LLDC Local Plan Examination in Public Statement on Matters 1, 2, 3, 4, 5 & 7

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1 A Bilfinger Real Estate company Workspace 14 Report LLDC Local Plan Examination in Public Statement on Matters 1, 2, 3, 4, 5 & 7 February 2015 gva.co.uk

2 Contents Contents INTRODUCTION & WORKSPACE IN CONTEXT... 3 MATTER 1: LEGAL AND PROCEDURAL... 8 MATTER 2: BUSINESS GROWTH, JOBS AND LIFELONG LEARNING MATTER 3: HOUSING MATTER 4: NATURAL AND BUILT ENVIRONMENT MATTER 5: INFRASTRUCTURE MATTER 7: SUB AREA POLICIES Appendices Appendix 1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 Recent Workspace Completions &Extract of Brochure Summary of Marsghate Business Centre Proposals GLA, London Borough of Newham & LLDC Feedback & Policy Application on Marshgate Business Centre Squire & Partners Supplementary Pudding Mill Townscape Analysis Schedule of suggested changes February 2015 gva.co.uk 2

3 Introduction & Workspace in Context 1.1 Workspace is the owner of the Marshgate Business Centre, Marshgate Lane, within the Pudding Mill area of Stratford. 1.2 Workspace 14 Limited is a leading provider of managed business accommodation for Small and Medium sized Enterprises (SMEs) in London, and manages over 485,000 sqm of floorspace across more than 25 of Greater London s Boroughs. 1.3 The Workspace 14 portfolio provides a variety of hubs and clusters where small businesses are successfully fostered. Workspace 14 s success across London is integrally linked to being able to offer clients and customers flexible floorspace options, excellent support services and well-tempered environments. To support the diverse nature of SMEs in London's economy, there is a need to continually refresh, rationalise and regenerate elements of the property portfolio, which is the approach that has been successfully achieved throughout London. An extract of our brochure including some examples of our recent completions are attached at Appendix Approximately 90% of the space let to SME's by Workspace is managed directly by Workspace, whom maintain a dedicated team to identify, market and let space to businesses. Through its web and internet based marketing programmes and costumer surveys, Workspace is able to identify the number of businesses looking at specified buildings, locations, and sectors which can be monitored by the company. This helps Workspace respond swiftly to changing market requirements and demands. 1.5 The key findings from recent customer survey work has identified the following as important to our customers: Good access and proximity to Public Transportation, e.g. PTAL 5+; Additional services - excellent data capacity and integrated telecoms; Like-minded or similar business sector within business centre or close by; Excellent collaborating working, social and hospitality spaces including local amenities. 1.6 During the Olympics, the wider Pudding Mill site, of which a small proportion comprises of Marshgate Business Centre, was cleared to allow for the occupation of February 2015 gva.co.uk 3

4 approximately half the wider site (not including Marshgate) by the HM Security Services between December 2011 and October 2012, covering the Olympic period. Post-Games, an outline planning application was approved for the majority of the adjoining land as part of the Legacy Communities Scheme consent (LPA Ref: 11/90621/OUTODA). The by-product of the Olympic Games was that the Pudding Mill area has been blighted as an area for industry given the substantial clearance. 1.7 Since the Olympic period, the Pudding Mill area in general has declined and, for investment purposes, the area does not rank highly against the criteria required to attract our customers and business occupiers. The Marshgate Business Centre site, for example, is currently 50% vacant. Where a build can achieve good average rents or the potential for growth, then it can attract significant investment capital. In the context of Marshgate Business Centre, the site requires significant subsidy in the form of an optimum mix of uses to allow for its viable redevelopment for commercial floorspace given is considerable drawbacks, which include: The location of the Marshgate Business Centre, to the south west of the Olympic Park in an isolated site with no form of local amenities such as shops or restaurants; The lack of proximity with other businesses and the perception of Pudding Mill as an isolated island site, which is neither Stratford nor the Olympic Park; Its poor connections with the road network for road freight and vehicles, which limits its use for B2/ B3/ B8 uses, notwithstanding the incompatibility of these uses with residential in respect of its allocation as a mixed use Opportunity Area as designated in the London Plan; The existing quality of the buildings on site, which are not of any historical merit to warrant their retention and attract Workspace tenants - despite the poor location - many of whom prefer to work in older buildings. This can also be said for the adjoining environment, which is bereft of any existing townscape context or character given its cleared status; Whilst the site is close to Pudding Mill DLR station, the route provides no surveillance to pedestrians using the route through to the station as the adjoining sites are all cleared. Consequently, there is a perception of a lack of safe walking routes to and from the station and is in fact a route that is avoided, as evidenced anecdotally through discussions with residents at the Public Consultation and through discussions with tenants; The lack of public sector investment that has been provided in the area to date, and which will not be delivered for at least 5 more years or possibly more, which is February 2015 gva.co.uk 4

