london borough of sutton - local development framework ......direct telephone: 0207983 4804 fax: 020...
TRANSCRIPT
1 WATERHOUSE SQUARE, 138 – 142 HOLBORN, LONDON, EC1N 2ST
Telephone 020 7973 3000 Facsimile 020 7973 3001 www.english-heritage.org.uk
Please note that English Heritage operates an access to information policy. Correspondence or information which you send us may therefore become publicly available
Head of Strategic Planning London Borough of Sutton Strategic Planning Environment & Leisure 24 Denmark Road Carshalton SM5 2JG
Our ref: Your ref: Telephone Fax
020-7973-3771
19 March 2009 Dear Sir/Madam London Borough of Sutton - Local Development Framework: Hackbridge Master Plan Thank you for consulting English Heritage on the Draft Hackbridge Masterplan. As the government’s advisor on all matters relating to the historic environment and a statutory consultee in respect of the Strategic Environmental Assessment of plans, we are keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the Local Development Framework process. Our document Conservation Principles: Policy and Guidance (2008) provides the basis by which the following judgements and advice are made. It is consistent with Planning Policy Statement 1: Delivering Sustainable Development (2005), Planning Policy Guidance (PPG) 15: Planning and the Historic Environment (1994) and PPG 16 Planning and Archaeology (1990) and the explicit objective of ‘protecting and enhancing the natural and historic environment’. In general terms, English Heritage welcomes the Draft Masterplan as a considered approach to developing a sustainable community. English Heritage particularly supports the London Borough of Sutton’s preparation of a Tall Buildings Study and its application to the Masterplan, as indicated in paragraph 2.30 on page 22. This is exemplary practice in terms of English Heritage and CABE’s joint Guidance on Tall Buildings (July, 2007). English Heritage is of the view that the Masterplan contains some excellent recognition of the heritage values of Hackbridge, most notably in identifying the:
• archaeological priority area status of the five development sites within the Hackbridge Neighbourhood on pages 18 and 19;
• heritage features in Beddington Park in paragraph 3.27 on page 32;
1 WATERHOUSE SQUARE, 138 – 142 HOLBORN, LONDON, EC1N 2ST
Telephone 020 7973 3000 Facsimile 020 7973 3001 www.english-heritage.org.uk
Please note that English Heritage operates an access to information policy. Correspondence or information which you send us may therefore become publicly available
• heritage significance of the River Wandle on pages 32 and 33; and • value of heritage interpretation as part of regenerating a place on page 33.
English Heritage welcomes “Chapter 3: Understanding Hackbridge” as exemplary in principle. The coverage of the history of the borough in the opening paragraphs of this chapter is good. English Heritage would welcome recognition of the Grade II listed status of five places in Hackbridge – the Old Red Lion pub, Riverside (former Mill House in Middleton Road, the terrace of 9-15 Hackbridge Green, the terrace of 40, 44 and 48 Mill Green Road and the 19th century Mill buildings at 258 London Road. It should also be noted that there has been a Mesolithic and a Neolithic archaeological find in the Hackbridge area, the latter of which is now in the British Museum. Not only does this suggest the potential for pre-historic archaeological finds throughout the area but it presents a further interesting heritage dimension to the place. English Heritage notes that while various connections are made in the document to the area’s heritage, this is not then built upon to any great degree in the section on Culture and Heritage in Chapter 7 which concerns itself purely with community space rather than also developing a positive sense of continuity in Hackbridge. English Heritage would welcome reference to the proposed public art interpretations of the area’s heritage in this section, and some more consideration as to how the remaining heritage assets anchor and support the achievement of such a sense of continuity, particularly as educational resources. Finally, it must be noted that this advice is based on the information provided by you and for the avoidance of doubt does not reflect our obligation to advise you on, and potentially object to any specific development proposal which may subsequently arise from this or later versions of the Masterplan, and which may, have adverse effects on the historic environment. Yours sincerely
Claire Craig Regional Planning Adviser (London) E-mail: [email protected]
GREATER LONDON AUTHOR ITY
Development & Environment Directorate
Paul McAleerSutton Council
Strategic PlanningEnvironment and Leisure Group24 Denmark Road
CarshaltonSurrey SM5 2JG
City Hall
The Queen's Walk
More London
London SEl 2AA
Switchboard: 0207983 4000Minicom: 0207983 4458Web: ww.london.gov.ukOur ref: PDU/ LDF29/LDD05
Your ref:Date: ~? Iï ~lM:i ':009.i. ... Hti1f': I'
Dear Paul McAleer,
Planning and Compulsory Purchase Act 2004;Greater London Authority Act 1999
Sutton Council Supplementary Planning Document: Hackbridge SustainableSuburb Final Draft Masterplan
Thank you for consulting the Mayor of London on the above draft supplementary planningdocument. The Mayor has afforded me delegated authority to make comments on his behalf ondraft supplementary planning documents. The GLA welcomes the opportunity to consider thedocument at this draft stage. These comments are officer-level only and do not preclude anyfurther comment the Mayor may make on future consultation phases of the Councils LDF.
Overall there is much to support in the consultation document from a strategic planning perspective,including the Council's aspirations to reduce the local need to travel by providing for local services,retail and community facilities in the town centre, as well as for the variety of housing sizes to beprovided. The ambitions to improve the public realm along London Road, enhance the River WandleCorridor and to achieve all this in the context of 'one-planet living' principles are all welcomed.
Although the principles noted above are broadly consistent with the London Plan, the Mayor'sresponse to the Councils pre-submission draft of the Core Strategy emphasised the need for furtherevidence and justification for proposals to release industrial land within the Hackbridge area and toremove the 'Metropolitan Open Land' and 'Site of Metropolitan Importance for Nature Conservation'designations for the land north of BedZED to allow redevelopment for mixed uses. This Masterplandoes not provide any further justification to address these concerns, and as such there is a likelihoodthat the Masterplan and forthcoming SPD would be found to be not in general conformity with theLondon Plan.
