw back clause could be used in the section 106 agreement in case profits are higher than expected.

9. Penn Road belongs to HSBC as part of their site (HD152573). The masterplan assumes that it will be used to access other parts of the development area beyond, but HSBC will not agree to that unless they are satisfied that they will be allowed to develop their own site as they wish, and that the use of Penn Road by additional traffic will not harm their interests.

10. A plan on page 11 mentions a potential school site west of St Albans Rd. This is inconsistent with other parts of the masterplan that suggest there would be 2 primary schools: one on the HSBCP land and the other east of the Abbey Line.

11. The suggestion of creating a primary school on the HSBCP site with one form entry per 500 homes is too crude. It should depend on the tenure of those homes. Otherwise this would fail the test of what is a reasonable requirement to make of a developer through Section 106. Being a central urban area, developments here are likely to be largely private rented properties that will appeal to young professionals, not families with children. HSBCP acknowledge that there might be a need for a primary school for the development on someone else’s land, but not on theirs. They argue that their site is likely to be an early phase, and would not generate enough demand for a school – the need for which would arise later. Section 106 should not be used to cater for existing demand.

12. Section 3.2 sets a maximum density limit in terms of plot ratio of 2.5 Gross External Area to Site Area, but this is an antiquated means of assessing the acceptable scale and form of development. It is too prescriptive and would limit developers’ ability to make the best use of their land, which is a highly sustainable site that

British planning system. 6. The disagreement is noted. 7. The implication here seems to be that, because HSBC

would like to be the first landowners to build, they should not have to pay for any supporting infrastructure (eg schools, open space etc) and that other land owners should have to pay for those facilities instead at a later date. This follows their comments that they do not intend to co-operate with the Council and that they doubt whether any development will happen on their site unless the Council allow them to build whatever they like without having to make financial contributions to supporting infrastructure. The two comments seem to contradict each other.

8. There is an acute need for affordable housing in the borough. The Watford Local Plan Part 1 (adopted in 2013) contains Policy HS3 which requires provision of 35% affordable housing on major developments except in exceptional circumstances. In cases where exceptions to that policy are allowed because viability problems have been proven, a claw-back clause is usually applied.

9. See the response to point 4 above regarding Compulsory Purchase Orders. Penn Road is an important access to the masterplan area.

10. Further discussions will be undertaken with Hertfordshire County Council, who are the Local Education Authority, regarding the provision of school places on the site.

11. See the responses to points 7 and 10. The intention is that the masterplan will provide a mixture of sizes and tenures of homes, including two and three

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should be optimised. The PTAL rating of a site should have been used instead, to determine the level of density based on its proximity to public transport. Using the limit of 2.5 GEA / site area on the HSBCP site one would arrive at a limit of 246 dwellings per hectare, i.e. 622 units, but in view of the site’s high PTAL rating a density of 400-450 dwellings per hectare would be more appropriate. Instead of such a prescriptive approach to density, the Council should take a design-led view of what is acceptable on the site.

13. Page 44 is overly prescriptive as to how much commercial ground floor space should be provided. More flexibility should be allowed, given variations in market demand. Station Quarter West should be the area where commercial space is concentrated, not the HSBCP land.

14. Page 42’s proposals re parking space provision are 0.40-0.58 spaces per dwelling. Given how sustainable this site is, with a high PTAL score, this is an excessive amount of parking space. Instead use of public transport should be encouraged.

bedroom dwellings that would be suitable for families with children. There is a need for new family homes near the Town Centre.

12. The point is well made. The Council agrees that a prescriptive approach to density can be unhelpful. This will be reconsidered when the final version of the masterplan is produced. It is important that dwellings should be of a decent size, complying with the national internal space standards that the Council have adopted. These space standards, combined with a design-led assessment of the appearance of buildings and of their impacts on their surroundings, should be the main criteria by which density is assessed.

13. The masterplan is to be adopted as a Supplementary Planning Document. An SPD is a guidance document to aid in the interpretation of a policy (in this case adopted Policy SPA2) and they are not immutable. Commercial ground floor space is desirable in mixed use neighbourhoods because it provides active frontages onto the street, bringing vitality and deterring crime.

14. The point about parking space is well made. This will be reconsidered, with a view to making the new neighbourhoods car-light and sustainable.

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Appendix C: Front cover of the document that was consulted upon