5 at odds with the comparative level of funding that has been provided by the public sector within other new employment locations including Here East and the Millennium Quarter; The quality of the existing buildings on site which, along with the cumulative issues included above, has resulted in low demand which Workspace 14 for investment purposes is unable to leave in its current state until public sector money begins being invested in the area from 2020 onwards. 1.8 It is against this context that Workspace 14 has prepared its planning application for the redevelopment of the site, submitted in November A summary of the proposals is provided at Appendix 2. The application proposes mixed use residential redevelopment which will deliver a rationalised quantum of replacement employment floorspace, to be managed by Workspace 14, required to be subsidised by residential given the low current market demand for SME floorspace within this location. 1.9 Since the beginning of the plan-making process, Workspace has sought to engage with the London Legacy Development Corporation. Throughout this process, Workspace has continued to raise concerns that the plan s restrictive policies will prevent sustainable mixed use development coming forward and continues to raise these issues. To be specific, Workspace 14 is concerned about policies relating to: Employment: the draft Local Plan contains a number of stringent policy tests for a loss of employment floorspace outside of Employment Clusters, which fail to be backed up with an appropriate evidence base and fail to reflect the approach currently adopted by the London Borough of Newham and the Greater London Authority. They serve to curtail development which would provide wider regeneration benefits and would kick start regeneration in Pudding Mill, and contradict the approach as proposed within the LLDC s Employment Land Review (URS), which sets out that the success of the office ambitions for Stratford to hinge on major infrastructure investment and the quality of the Metropolitan Centre itself, none of which currently exists within Pudding Mill. It is also noted the policy is at odds with the Combined Policies Viability Study (BNP Paribas), which states that a flexible approach should be taken to developments proposing commercial and employment uses to allow for development to come forward. Attached at Appendix 3 is our most recent correspondence with the GLA, LLDC and the London Borough of Newham, which demonstrates how the LLDC intends to apply its policies which is at odds with the other parties and its evidence base. The plan fails to meet all of the Tests of Soundness in this regard. February 2015 gva.co.uk 5

6 Mix of uses: the draft plan fails to allow for the appropriate flexibility for a mix of uses to enable development to come forward. This strategy is one has been adopted to allow for the regeneration of the LLDC area, and whilst specific employment clusters should be protected in locations where they are most suited (e.g. the Stratford City for office; Employment Clusters for B2/ B8 uses in sequentially preferable locations) it should be recognised that, in mixed use regeneration areas applying the same stringent policy will curtail rather than enable development. Workspace s current proposals provide a lower quantum of employment floorspace than is on the site currently, however the redevelopment of the site will provide in excess of 200 jobs whilst the current site employs just under 30 people. The policy approach in Policy B.1 fails to recognise that redeveloped employment land has regenerative benefits that would not be possible without rationalising employment floorspace, and because of this the policy test is too stringent to allow development to come forward. Instead, the approach taken in policy J2 of London Borough of Newham s Core Strategy should be adopted instead. In this respect, the plan fails to meet Tests of Soundness 3. Density and building heights: the draft Local Plan relates to an area of regeneration; a mixed use Opportunity Area including for residential as allocated within the London Plan. The London Plan is emphatic that development should optimise the use of sites to meet Greater London s Housing Target, which has further increased within the Further Alterations to the London Plan (FALP). The FALP sets out a combined minimum target of 98,578 homes for the Olympic Boroughs, whilst the London Plan 2011 set out a combined target of 73,050. Despite this increased emphasis, the Local Plan fails to provide adequate flexibility for density and building heights across Pudding Mill, and instead seeks to propose a blanket restriction. This is an approach that it is included neither in the London Plan nor Newham s Core Strategy. Our Project Architects for the planning application, Squire and Partners, have provided an analysis in townscape terms as to why our site is appropriate for a taller building, attached at Appendix 4. The analysis shows that in the context of other approvals within Pudding Mill, the restriction in heights to approximately 21 storeys is unfounded and would fail to optimise sites as set out in the London Plan. Without appropriate flexibility to allow for a site specific solution to building heights, the plan fails to meet Test of Soundness 2. Viability: the draft Local Plan contains a number of stringent policies which fail to reflect changing market circumstances over time, providing for an undeliverable development plan. The Combined Policies Viability Study (BNP Paribas) states that a flexible approach should be taken to developments proposing commercial and employment uses to allow for development to come forward. The Local Plan does not reflect this approach in its policies, nor does it recognise the conclusions drawn within LLDC s Employment Land Review that the success February 2015 gva.co.uk 6

7 of the office ambitions for Stratford to hinge on major infrastructure investment and the quality of the Metropolitan Centre itself, none of which currently exists within Pudding Mill and which is lies outside of the Centre A series of further modifications have been made by the London Legacy Development Corporation (LLDC) in response to Workspace s representations, however these do not address the points we have raised above Workspace 14 would like the opportunity to redevelop and regenerate Marshgate Business Centre for a mixed use led redevelopment with the delivery of significant planning benefits including a new places to work, to live and relax with new waterside routes throughout the whole of our site, however as the current policy stands, and in consideration of how the LLDC seek to apply their policies as demonstrated in Appendix 3, our proposal is currently unviable. The evidence base has not been properly reflected in the policies, nor has the LLDC had regard to viability or national or regional planning policy. The Draft Plan therefore fails to meet Tests of Soundness 1, 2, 3 and We suggest that, based on the above representations and those included within this document, the Local Plan is amended in accordance with Appendix 5. February 2015 gva.co.uk 7