Direct telephone: 0207983 4804 Fax: 020 7983 4706 Email: alexandra.reitman0!london.gov.uk
Loss of MOL
1. This Masterplan suggests that the development of the a parcel of MOL north of BedZED formixed uses including residential and community facilities is essential to achieving the aspirationto regenerate Hackbridge into a 'sustainable suburb: The Masterplan states that developingthe land north of BedZED will allow for a more balanced spatial layout of the suburb and theintroduction of a 'northern gateway' along London Road to the town centre. The plan calls forthe provision of a new primary school and a mix of medium density housing development withan emphasis on larger family homes, some open space and a network of streets including asignalized junction at London Road. The Masterplan also suggests that the development ofthis land will alleviate the problems suffered by London Road such as its lack of distinctcharacter and identity and the high-speed traffc along the road.
2. As set out in the Mayor's consultation response to the proposed submission of the Council's
Core Planning Strategy, the London Plan requires all development to be sustainable, andtherefore the aspirations for Hackbridge are not considered to be exceptional circumstance thatmight justify the loss of the MOL. The Council suggests that the new neighbourhood will beexemplar in terms of sustainable design and construction (including the creation of a 'Iowcarbon zone'), however no evidence has been provided to demonstrate how the release of MOLwill facilitate this objective, or whether the release of MOL is absolutely essential to achievingthis objective. The planning brief for the site included in the draft Masterplan suggests thatdevelopment may 'consider the opportunity to link energy and heat provision with BedZED,'but no other discussion of the relevance,of this site to the delivery of the sustainable suburbobjectives is presented at this stage. In terms of improving London Road, the interventionsproposed in the overall public realm strategy in section 5.3 do not appear to require thedevelopment of the MOL land. Alternative strategies to developing the land north of BedZEDshould be pursued.
BiodiveislIJ
3. London Plan Policy 3D.14 Biodiversity and nature conservation identifies Sites of MetropolitanImportance for Nature Conservation (SMls), which is land of strategic importance for natureconservation and biodiversity across London. The policy requires boroughs to give strongprotection to these sites in their DPDs and to resist development that would have a significantadverse impact on the population or conservation status of protected and priority species.
4. The land north of BedZED is part of a much bigger area of MOL, the Beddington Farmlands,
which is also an SMI. The ecological appraisal for the land north of BedZED submitted as part ofthe Core Strategy evidence base noted that insufficient appraisals have been undertaken to fullyidentify the ecological value of the site, and therefore it is impossible at this stage to fullyappreciate whether the de-designation of the site would impact significantly on the biodiversity ofthe wider SMI. In actual fact, the evidence submitted confirms that the ongoing designation ofthe land as SMI is fully justified as the reason for it having been so designated remains current.The proposed use of the land north of BedZED for mixed-use development would result in a lossof protection for the SMI and a loss of protection for sites of strategic importance for biodiversityin London. Consequently, this aspect of the Masterplan raises concerns relating to non-generalconformity with London Plan policy.
5. The redevelopment of the Wandle Valley Trading Estate appears to include the northern section ofthe Spencer Road Wetlands SINC (SINC 5 in Sutton's adopted UDP, mapl.13). This area includesan old mill pond and ditch, shown clearly on figures 1.3, 3.19 and 5.1, yet this is zoned for
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redevelopment in Figures 2.10,304,3.9,4.1,4.2,6.1 and 6.5. No explanation is given in the textfor why this area is not retained as a SINC or green space, so this also raises concerns relating tonon-general conformity with London Plan policy.
Wandle Valley Regional Park
6. The Hackbridge Masterplan makes several references to a proposed Wandle Valley Regional Park,but confuses this proposal with the area associated with the restoration of Beddington Farmlandsas a nature reserve. The proposed Wandle Valley Regional Park would extend from the upperRiver Wandle in Croydon, through Sutton, Merton and Wandsworth, and provide over 3,000hectares of connected green space and built areas along the length of the River Wandle. Theareas referred to in the Masterplan presumably refer to a local country park proposal, but thisshould not be confused with the regional park proposal in the London Plan.
District centre designation
7. Hackbridge is currently a local centre, however the Master Plan seeks to elevate the centre inthe London Plan town centre network to 'District Centre' leveL. The GLA is undertaking TownCentre health checks which will inform the revisions to the town centre network in the review ofthe London Plan. Even if the health checks suggest that Hackbridge could be upgraded toDistrict Centre, the proposed upgrade would need to be supported by evidence from detailedretail needs and capacity studies to identify potential for growth.
8. Notwithstanding the above, the principle of changing the town centre from local to districtstatus is supported, provided that it is in a highly sustainable and highly accessible location, andonly if the case can be made that there is an identifiable need/demand for the increase in retailand identified capacity to accommodate such an increase without encroaching on MOL.However, the development sites identified in the Hackbridge neighbourhood have publictransport accessibility levels of 1 a to 3, which may raise concerns that the area is not accessibleenough to justify elevation to a district centre.
9. More significantly, any growth plan for the town centre that relies on the development of MOLwould not be in general conformity with the London Plan; aspirations for growth would not beconsidered to be an exceptional circumstance that would justify the loss of MOL. The currentMasterplan does not illustrate alternatives for growth of the centre without encroaching onMOL, and therefore the implication of the Council's proposals for Hackbridge suggests that thegrowth of the centre could not be achieved without encroaching on MOL. An option thatprovides for town centre growth without the development on MOL should be pursued.
Loss of industrial land
10. The Council's Core Planning Strategy has been submitted to the Secretary of State forconsideration, and includes a proposed de-designation of Industrial sites in Hackbridge for mixeduses. The Mayor's SPG on industrial land capacity states that Sutton is a restricted transferborough for the release of industrial lands, however, it also makes clear that this status does notpreclude the possibility of smaller scale and controlled release of industrial land. London Plan
policy 3Bo4/ndustrial Locations and the Mayor's SPG do recognise that it may be appropriate torelease some sites in the town centres for redevelopment into mixed uses in order to achieveemployment objectives without requiring the re-provision of industrial land elsewhere.