8 Matter 1: Legal and Procedural Matter 1: relates to the Duty to Co-operate and other Legal Requirements. The key issues relate to whether the duty to cooperate has been met and whether the legal requirements have been complied with. Introduction 2.1 In respect of Workspace s overall response as to whether the Duty to Cooperate and other legal requirements have been complied with, we would suggest that the LLDC has missed opportunities to take into consideration our requests to amend the plan to meet this requirement. We have provided details of the LLDC s approach to applying its Local Plan in Appendix 3, which is at odds with existing adopted policy and the general thrust of the London Plan. LLDC s approach is also inconsistent with the views of the London Borough of Newham (LBN) and the GLA. 2.2 We would re-iterate that the plan needs to be amended to reflect the policies and approach of the GLA and the London Borough of Newham. Accordingly, we have provided a schedule at Appendix 5 to reflect this, and would like to discuss these recommended amendments in more detail at Examination in Public. Question 3: Has there been constructive, active and on-going engagement between the relevant parties to maximise effectiveness in respect of all the main issues, in particular, the following: - Housing policy and targets for new development; - Provision for Gypsy and Traveller accommodation; - The planned growth of Stratford Metropolitan Town Centre (55,000sqm comparison retail floorspace) and possible adverse impact on other town centres; and - Waste management policy? If not how exactly has the process been deficient. 2.3 We would suggest that there has been limited constructive, active and on-going engagement between the relevant parties in terms of quantum of housing policy, mix of uses and site allocations. This can be demonstrated from the Appendix 3, which shows that although the GLA and Newham support the mix of uses provided as part of our on-going planning discussions and widely support our townscape response and building heights, LLDC has not adopted the same approach and does not share the same approach in respect of providing for its housing need. February 2015 gva.co.uk 8

9 2.4 In respect of employment floorspace, evidence for the provision of a blanket 25% non-residential uses (as LLDC is seeking to apply it on our site, see Appendix 3) or cumulative 25% across Pudding Mill is not founded, and no evidence for this policy can be found in either the LLDC s Employment Land Review (URS) or its Combined Policies Viability Study (BNP Paribas). Instead, an approach should be taken in both policy B.1 and Policy SA4.3 that follows the loss of employment test as set out in J2 of LBN s Core Strategy and allows for mixed use development including a higher proportion of residential to allow for development to viably come forward. 2.5 In early representations we commented that the Marshgate Business Centre s housing allocation had not been included within the Greater London SHLAA, and therefore it should be included within the other housing site allocations in the plan. The LLDC should deliver the minimum housing targets within the London Plan, however the policy approach does not reflect this onus nor is it reflected in the LLDC s approach to the release of employment land. It should be noted that there is further onus on the LLDC to deliver housing, as can be demonstrated by the FALP s latest housing targets; the London Plan 2011 sought 73,050new homes across the Olympic Boroughs; this has risen to 98,578 within the FALP. 2.6 The blanket policy in respect of building heights within policy SA4.3 across the Pudding Mill Area will also fail to optimise the delivery of housing, and does not reflect the Density Matrix on sites of higher public transport accessibility level in Table 3.2 of the FALP. Question 10 - Is the Local Plan in general conformity with the London Plan 2011 and amendments to it (RP/01, RP/02, RP/03, RP/04)? Has sufficient regard been had to the GLA s comments in its letter of 6 October 2014 (KD/25)? 2.7 Please see the comments above for Question The LLDC Local Plan should reflect the comments provided within the GLA by sequentially allocating B1(a) uses to town centres; demonstrating its 5 year supply of housing in its Housing Trajectory and maximising housing supply by providing a minimum of 24,000 new homes. However, the amendments do not address the more detailed policy points that have been overlooked, including LLDC s approach to mixed use development outside of the Employment Clusters, and the policies on February 2015 gva.co.uk 9

10 maximising housing supply in these locations as set out by London Plan in Opportunity Areas. Question 11- Appendix 1 to the Local Plan explains that it will supersede the adopted Local Plans which currently apply to the area, once adopted. Are there any significant departures and differences from the plans listed in Appendix 1, and if so are these fully justified (very briefly with a cross reference to other matters if necessary)? And is the approach set out in the Stratford Metropolitan Masterplan (BPP/10) carried through to the current Local Plan? 2.9 We consider there to be three key departures from the content of the Local Plan with LBN s Core Strategy and the FALP; employment policy, approach to mixed uses and building heights In respect of employment policies, the proposed cumulative 25% replacement employment / non-residential floorspace is unachievable and no evidence has been supplied to support it. Policy tests for loss of employment should be based around job densities and job quality not floorspace, as set out in Policy J2 of Newham s Core Strategy. There is no evidence to suggest that the creation of employment floorspace can be equated with job creation. The LLDC s application of this policy can be shown at Appendix 3, whereby they are seeking to impose the 25% policy to the Marshgate site in its entirety. The letter from LLDC also refers to the 25% policy being applied to Marshgate within the Pudding Mill Land Use and Design Framework; this is incorrect policy application for a document that holds no policy weight As with an affordable housing policy, a viability assessment should be undertaken to ensure the balance of employment floorspace required does not make schemes unviable. The 25% policy also fails to recognise that B1(a) use, as set out by the GLA to ensure policy conformity, should be located within the Town Centres. It is also suggested that this policy will rely upon the development of the wider area, in particular designated Employment Clusters/ locations, whereby commercial floorspace that would not be acceptable next to residential should be provided. The mix of uses Plan. should be considered flexibly, and reflect the approach of the London 2.12 The building heights and relevant policies referenced within Newham s Core Strategy are not specific, nor are those within the London Plan. These are the policies that the LLDC Local Plan should adhere to and not the Stratford Metropolitan Masterplan or the OLSPG, as these documents are planning guidance only and do not form part of the Development Plan. Furthermore, the blanket height restriction in respect of Sub February 2015 gva.co.uk 10

11 Area Policy 4A.3 fails to reflect the approach with which the FALP and LBN seeks to optimise housing The Town and Country Planning (Local Planning) (England) Regulations 2012 ("Planning Regulations") sets out legal regulations which apply to the policy weight of SPDs. It should be noted that an SPD: Should not contain Development Management/ Site Allocation policies (Regulation 5(1)); Should not identify an area as an area of significant change or special conservation (Regulation 5(2)); Should not conflict with the adopted development plan (Regulation 8(3)) The Stratford Metropolitan Masterplan is not the most up to date or relevant document by which to prepare a statutory development plan, nor does it share the same status Instead, guidance should be taken from the more recently adopted Newham Core Strategy and the London Plan Similarly, the Pudding Mill Land Use and Design Framework holds no status (not even SPD status) and should not be used as a development plan tool, which is clearly the incorrect approach by LLDC as evidenced by their letter in Appendix 3. The policy weight of this document needs to be confirmed by the Inspector to ensure the principles of the Local Plan are followed appropriately. February 2015 gva.co.uk 11

12 Matter 2: Business Growth, Jobs and Lifelong Learning With particular reference to its section 4, whether the Local Plan supports sustainable economic growth in line with paragraphs of the National Planning Policy Framework; and whether it conforms with the London Plan s aims for economic growth in changing times, securing the legacy of the 2012 Olympic and Paralympic Games, and tackling the persistent problems of deprivation and exclusion in the East of London. Introduction 3.1 Workspace 14 have a long and established track record in working alongside public and private partners to deliver new workspace that is specifically aimed at providing an environment that supports new and small businesses through the early phases of their development. The approach has always been responsive to both local market dynamics and regeneration agendas in order to deliver space that matches sectorial needs and helps to enhance local economic conditions. 3.2 Workspace 14 have delivered high quality, well used workspaces in most of London s key regeneration areas that serve to underpin the local economic base and provide a foundation for wider economic aspirations to be realised. The Workspace 14 approach is not a one size fits all development solution, the scale and nature of space is directly aligned to the type of businesses seeking to locate within an area and the scale and capacity of demand in the market. This creates a successful solution in each location, delivering space that is well used and accommodates a high level of new employment. 3.3 It is this experience that Workspace 14 is seeking to utilise at Marshgate to help deliver the LLDC s aspirations within the Pudding Mill sub-area. 3.4 Workspace 14 is highly supportive of the positive changes occurring within the Olympic Park. The 2012 Games and subsequent investment led by the LLDC have transformed the area, bringing significant benefits to both the Park itself and the wider area. The scale of development delivered, and still planned, is transformative and will begin to deliver a much enhanced location for visitors, residents and business. 3.5 The investment in economic infrastructure by Higher Education Institutions and Government, coupled with the delivery of large scale private sector led office development will, over time, begin to integrate the area into the Central London February 2015 gva.co.uk 12