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11. The proposals in the Masterplan to redevelop the Felnex Industrial and Wandle Valley Tradingestates for mixed use development to meet the need for more local employment opportunitiesusing industrial land more efficiently. However, the Core Strategy also proposes to expandStrategic Industrial Locations elsewhere in the borough onto Metropolitan Open Land, partially tomeet anticipated need for industrial land. The loss of MOL to meet the need for industrial landsuggests that although London Plan policy may support the principle of release without re-provision to achieve employment objectives, given Sutton's 'restricted transfer' status forindustrial land and identified need, the principle of the loss of industrial lands in this location maynot be justified.
12. This potential conflict should be addressed in the evidence base submitted with the proposed CorePlanning Strategy, and a view will have to be taken by the Inspector at the Examination in Public.The elements of the Masterplan that propose releasing the industrial sites to mixed uses shouldtherefore be reviewed following the Examination in Public for the Core Strategy to ensure it isconsistent with the approach to industrial land agreed by the Inspector.
Urban design framework
13. The proposed Masterplan seeks to enhance the 'natural heart' of Hackbridge by expanding theexisting town centre at the junction of Hackbridge and London Roads. There may be furtheropportunities to build on the existing areas of special character such as Hackbridge Green indeveloping the town centre which should not be overlooked.
14. The Council should focus on strengthening that one centre along London Road rather thandiluting its importance by promoting simultaneous reinforcement of the 'secondary' centreopposite BedZED. The need to reinforce this secondary centre assumes on the creation of agateway at this point, which is not entirely convincing, and also assumes that development onMOL north of BedZED will occur. It may be more suitable to encourage a secondary towncentre near the Wandle Valley Trading Estate, which could more effectively serve the northernpart of the Masterplan area including the proposed employment and residential areas.
Climate_rhange and one-planet living
15. Generally, the policies and direction of the SPG support the climate change and energy policiesin the London Plan (London Plan Policies 4A.1 - 4A.7). Chapter 7 of the Masterplan sets outthe vision for "One Planet Living" in Hackbridge. In this section, Sutton states in section 7.5that "details on how to best fulfil the One Planet Living principles in Hackbridge are still beingconsidered" and that a further review is being undertaken with environmental consultants.With this in mind, the following points are to assist in the further development of the OnePlanet Living section of the SPG.
16. The new district centre could be ideal for CHP and CCHP. There are many references to districtheating and CHP (section 7.7), but this could be further strengthened by undertaking anEnergy masterplanning exercise to strategically and spatially identify sites for energy centre andheating networks, and also that the networks include cooling. This would meet London PlanPolicy 4A.5. However, none of the maps made available in the draft Masterplan set out theopportunities for decentralised energy or make recommendations for a strategic energy centre.An energy masterplanning exercise would help Sutton identify suitable locations for maximisingthe potential from renewables and decentralised energy. If the development is planned instages, there could be the opportunity to strategically develop these networks throughout thesite in phases.
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17. Section 7.3 also refers to "maximising the potential role of renewable energy sources anddecentralised energy infrastructure," an aspiration which is supported and in line with LondonPlan policy. However, in the more detailed development briefs for the Felnex site and the landnorth of the rail station, there is no specific requirement for the inclusion of energy and heatingnetworks, whereas this requirement is clearly set out in the briefs for the land north of BedZedand the Wandle Valley Trading Estate. It is unclear whether this is an intentional ommision, andif so, what the rationale may be for not encouraging the use of heating networks on those twosites.
18. We are interested in having further information on the "Charter for Hackbridge SustainableSuburb" and the individual planning performance agreements and how these can be linked inwith climate change mitigation and sustainable energy. The Masterplan also refers to thedevelopment of a "Low Carbon Zone" in Hackbridge. The Mayor has announced his intentionto develop a number of Low Carbon Zones across London, and there may be an opportunity forHackbridge to link into this Mayoral initiative.
19. The reference to "Iow carbon standards" does not include any robust definition. A robustdefinition is necessary to make the policy clear, but it is recommended that this take intoaccount the outcome of the Government's consultation on the definition of Zero Carbon homesand non-domestic buildings, which closed 18th March 2009.(http://www .comm u n iti es. gov. u k/ pu b i ications/ pi a n ni nga nd bu i Idi ng/zeroca rbondefi niti on)
20. The GLA is very supportive of the references to retrofitting and improving existing buildings, toimprove their energy efficiency and to link them into renewable energy opportunities that maydevelop in Hackbridge. The ambition to reduce the embodied carbon of construction materialsby 75% is also supported.
21. Section 7.8 refers to private wire networks. Generally, private wire networks are unnecessaryand are not required to meet the energy policies in the London Plan.
22. Section 7.2 refers to sustainable energy from waste and sections 7.9 and 7.10 refer to wastemanagement. This could include opportunities for waste management and heat / energy fromanaerobic digestion. More information on integrating waste management facilities intodevelopments can be references in the GLA report "Rubbish In Resources Out: Design ideas
for waste facilities in London, 2008" which is available online at:http://www.london.gov. u k/ mayor / envi ronment/waste/ docs/waste-desig n.pdf.
Waste
23. The long-term aim of a "One-Planet" Living community is to achieve waste levels approachingzero and ultimately to eliminate the concept of waste. The GLA welcomes the aim for a zerowaste strategy and targets that exceed or meet those set out in policy 4A.21 of the LondonPlan. The Masterplan states that this will be done by on-site composting, recycling bins andother conveniently located recycling bins. We will be interested in the policies that will supportthe delivery of these proposals which should demonstrate how it will meet the targets they haveset and how performance will be measured/monitored.
24. The GLA also welcome the aim for zero carbon and that all new buildings should be powered byrenewable energy and /or sustainable energy from waste, in line with London Plan policy
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4A.2l, which encourages the production of energy from waste. Landfill and sewage gas has
already been identified as a possible source of energy, however alternative technologies such asanaerobic digestion should be explored. Parallel to this the Masterplan will also need todemonstrate how during its implementation it will respond to London Plan 4A.22 which wouldexpect DPDs to require the provision of suitable waste and recycling storage facilities in all newdevelopments, including treatment facilities to recover value from residual waste. If wastecannot be dealt with locally the council must provide waste facilities that have good access torail or the Blue Ribbon Network (4C.8).
25. Policies should be put in place in relation to the sustainable management of waste on-siteduring development, in line with London Plan policy 4A.28.
Transport
26. Transport for London notes that new mixed use development is proposed including 1,100 newresidential units. This could potentially have a substantial transport impact and developers will
need to provide mitigation measures via section 106 funding and/or the CommunityInfrastructure Levy. The existing bus capacity in this area will be insufficient to cater for theproposed expansion of Hackbridge, therefore substantial developer contributions will berequired to improve bus provision. Furthermore, as an area of medium to low public transportaccessibility levels (ranging from a score of 1 - 3), substantial improvements to the publictransport provision in the area will be necessary to justify such high density development underthe GLA's habitable room density matrix and London Plan policy 3C.2 Matching development totransport capacity.
27. The attached table includes detailed comments on the Masterplan from Transport for Londonrelating to car parking, cycling, bus routes, freight transport, the proposed improvements toLondon Road and the site development brief for the Felnex site, among others.
As you are aware all local development documents including supplementary planning documentshave to be in general conformity with the London Plan under section 24 (1 )(b) of the Planning andCompulsory Purchase Act 2004. There are several aspects of the draft Masterplan that would raiseconcerns of non-general conformity at formal consultation stage. These should be addressed inthe draft SPD.
Yours sincerely,
Giles DolphinHead of Planning Decisions
cc Steve O'Connell, London Assembly Constituency Member for Croydon and Sutton
Nicky Gavron, Chair of London Assembly Planning and Spatial Development CommitteeJohn Pierce and lan McNally, GOLColin Lovell, TfLHelen Wood & Dean Williams, LDA
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ng r
easo
ns f
or o
bjec
tion
GL
Ath
e D
PD
doe
sL
ondo
nm
atte
r be
enre
leva
ntR
ef.
this
sub
mis
sion
Pla
n P
olic
yra
ised
Soun
dnes
si I
No.
rela
te to
?cr
oss
ref.
prev
ious
ly?
Tes
t(s)
TfL
not
es th
at th
e co
nsul
tatio
n do
cum
ent d
oes
not m
entio
n th
e ne
ed fo
r de
velo
pers
tosu
bmit
a T
rans
port
Ass
essm
ent (
TA
) al
ongs
ide
plan
ning
app
licat
ions
for
new
Sec
tion
4 U
rban
deve
lopm
ent.
TfL
sug
gest
s th
at th
e M
ovem
ent s
ectio
n sh
ould
cla
rify
the
coun
cil's
Des
ign
requ
irem
ents
in th
is r
espe
ct, m
akin
g cl
ear
that
any
app
licat
ions
for
maj
or d
evel
opm
ent
(ref
erab
le to
the
May
or u
nder
the
May
or o
f Lon
don
Ord
er 2
008)
sho
uld
beFr
amew
ork,
3C.2
acco
mpa
nied
by
a T
A p
rodu
ced
in a
ccor
danc
e w
ith T
fls
'Tra
nspo
rt A
sses
smen
t bes
tM
ovem
ent
(par
agra
phs
prac
tice
guid
ance
doc
umen
t (M
ay 2
006)
'. T
his
will
ens
ure
that
all
form
s of
tran
spor
tar
e ex
amin
ed a
s pa
rt o
f a
plan
ning
app
licat
ion,
that
app
ropr
iate
miti
gatio
n m
easu
res
4.14 - 4.31)
for
tran
spor
t are
put
for
war
d an
d th
at w
alki
ng, c
yclin
g an
d pu
blic
tran
spor
t mod
es a
refu
lly ta
ken
into
acc
ount
and
pro
mot
ed w
here
ver
poss
ible
.
TfL
not
es th
at th
e co
nsul
tatio
n do
cum
ent d
oes
not s
peci
fical
ly r
efer
to P
ublic
Sec
tion
4 U
rban
Tra
nspo
rt A
cces
sibi
lity
Leve
ls (
PT
ALs
), a
lthou
gh it
doe
s br
oadl
y ac
know
ledg
e th
at th
eD
esig
n,
loca
tion
of n
ew d
evel
opm
ent h
as a
n im
port
ant i
nflu
ence
on
man
agin
g de
man
d fo
ri
Fram
ewor
k,3C
.1tr
avel
. TfL
sug
gest
s th
at P
TA
Ls s
houl
d be
spe
cific
ally
ref
erre
d to
in th
e do
cum
ent:
InM
ovem
ent
acco
rdan
ce w
ith th
e L
ondo
n Pl
an, h
igh
dens
ity a
nd la
rge
scal
e de
velo
pmen
t sho
uld
be(p
arag
raph
s
I
care
fully
pla
nned
and
loca
ted
whe
re P
TA
Ls v
alue
s ar
e hi
gher
and
whe
re s
uffic
ient
I
4.14
-4.3
1)tr
ansp
ort c
apac
ity e
xist
s or
can
be
prov
ided
to a
ccom
mod
ate
gene
rate
d tr
ips.
3
Hac
kbrid
ge S
usta
inab
le S
ubur
b F
inal
Dra
ft M
aste
rpla
n
Rep
rese
ntat
ions
from
the
May
or o
f Lon
don
Stat
utor
y C
onsu
ltatio
n pe
riod
: 11
Febr
uary
to 2
5 M
arch
200
9
Whi
ch p
art o
fH
as th
isN
umbe
r of
Rep
rese
ntat
ions
, inc
ludi
ng r
easo
ns f
or o
bjec
tion
GL
Athe DPD does
Lon
don
Ref
.th
is s
ubm
issi
onP
lan
Pol
icy
mat
ter
been
rele
vant
rais
edSo
und
ness
No.
rela
te to
?cr
oss
ref.
prev
ious
ly?
Tes
t(s)
Sec
tion
4 U
rban
Des
ign
TfL
wel
com
es th
e re
fere
nces
in p
arag
raph
4.3
1 to
trav
el p
lann
ing.