13 market. However, as is currently being demonstrated by an occupier demand profile underpinned by public sector activity, it is likely this integration will take time and the market needs to mature significantly before it becomes a significant private sector occupier location. 3.6 Given the immaturity and fragility of this fledgling market it is vital that a development approach is adopted that seeks to reinforce the core offer, allowing critical mass to be developed around the key drivers to provide a focussed offer to the market and delivering complete places. An approach that seeks to disperse economic activity across the Olympic Park area has the potential to spread limited private sector demand too thinly, reducing opportunities to achieve critical mass and agglomeration benefits. 3.7 It is the Workspace 14 s belief that a more sensitive approach to policy making is required that is responsive both to the sequential nature of development and occupier demand and the specific characteristics and opportunities each site within the LLDC has. An approach that maximises each site s contribution to the overall vision for the Park based on its merits (rather than a blanket policy approach) is likely to achieve greater impact by delivering spaces in sequentially preferable locations that are attractive to businesses, such as town centres (as recommended by the GLA) in order to secure occupiers rather than lying empty or under-utilised. 3.8 This more sensitive approach is particularly required in locations which have, in effect, been held in stasis during the pre and post Games period. Whilst Games-related activity has generated many positive benefits it has effectively meant that the Pudding Mill area (in particular) has been out of general use for a decade. As such market activity and demand has been lost, preventing the natural evolution of this area as an economic location. Therefore, a market needs to be re-established, requiring an incremental approach to growth that responds to the characteristics of the area and develops employment space that aligns to these in both scale and nature of space provided. 3.9 It is Workspace 14 s experience that a market can be built over time in pioneer or fringe locations, but doing so successfully requires an approach that is of an appropriate scale but in its early stages the space provided needs to be at an appropriate scale to attract occupiers of a particular type. Providing a large amount of floorspace will not necessarily lead to the attractive of more occupiers and activity, February 2015 gva.co.uk 13

14 indeed the presence of significant amounts of empty space can significantly undermine market confidence, highlighting a weakness in the market rather than promoting strengths and opportunities. An oversupply will also further weaken rental positions across the LLDC area, challenging future workspace development viability and, ultimately, the achievability of the LLDC s strategic aims More importantly, without strong evidence of occupier demand for the types of employment uses envisaged by the draft Plan for the Pudding Mill area, the rigid requirement of 25% of floorspace to be employment generating could undermine development delivery generally. This space is likely to have a high level of vacancy and therefore be a significant cost to the development, it will therefore challenge the ability to viably deliver it alongside within a mixed use development that also delivers the LLDC s aims for affordable housing, high quality design, public realm enhancements and other infrastructure requirements It is our strong belief that a more appropriate approach to securing the successful economic-led regeneration of the Park would be to focus a strategy on the achievement of a higher level and a broader range of employment opportunities within sites and sub-areas rather than simply seeking to enforce the delivery of space in locations where there is no evidenced demand This should be linked to an evidenced understanding of what will drive occupier demand in different locations across the LLDC area and the different roles each can play in accommodating a range of different employment activities that integrate with other delivery priorities Ultimately we are not seeking to remove any need to provide employment generating floorspace and can see the role an early phase development such as the Marshgate site can play in helping build a new market. However, we wish to ensure that the approach taken is sufficiently flexible to respond to evidenced demand for space rather than rigidly enforce the delivery of space that is likely to remain vacant and threaten the deliverability and achievability of the LLDC s wider regeneration aspirations. How can the Local Plan be made sound? 3.14 We have suggested amendments in Appendix V. The Inspector s Report should also clarify the weight given to the Pudding Mill Land Use and Design Framework. February 2015 gva.co.uk 14

15 Question 1- Do the opening paragraphs 4.1 & 4.2 and Objective 1 provide a credible and appropriate starting-point for sustainable economic growth planning for the LLDC area? If not precisely why not? 3.15 Paragraph 4.2 discusses the level of change that has occurred over the area as a hotspot for development and activity. Whilst this is the case for many parts of the LLDC area, this is not true of Pudding Mill. No development has been delivered within the zone since the Olympics, whilst plans have been developed in the sub-area and neighbouring locations these are underpinned by various forms of public sector investment either through the LLDC, GLA, TfL, Central Government or HE Institutions. There has been very limited wholly private sector led development brought forward, undermining the notion that this is a particularly active location. This is further undermined by the low level of economic activity that has remained in the area since its use as a Games facility. It will take time to re-build the economic prospects in this area Objective 1 discusses expansion in research and development activity focused at Pudding Mill there is no evidence for this need nor existing uses for such expansion. It is important that an evidence based approach is taken for the retention/release of employment land, including on the type and proportion of existing uses and future demand. Proposals for Here East and UCL East (in particular) are at an early but have not demonstrated significant levels of need for additional employment space. Indeed each is seeking to provide their own start up and commercialisation spaces to support the core offer, suggesting they will seek to retain and attract businesses to their own sites The existing evidence base places Stratford in the Central London office market, which given the scale and nature of stock being delivered, may be appropriate over time (see response to Question 4) but this cannot be applied in a blanket way to the whole LLDC area. This ignores the factors that have driven the development agenda in this location (significant investment in infrastructure, place making and also public sector relocations) and how these differ in other parts of the LLDC area. In essence this section of the Local Plan fails to respond to local conditions and drivers. February 2015 gva.co.uk 15