How
ever
, it w
ould
be
Fram
ewor
k,3C
.2us
eful
if th
is p
arag
raph
cou
ld b
e ex
pand
ed to
spe
cify
that
trav
el p
lans
sho
uld
com
ply
Mov
emen
twith Tfls best practice guidance for residential and workplace travel plans (February
(par
agra
ph20
08).
4.31
)
4
Hac
kbrid
ge S
usta
inab
le S
ubur
b F
inal
Dra
ft M
aste
rpla
n
Rep
rese
ntat
ions
from
the
May
or o
f Lon
don
Stat
utor
y C
onsu
ltatio
n pe
riod
: 11
Febr
uary
to 2
5 M
arch
200
9
Whi
ch p
art o
fH
as th
isN
umbe
r of
Rep
rese
ntat
ions
, inc
ludi
ng r
easo
ns f
or o
bjec
tion
GL
Athe DPD does
Lon
don
Ref
.th
is s
ubm
issi
onP
lan
Pol
icy
mat
ter
been
rele
vant
rais
edSo
undn
ess
No.
rela
te to
?cr
oss
ref.
prev
ious
ly?
Tes
tes)
ì
TfL
wel
com
es th
e C
ounc
il's
prop
osal
s re
res
iden
tial c
ar p
arki
ng s
tand
ards
and
car
club
s. H
owev
er, t
he M
aste
rpla
n fa
ils to
men
tion
car
park
ing
for
non-
resi
dent
ial
deve
lopm
ent.
It w
ould
be
help
ful f
or th
e M
aste
rpla
n to
mak
e re
fere
nce
to L
ondo
nPl
an m
axim
um c
ar p
arki
ng s
tand
ards
, as
wel
l as
any
stan
dard
s ad
opte
d by
the
Bor
ough
in li
ne w
ith th
e L
ondo
n Pl
an (
see
TfL
's c
omm
ents
sub
mitt
ed s
epar
atel
y in
resp
onse
to th
e co
nsul
tatio
n on
Sut
ton'
s S
ite D
evel
opm
ent P
olic
ies
Pre
ferr
ed
Sec
tion
4 U
rban
Opt
ions
,Fe
brua
ry 2
009)
. Giv
en th
e Su
stai
nabl
e Su
burb
con
cept
, the
re is
sco
pe to
Des
ign
appl
y ca
r pa
rkin
g st
anda
rds
that
are
sig
nifi
cant
ly b
elow
the
max
imum
sta
ndar
ds in
Fram
ewor
k,A
nnex
4th
e L
ondo
n Pl
an. C
ar c
lubs
can
als
o be
inva
luab
le f
or b
usin
esse
s an
d re
duce
the
Mov
emen
t3C
.23
need
for
sta
ff/o
pera
tiona
l car
par
king
. The
par
king
sec
tion
shou
ld a
lso
addr
ess
the
(par
agra
phs
3C.2
4ne
eds
of d
isab
led
mot
oris
ts a
s w
ell a
s co
nsid
erin
g re
quir
emen
ts f
or d
rop-
off/
pick
-up
4.28 - 4.29)
faci
litie
s fo
r ta
xis
at th
e ra
il st
atio
n/in
terc
hang
e. D
rop-
off/
pick
-up
faci
litie
s ne
ed to
be within close proximity of entrances to allow easy access for wheelchair and
mob
ility
impa
ired
use
rs.
TfL
sug
gest
s th
at th
e Si
te D
evel
opm
ent B
rief
s sh
ould
be
deve
lope
d fu
rthe
r in
this
resp
ect.
5
Hac
kbri
dge
Sust
aina
ble
Subu
rb F
inal
Dra
ft M
aste
rpla
n
Rep
rese
ntat
ions
from
the
May
or o
f Lon
don
Sta
tuto
ry C
onsu
ltatio
n pe
riod:
11
Feb
ruar
y to
25
Mar
ch 2
009
Whi
ch p
art o
fH
as th
isN
umbe
r of
Rep
rese
ntat
ions
, inc
ludi
ng r
easo
ns f
or o
bjec
tion
GL
Athe DPD does
Lon
don
Ref
.th
is s
ubm
issi
onP
lan
Pol
icy
mat
ter
been
rele
vant
rais
edSo
undn
ess
No.
rela
te to
?cr
oss
ref.
prev
ious
ly?
T est(s)
TfL
wel
com
es th
e pr
opos
als
to im
prov
e th
e ne
twor
k of
cyc
le r
oute
s th
at c
onne
ct w
ithin
Hac
kbri
dge
and
to k
ey d
estin
atio
ns o
utsi
de o
f th
e ar
ea. H
owev
er, t
he m
ain
text
of
the
SP
D d
oes
not m
entio
n th
e im
port
ance
of c
ycle
par
king
in e
ncou
ragi
ng c
yclin
g. W
hile
Sec
tion
4 U
rban
cycl
e pa
rkin
g is
men
tione
d in
App
endi
x B
: Tra
nspo
rt, T
fL s
ugge
sts
that
this
sho
uld
beD
esig
nA
nnex
4br
ough
t for
war
d in
to th
e m
ain
docu
men
t.Fr
amew
ork,
3C.2
2M
ovem
ent
3C.2
3T
he M
aste
rpla
n sh
ould
ref
er s
peci
fical
ly to
the
adop
tion
of m
inim
um c
ycle
par
king
(par
agra
phs
stan
dard
s in
line
with
the
Lond
on P
lan
and
as s
et o
ut in
Sut
tons
's S
ite D
evel
opm
ent
4.14
-4.3
1)P
olic
ies
Pre
ferr
ed O
ptio
ns, F
ebru
ary
2009
. Sec
ure,
acc
essi
ble
and
pref
erab
ly s
helte
red
icy
cle
park
ing
shou
ld b
e pr
ovid
ed a
t new
dev
elop
men
ts a
nd k
ey d
estin
atio
ns, i
nclu
ding
at s
tatio
ns!
publ
ic tr
ansp
ort i
nter
chan
ges.
TfL
sug
gest
s th
at th
e Si
te D
evel
opm
ent
Brie
fs s
houl
d be
dev
elop
ed fu
rthe
r in
this
res
pect
.
6
Hac
kbrid
ge S
usta
inab
le S
ubur
b F
inal
Dra
ft M
aste
rpla
n
Rep
rese
ntat
ions
from
the
May
or o
f Lon
don
Stat
utor
y C
onsu
ltatio
n pe
riod
: 11
Febr
uary
to 2
5 M
arch
200
9
Whi
ch p
art o
fH
as th
isN
umbe
r of
Rep
rese
ntat
ions
, inc
ludi
ng r
easo
ns f
or o
bjec
tion
GL
Athe DPD does
Lon
don
Ref
.th
is s
ubm
issi
onP
lan
Pol
icy
mat
ter
been
rele
vant
, rai
sed
Soun
dnes
sN
o.re
late
to?
cros
s re
f.pr
evio
usly
?T
este
s)
TfL
not
es th
at th
ere
is n
o co
nsid
erat
ion
of f
reig
ht is
sues
in th
e M
aste
rpla
n. T
fLsu
gges
ts th
at th
e M
aste
rpla
n sh
ould
ref
er to
a lo
cal d
ocum
ent w
ith d
evel
opm
ent p
lan
status which includes a general policy on freight, based on Policy 3C.25 of
the
Lon
don
Plan
(an
d PP
G i
3), t
akin
g in
to a
ccou
nt th
e su
stai
nabi
lity
aspe
cts
of f
reig
ht.
Itis
impo
rtan
t to
cons
ider
bot
h co
nstr
uctio
n fr
eigh
t and
del
iver
y an
d se
rvic
ing
requ
irem
ents
. Det
ails
of
Con
stru
ctio
n L
ogis
tics
Plan
s (f
or c
onst
ruct
ion
of n
ewde
velo
pmen
t) a
nd D
eliv
ery
and
Serv
icin
g Pl
ans
(for
occ
upat
ion)
are
out
lined
in th
eL
ondo
n Fr
eigh
t Pla
n, v
iew
able
at h
ttp://
ww
w.tf
l.gov
.uk/
frei
ght.
Furt
her
info
nnat
ion
can
also
be
prov
ided
by
the
TfL
Fre
ight
Uni
t on
requ
est.
Sec
tion
4 U
rban
I
i Des
ign
TfL
sug
gest
s th
at th
e M
aste
rpla
n sh
ould
set
out
how
the
gene
ral p
olic
y on
frei
ght w
illbe
app
lied
loca
lly in
the
case
of H
ackb
ridge
. The
Site
Dev
elop
men
t Brie
fs s
houl
d al
soFr
amew
ork,
be d
evel
oped
fur
ther
in th
is r
espe
ct.
Mov
emen
t3C
.25
(par
agra
phs
In p
aiiic
ular
, TfL
not
es th
at th
ree
of th
e si
tes
in th
e M
aste
rpla
n ar
e cu
rren
tly4.
14-4
.31)
indu
stri
al a
nd a
re id
entif
ied
as s
uch
in th
e U
DP;
the
Mas
terp
lan
seek
s to
cha
nge
this
.TfL is conccrned that if
the
exis
ting
uses
(w
areh
ousi
ng/lo
gist
ics)
are
dis
plac
ed to
outs
ide
of L
ondo
n, th
e "s
usta
inab
le s
ubur
b" c
ould
act
ually
be
gene
ratin
g m
ore
and
long
er f
reig
ht tr
ips,
lead
ing
to m
ore
C02
em
issi
ons
and
cong
estio
n. T
he M
aste
rpla
nne
eds
to a
ddre
ss th
ese
issu
es. F
rom
a p
ublic
tran
spoi
i and
traf
fic
impa
ct p
ersp
ectiv
e,th
e ch
ange
in th
e nu
mbe
r an
d na
ture
of
trip
s as
soci
ated
with
new
use
rs o
f th
e si
tes
shou
ld a
lso
be c
onsi
dere
d i.e
. new
res
iden
tial a
nd o
ffic
e de
velo
pmen
t is
likel
y to
resu
lt in
pea
k hO
Ul.t
rips
, whe
reas
the
old
trip
s w
ere
prob
ably
shi
ft w
orke
rs, a
nd o
f
I
lowcr numbers. None of
thes
e si
tes
seem
s la
rge
enou
gh to
fun
ctio
n as
sel
f-co
ntai
ned
live/
wor
k ar
eas,
hen
ce th
crc
wil
be c
omm
utin
g tr
ips
betw
een
resi
dent
s an
d th
eir
offc
es/p
lace
of w
ork.
7
Hac
kbri
dge
Sust
aina
ble
Subu
rb F
inal
Dra
ft M
aste
rpla
n
Rep
rese
ntat
ions
from
the
May
or o
f Lon
don
Stat
utor
y C
onsu
ltatio
n pe
riod
: 11
Febr
uary
to 2
5 M
arch
200
9
Whi
ch p
art o
fH
as th
isN
umbe
r of
Rep
rese
ntat
ions
, inc
ludi
ng r
easo
ns f
or o
bjec
tion
GL
Ath
e D
PD
doe
sL
ondo
nR
ef.
this
sub
mis
sion
Pla
n P
olic
ym
atte
r be
enre
leva
ntra
ised
Soun
dnes
sN
o.re
late
to?
cros
s re
f.pr
evio
usly
?T
est(
s)
TfL
sug
gest
s th
at th
e M
aste
rpla
n sh
ould
ref
er to
a lo
cal d
ocum
ent w
ith d
evel
opm
ent
plan
sta
tus
(e.g
. Sut
ton'
s S
ite D
evel
opm
ent P
olic
ies
Pre
ferr
ed O
ptio
ns, F
ebru
ary
2009
), w
hich
set
s ou
t a g
ener
al p
olic
y on
tran
spor
t-re
late
d pl
anni
ng o
blig
atio
ns,
incl
udin
g th
e ne
ed to
col
lect
pla
nnin
g ob
ligat
ions
for
publ
ic tr
ansp
ort,
wal
king
and
Sec
tion
4 U
rban
cycl
ing.