16 Question 2- Should the Local Plan give more in-depth information about the economic impact of the Games, including the effect on local communities and businesses? In addition to benefits, should perceived recent difficulties associated with the Games- disruption to some businesses and loss of local jobs- be acknowledged? 3.18 Since the Olympic period, the Pudding Mill area in general has declined and, for investment purposes, this has largely been a result of the sterilisation of the land in market terms in the pre and post Games periods, halting its evolution as an economic hub. Essentially an employment and occupier market needs to be established in this location, particularly if the LLDC wishes to see a considerable improvement in the quality and type of employment and wider mix of uses The site does not rank highly against the criteria required to attract Workspace s customers and business occupiers. For example, our site is currently 50% vacant. Where a build can achieve good average rents or the potential for growth, then it can attract significant investment capital. In the context of Marshgate Business Centre, the site requires significant subsidy in the form of an optimum mix of uses to allow for its viable redevelopment for commercial floorspace given is considerable drawbacks. Question 3- The Employment Land Review, Examination Document LEB/006 considers it best to regard Stratford City and Here East as part of the Central London office market. Although the supply of such office space currently proposed across London exceeds the projected demand, the Review concludes that the Stratford area has good credentials compared with some other possible areas of supply. Is there good evidence to support a different conclusion? 3.20 The employment land study produced by LBN and the LOPR includes the International Quarter and Here East within the local office market which is the correct approach at this point of time given both offers are yet to be established and largely underpinned by significant public sector investment. However we recognise that, over time, the offer may evolve to become part of the Central London market and attract greater levels of private sector activity. February 2015 gva.co.uk 16

17 3.21 An important distinction is required between these distinct locations and the other parts of the LLDC area which do not benefit from the same drivers of activity and therefore do not have the correct conditions to perform in the same way in the future. The Employment Land Review (Pg 44) suggests with regard to Stratford and Here East that as both these sites are relatively self-contained and aimed at a different market the implications in terms of these proposals for the rest of the LLDC area might be potentially relatively limited These local locations will have a different form of demand, and the ELR suggests much lower scales of activity are expected, identifying a potential for 85,600sqm of pipeline space to be delivered. Our understanding, based on the ELR suggests that, outside of Stratford and Here East, there would result in a potentially significant oversupply of office floorspace of up to 30% in local areas, which the LLDC evidence base does not appropriately justify a qualitative or quantitative need for Furthermore, the assertion that Stratford has good credentials compared to other locations is not substantiated or evidenced. We would contend that, whilst a number of fundamentals are in place in terms of infrastructure, the market is (as yet) unproven, with demand underpinned by public sector occupiers. To justify a large supply within Stratford (given the large London-wide pipeline) the LLDC should provide evidence directly demonstrating how it is better placed than major locations in established markets (such as Wood Wharf, Vauxhall Nine Elms, Paddington, King s Cross and Greenwich Peninsula) to attract demand beyond potential price competitiveness. Question 4 - The London Plan, Document RP1, gives an indicative employment capacity for the Lower Lee Valley including Stratford of 50,000 to Over 30,000 predominantly office jobs are included in this figure. Is the Local Plan (Table 1) in general conformity, and is there any substantive evidence to dispute its figures? 3.24 Please note this section should also be read in accordance with our Introduction, which provides further context on this question in terms of how the different offers within the LLDC are likely to come forward The plan proposes 50,000 new jobs just for the legacy area so clearly there is a big discrepancy in these figures. February 2015 gva.co.uk 17

18 3.26 This is a capacity led target which, to date, has not been aligned with a robust assessment of whether there is sufficient demand side requirements to meet the target. The LLDC employment land review does not provide clear employment growth projections but identifies modest levels of office based employment growth within local areas for all 5 boroughs the LLDC covers of 1% (based on GLA Economics projections) suggesting an increase of c.23,000 jobs across all 5 boroughs for local office space alongside a small decline (0.9% or 8,000 jobs) for local industrial No detailed assessment is made of the scale of employment growth for the Stratford/Here East areas from a demand side, relying on the scale, critical mass and relative competitiveness (see our response to Q3 on this point) of the area to capture a share of Central London orientated growth. It is therefore somewhat unsubstantiated that this is a realistic expectation given the lack of evidence to suggest how Stratford can out-compete better located and more established locations on the CAZ fringe. Question 7 - Is Policy B1 overly concerned with directing new and expanding businesses to the Employment Clusters, Table 2, to maintain their local character, instead of recognising that market forces should prevail? Is there a case for more flexibility over the location and maintenance of employment uses? Is there strong evidence to relax the requirements of Policy B1 5? 3.28 This policy should recognise that each of the existing employment sites within the LLDC varies in quality and number of people employed and should recognise changing viability considerations of the plan period. The employment clusters should be protected, whereas those with potential for mixed use development should be given more flexibility where there is an increase in job numbers LBN CS Policy J2 has allowed for this level of flexibility without resulting in an adverse impact on the provision of employment floorspace, and in particular allowing development to come forward where there is a loss of floorspace, but improvement on the quality of jobs, and/or job numbers alongside other benefits such as housing, an increasing priority within the FALP. February 2015 gva.co.uk 18