TfL
sug
gest
s th
e ov
eral
l pol
icy
on p
lann
ing
oblig
atio
ns s
houl
d in
clud
e ex
plic
it
Des
ign
supp
ort f
or p
oole
d co
ntrib
utio
ns, a
s ad
voca
ted
in c
ircul
ar 0
5/05
. In
adva
nce
ofle
gisl
atio
n on
the
Com
mun
ity In
fras
truc
ture
Lev
y (C
IL),
sec
tion
106
cont
ribut
ions
can
Fram
ewor
k,6A
.4be
use
d to
con
trib
ute
to b
orou
gh w
ide
tran
spor
t im
prov
emen
ts a
s w
ell a
s si
te s
peci
ficM
ovem
ent
(par
agra
phs
6A.5
impr
ovem
ents
if th
e ju
stifi
catio
n is
set
out
in a
Dev
elop
men
t Pla
n D
ocum
ent.
TfL
perio
dica
lly e
nter
s in
to s
ectio
n 10
6 ag
reem
ents
as
co-s
igna
tory
with
bor
ough
s, if
TfL
is4.14 - 4.31)
requ
ired
to p
rovi
de th
e tr
ansp
ort i
nfra
stru
ctur
e re
quir
ed a
s pa
rt o
f th
e ag
reem
ent.
Thi
s of
ten
assi
sts
in d
eter
min
ing
the
deta
ils o
f the
sch
eme
and
deliv
ery
of th
ein
fras
truc
ture
mor
e ac
cura
tely
.
TfL suggests that the Masterplan should set out how the general policy on planning
oblig
atio
ns w
ill b
e ap
plie
d lo
callv
in th
e ca
se o
f Hac
kbrid
ae.
8
Hac
kbrid
ge S
usta
inab
le S
ubur
b F
inal
Dra
ft M
aste
rpla
n
Rep
rese
ntat
ions
from
the
May
or o
f Lon
don
Stat
utor
y C
onsu
ltatio
n pe
riod
: 11
Febr
uary
to 2
5 M
arch
200
9
Whi
ch p
art o
fH
as th
isN
umbe
r of
Rep
rese
ntat
ions
, inc
ludi
ng r
easo
ns f
or o
bjec
tion
GL
Ath
e D
PD
doe
sL
ondo
nR
ef.
this
sub
mis
sion
Pla
n P
olic
ym
atte
r be
enre
leva
nt, r
aise
dSo
undn
ess
No.
rela
te to
?cr
oss
ref.
prev
ious
ly?
Tes
t(s)
, i I I
Sec
tion
4 U
rban
Re
prop
osal
s fo
r th
e im
prov
ed b
us in
terc
hang
e, s
ee c
omm
ents
und
er S
ectio
n 8.
Des
ign
3CI
Fram
ewor
k,3C
.3M
ovem
ent
3C.1
4(p
arag
raph
3C.1
84.
24)
3C20
The
sec
tion
on s
usta
inab
le tr
ansp
ort (
para
grap
hs 7
.11
- 7.
12)
is w
elco
med
, par
ticul
arly
the
inte
ntio
n to
hav
e re
side
ntia
l car
par
king
at 0
.8 s
pace
s pe
r un
it or
less
. How
ever
, TfL
, wou
ld li
ke to
see
firm
er c
omm
itmen
t to
this
inte
ntio
n ac
ross
the
entir
e M
aste
rpla
n si
teSe
ctio
n 7
One
and
ther
e is
no
men
tion
of c
ar p
arki
ng s
tand
ards
for
non
-res
iden
tial d
evel
opm
ent.
Pla
net L
ivin
g3C
.2T
here
is a
lso
no m
entio
n of
cyc
le p
arki
ng p
rovi
sion
or
the
role
that
trav
el p
lans
can
pla
yPr
inci
ples
,A
nnex
4in
red
ucin
g ca
r de
pend
ency
. Whi
lst i
t is
appr
ecia
ted
that
thes
e is
sues
are
to s
ome
Sust
ai n
able
3C.2
2ex
tent
cov
ered
els
ewhe
re in
the
cons
ulta
tion
docu
men
t, T
fL s
ugge
sts
that
they
sho
uld
Tra
nspo
rt3C
.23
be in
clud
ed in
this
sec
tion.
(par
agra
ph3C
.24
7.12
)T
here
is a
lso
no m
entio
n of
the
Smar
ter
Tra
vel S
utto
n pr
ojec
t tha
t has
bee
n su
cces
sful
in r
educ
ing
car
depe
nden
cy a
nd e
ncou
ragi
ng s
usta
inab
le tr
avel
. TfL
sug
gest
s th
at th
isdo
cum
ent w
ould
be
an id
eal p
lace
to s
ecur
e fu
ndin
g to
wid
en th
ese
prin
cipl
es a
cros
sm
ore
of S
utto
n.
9
Hac
kbrid
ge S
usta
inab
le S
ubur
b F
inal
Dra
ft M
aste
rpla
n
Rep
rese
ntat
ions
from
the
May
or o
f Lon
don
Sta
tuto
ry C
onsu
ltatio
n pe
riod:
11
Feb
ruar
y to
25
Mar
ch 2
009
Whi
ch p
art o
fH
as th
isN
umbe
r of
Rep
rese
ntat
ions
, inc
ludi
ng r
easo
ns f
or o
bjec
tion
GL
Athe DPD does
Lon
don
Ref
.th
is s
ubm
issi
onP
lan
Pol
icy
matter been
rele
vant
rais
edSo
undn
ess
No.
rela
te to
?cr
oss
ref.
prev
ious
ly?
Tes
tes)
TfL
wel
com
es th
e pr
opos
al to
impr
ove
the
rail/
bus
inte
rcha
nge
at H
ackb
ridge
Sta
tion,
subj
ect t
o th
e ef
fect
on
bus
jour
ney
times
bei
ng n
eglig
ible
. TfL
not
es th
at th
e us
e of
urba
n re
alm
to im
prov
e in
terc
hang
e is
sup
port
ed b
y th
e M
ayor
and
is r
efle
cted
inpa
ragr
aph
4.6
of th
e M
aste
rpla
n re
the
Stat
ion
Impr
ovem
ent S
chem
e. T
fls
Inte
rcha
nge
Bes
t Pra
ctic
e G
uide
lines
(20
01)
are
due
to b
e re
publ
ishe
d in
Spr
ing
2009
and
shou
ld a
ssis
t with
the
deve
lopm
ent o
f th
e M
aste
rpla
n pr
opos
als.
Section 8
TfL
wel
com
es th
e pr
opos
ed a
ppro
ach
to s
usta
inab
le tr
ansp
ort l
inka
ges
but t
he p
ublic
Dev
elop
men
t3C
.1tr
ansp
ort a
spira
tions
will
nee
d to
be
test
ed.
Bri
ef: F
elne
x3C
.3an
d K
elvi
n3C
.14
TfL
not
es th
e pr
opos
als
to in
trod
ucc
a bu
s ga
te in
the
Feln
ex s
ite (
para
grap
h 4.
24).
It
Hou
se; S
ectio
n3C
.18
is a
ssum
ed th
at th
e co
sts
occu
rred
for
inst
allin
g an
d m
aint
aini
ng th
e ga
te w
ill b
e4,
par
agra
ph3(
20ta
ken
up b
y th
e de
velo
per.
TfL
wou
ld n
ot ta
ke r
espo
nsib
ility
for
mai
ntai
ning
thc
4.24
gate
, but
wou
ld e
xpec
t it t
o be
rel
iabl
e fo
r al
l bus
ser
vice
s.
Seco
ndly
it is
men
tione
d th
at th
ere
is p
refe
renc
e to
put
the
new
bus
inte
rcha
nge
poin
tin
lay-
bys
(par
agra
ph 4
.24)
. TfL
gen
eral
ly p
refe
rs th
at b
uses
do
not s
top
in la
y-by
s(o
ther
than
in th
e ca
se o
f bu
s st
ands
) al
thou
gh la
y-by
s ca
n be
con
side
red
unde
rI
spec
ial c
ircu
mst
ance
s. H
avin
g th
e st
ops
in th
e m
ain
flow
of
traf
fic
help
s pr
ovid
ebe
tter
bus
prio
rity
, mak
es it
eas
ier
for
buse
s to
sto
p ad
jace
nt to
the
kerb
and
pro
vide
spa
ssen
gers
with
qui
cker
boa
rdin
g an
d al
ight
ing
times
.
10
Hac
kbri
dge
Sust
aina
ble
Subu
rb F
inal
Dra
ft M
aste
rpla
n
Rep
rese
ntat
ions
from
the
May
or o
f Lon
don
Stat
utor
y C
onsu
ltatio
n pe
riod
: 11
Febr
uary
to 2
5 M
arch
200
9
Whi
ch p
art o
fH
as th
isN
umbe
r of
Rep
rese
ntat
ions
, inc
ludi
ng r
easo
ns f
or o
bjec
tion
GL
Athe DPD does
Lon
don
Ref
.th
is s
ubm
issi
onP
lan
Pol
icy
mat
ter
been
rele
vant
rais
edSo
undn
ess
No.
rela
te to
?cr
oss
ref.
prev
ious
ly?
Tes
t(s)
I
Dep
endi
ng o
n th
e si
te d
ensi
ty, b
us s
tand
s m
ay b
e re
quir
ed to
allo
w a
n ad
ditio
nal r
oute
to te
rmin
ate.
If a
sta
nd is
req
uire
d, a
toile
t fac
ility
sho
uld
be m
ade
avai
labl
e fo
r dr
iver
use,
whi
ch L
ondo
n B
uses
will
mai
ntai
n.
Con
cern
ing
bus
stop
s, a
ny n
ew b
us s
helte
rs, p
osts
and
fla
gs m
ust b
e L
ondo
n B
uses
compliant and not bespoke.
Section 8
Dev
elop
men
tI T
he p
ropo
sals
for
Lond
on R
oad
(incl
udin
g th
e nu
mbe
r of
pro
pose
d pe
dest
rian
and
Bri
ef: F
elne
xtr
affic
cal
min
g m
easu
res,
the
road
nar
row
ing
and
20 m
ph s
peed
lim
it) a
re li
kely
to h
ave
and
Kel
vin
an im
pact
on
the
relia
bilit
y of
bus
es a
nd d
etai
led
prop
osal
s sh
ould
be
deve
lope
d in
Hou
se; S
ectio
nco
llabo
ratio
n w
ith th
e T
fL B
us P
riorit
y T
eam
to e
nsur
e th
at th
e pr
opos
als
do n
ot4,
par
agra
phne
gativ
ely
affe
ct th
e bu
s se
rvic
es to
/fro
m H
ackb
ridg
e.4.24 & 4.27
. (co
ntin
ued)
In p
rinci
ple,
TfL
wel
com
es p
ropo
sals
for
real
-tim
e pa
ssen
ger
info
rmat
ion
(par
agra
phi
4.24
). H
owev
er, S
utto
n co
unci
l sho
uld
be a
war
e th
at th
ere
is a
n on
goin
g re
venu
e co
stto
suc
h in
fras
truc
ture
and
TfL
wou
ld n
eed
to r
evie
w if
suc
h eq
uipm
ent w
as ju
stifi
ed(u
nles
s a
deve
lope
r w
ere
to m
ake
an o
ngoi
ng c
ontr
ibut
ion
to th
e m
aint
enan
ce o
f su
chsy
stem
s). T
he c
ombi
natio
n of
bus
and
trai
n in
form
atio
n is
a g
ood
idea
in p
rinc
iple
, but
Sut
ton
coun
cil s
houl
d no
te th
at it
may
be
diffi
cult
to im
plem
ent i
n pr
actic
e.
1 i