19 3.30 The Employment Clusters should be protected whilst a more flexible policy test should be applied outside of these areas. We would suggest that the provision of floorspace outside of clusters should not just be about providing equivalent floorspace or jobs as this does not guarantee delivery. Question 8 - Is Policy B1 5b) encouraging higher (job) densities outside the clusters and within other Industrial Locations likely to be detrimental to locally important cultural, artistic, manufacturing and food industries? Could it restrict the growth of activities around new technology more likely to occur in workshops and yards than B1 office space? 3.31 Site viability circumstances have been taken into account for the re-provision of employment uses and where more stringent policy may have prevented sites coming forward In order to re-develop sites, a mix of uses is required to bring forward regeneration benefits which was the rationale behind LBN s Policy J2. The proposed policy does not allow for this flexibility to allow for development to come forward. Question 9 - It is suggested that local employment land releases have been three times higher than the London Plan foresaw. There is also concern that low value uses providing jobs for vulnerable workers with low skill levels and pay are most at risk in the changing market. Does Policy B1 provide appropriate protection for employment sites in the area? 3.33 This is not a LLDC specific issue and affects many locations on the edge of the CAZ, it is therefore not appropriate for a Local Plan to seek to deal with this in isolation, a broader approach is required to be a success A mix of uses should be promoted dependent on need. The Olympic Legacy has been predicated on this approach, and in order to realise this regeneration it is important that more valuable uses are brought forward to ensure delivery Similarly the LLDC area cannot be considered in isolation, indeed the 5 host boroughs all provide locations where these uses have already been relocated to as a result of the Park s regeneration. Given the scale of ambition for the LLDC area it would be incongruent to then seek to retain low margin or value activities in an area which has February 2015 gva.co.uk 19

20 stated aspirations to be part of the Central City. A more robust approach would be to secure a mix of spaces within the LLDC area that reflect both the changing nature of the place and viability considerations and also work at a sub-regional level to retain capacity in other areas for a wider range of activity By recognising the full range of employment generating uses that could be brought forward across the Park as being equal a wider range of employment opportunities can also be provided to engage the full spectrum of resident skills. Question 11 - Should Cooks Road be excluded from Table 2, having regard for paragraph 22 of the NPPF (the long term protection of employment use should be avoided where there is no reasonable prospect of it coming forward)? 3.37 Flexibility should be applied where appropriate, however it is important to note that different Employment Clusters are of varying quality, and those outside of Pudding Mill have locational advantage in respect of agglomeration, existing infrastructure etc The Cooks Road application is also based on a distinct set of circumstances that are not reflective of general market demand. Whilst it has secured 18% of floorspace as commercial this is underpinned by the site owner/developer moving into the space delivered. As such this is not a signal that there is significant market requirement in the Pudding Mill area. Question 19 - Are all the criteria in Policy B4 justified including the figure of 75% of historic market rent as achieved at Neptune Wharf? And does the Glossary include a satisfactory definition of low cost workspace? 3.39 The supporting text of this policy should allow for appropriate flexibility in line with para 182 of the NPPF, which requires plans to be deliverable over the plan period This policy should be subject to viability assessments. The policy is considered too inflexible and unviable given the LLDC s approach to seek 25% employment floorspace with only 75% market rent on top. Relating valuable workspace to rent is only one way of looking at the value of the site, and where sites are cleared and February 2015 gva.co.uk 20

21 employment re-provided, it would be unrealistic to think that rents could be benchmarked against previous uses Also a low cost rent model may be unenforceable given the majority of workspaces provide space on an inclusive basis rather than a /sqm. Indeed, newer co-working models are even more complex, letting space to businesses on a membership basis which, generally, does not equate to a specific unit or floorspace provision. As such, whilst the Glossary definition is clear in its aim in terms of the financial requirement, it is not actually fit for purpose or based on a clear understanding of how the workspace market operates. It also mis-understands how capable the businesses may be of paying rent when it is all inclusive. It fails to pick up the relationship between total occupancy cost and the businesses total revenue A further challenge to the definition will be in the use of rather generic identification of creative and cultural sectors. Whilst the intention of the policy is honourable this definition is too loose to be enforceable as the creative and cultural sectors could encompass a wide range of mainstream economic activity which is perfectly capable of paying market rents. The policy sets no thresholds to judge how it should be applied in relation to specific businesses and will led to a complex and onerous vetting procedure which, at present, it is not clear who would take responsibility for monitoring its enforcement or identifying the vetting criteria We would also question the need for the reduced rent model if the LLDC is confident in its forecasts for demand for the scale of space it is allocating. A robust allocation would be predicated on delivering a portfolio and scale of space that is attuned to local market demand, as such incentives would not likely be required to create demand. February 2015 gva.co.uk 21

22 Matter 3: Housing Whether the Local Plan, notably Section 5, is consistent with the National Planning Policy Framework s aims to boost significantly the supply of housing and deliver a choice of high quality homes to meet the needs of different population groups; whether the Local Plan is in general conformity with the London Plan and Draft Further Alterations to it. 4.1 There is ever-increasing emphasis on providing housing for providing housing in London. 4.2 The recently examined London Plan identifies the ever increasing impetus required on London Boroughs to deliver housing, with demand outstripping supply year on year. 4.3 This is reflective in the Further Alterations to the London Plan, which requires a minimum combined target for the Olympic Boroughs including LLLDC, of 98,578 homes. This compares within the London Plan 2011 target, which set out a minimum of 73,050 homes. 4.4 The Further Alterations to the London Plan (FALP) (2014), provides increased emphasis on housing delivery to address the backlog of supply (new Paragraph 3.16b), particularly in Opportunity Areas. 4.5 It is expected that a more flexible policy test for the release of employment for mixed use residential led development, including at Marshgate Business Centre, can assist in achieving the required level of housing growth, with the benefit of unlocking the scheme for redevelopment but only subject to viability based on an appropriate mix of uses that allows for the site to come forward for redevelopment. 4.6 In this respect, the LLDC Local Plan should reflect the new priority focus of housing in the Further Alterations to the London Plan with support from accurate data. The relevant revised sections on housing delivery are included below, taken from the Further Alterations to the London Plan demonstrating this point: 4.7 Para. 3.16b - the central projection in the SHMA indicates that London will require between approximately 49,000 ( ) and 62,000 ( ) more homes a year. This range incorporates different levels of population change over the period, the time taken to address current need (backlog) and the anticipated under delivery between 2011 and The figure of 49,000 additional homes a year February 2015 gva.co.uk 22

23 provides the basis for the detailed housing need figures set out in this Plan. In light of the projected higher need, especially at the start of the plan period, this figure should be regarded as a minimum 4.8 Para London is part of a global and national housing market as well as having its own, more local and acute housing need which place a unique challenge in reducing the gap between need and supply. Boroughs should use their housing supply targets in Table 3.1 as minima, augmented with additional housing capacity to reduce the gap between local and strategic housing need and supply. 4.9 Para town centres, opportunity and intensification areas (Policy 2.13), and other large sites could provide a significant increment to housing supply. In addition, the process of managing the release of surplus industrial land should focus on bringing forward areas with good public transport accessibility which will be particularly appropriate for high density It is recommended the Local Plan is revised to reflect the positive approach offered by the London Plan in respect of residential development and mix of uses. How can the Local Plan be made sound? 4.11 We have suggested amendments in Appendix 5. The Inspector s Report should also clarify the weight given to the Pudding Mill Land Use and Design Framework. Question 1- Bearing in mind the recent Inspector s report following the Further Alterations to the London Plan examination (see paragraphs of that report), is there any case for the LLDC to have carried out its own strategic housing market assessment and calculated its own objectively assessed need for housing? 4.12 The requirement for housing is clear across London The London Plan s SHMAA is sufficient, however LLDC needs to demonstrate its supply and show that it is seeking to boost housing supply significantly, in line with the comments within the Introduction above. This includes removing the blanket restriction for building heights in Policy SA4.3. Question 2 - The Housing Position Statement, LD/28, and Background Paper TBP/04, contain much useful information. Should the Local Plan include more detail about the derivation of numbers, perhaps explaining how its target relates to the needs and requirements of the boroughs which make up the LLDC area? February 2015 gva.co.uk 23

24 4.14 The evidence base should be updated where relevant including sites such as Marshgate within the housing supply. The LLDC s Local Plan should be more transparent about how it is allocating its needs and supply. Question 4- Paragraph 5.1 and Objective 2 of the Local Plan refer to building about or approximately 24,000 new homes by The table of minor amendments and corrections, LD/26, indicates a change in Objective 1 to refer to more than 24,000. Presumably a change to Objective 2 is intended? Would this make the plan appropriately more positive and consistent with the text in paragraph 5.3? 4.15 We highlighted previous discrepancies in the evidence base and the minimum requirement to meet London Plan targets (and given that Inspectors Report for FALP sets out these are a minimum). The Objective should be changed accordingly which would also be in accordance with the comments provided by the GLA. Question 5- - Is there sufficient consistency and clarity in the figures for new housing provision over the plan period? Policy SP.2 seeks to deliver in excess of 1,471 units per annum (totalling 23,536 over the period ), which reflects the monitoring targets for in Table 3.1 of the FALP. However, footnote 21 on Page 43 of the Local Plan gives figures of 22,065 and 25, Our response is the same as Question 4, we have highlighted previous discrepancies within the evidence base and minimum requirement to meet London Plan targets (and given that Inspectors Report for FALP sets out these are a minimum). Question 7- The NPPF expects Local Planning Authorities to identify and update annually a supply of specific deliverable sites to provide 5 years worth of housing etc. (paragraph 47). Is the Local Plan consistent with the NPPF on 5 year supply (see TBP/04)? Is there any substantive evidence to support use of a 20% instead of a 5% buffer? 4.17 The plan is currently struggling to meet its five per cent buffer on a rolling 5 year basis beyond the first five years of the plan. We have highlighted previous discrepancies in the evidence base and the minimum requirement to meet London Plan targets (and given that Inspectors Report for FALP sets out these are a minimum). Therefore we consider that in order to meet the tests of soundness it should be ensured that discrepancies within the evidence base are rectified Furthermore, it is expected that a more flexible policy test for the release of employment land (Policy B.1) for mixed use residential led development, including at Marshgate Business Centre, can assist in achieving the required level of housing February 2015 gva.co.uk 24