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HOUNSLOW LOCAL PLAN EXAMINATION
http://www.hounslow.gov.uk/localplan/ldf_examinations_public.htm
SESSION 11 – SITE ALLOCATIONS (Part 1)(Chapter 12)
Inspector’s Agenda with Matters, Issues, and Questions
[The attention of participants in the hearing is drawn to the
Procedural Guidance Notes]
1.
GENERAL ISSUES
1.1
Chapter 12 of the Plan includes some 71 site allocations. Brief descriptive
details are included for each site together with an Ordnance Survey based plan
extract at a larger scale than would be shown on the policies map.
1.2
The site allocation descriptions are very brief and do not always correspond to
uses that are recognised in the Town and Country Planning (Use Classes)
Order (eg ‘mixed use’, ‘heritage asset’, ‘commercial use’, ‘employment’). The
Site Allocations Topic Paper IMP02 uses more conventional terms such as
‘retail’ and ‘office’ when estimating site capacity.
Qn1a.
Do the allocation descriptions provide sufficient certainty as
to what use is proposed or do they require further definition?
Qn1b.
What uses could be included in ‘commercial use’? and
would they include ‘town centre’ uses (as defined in the National
Planning Policy Framework) that are not in town centres?
Qn1c.
Is allocation as a ‘heritage asset’ intended to create a
designated heritage asset and is that adequately justified by
evidence?
1.3
None of the allocations include any estimate of the amount of development
that would be provided or how the site would contribute to meeting the
development needs that are identified elsewhere in the Plan eg for housing,
retail floorspace or offices. In places there is a reference that capacity has
been identified in the London SHLAA 2013 but no figures are included.
However estimated numbers of residential units are included for each site in
the IMP02 Site Allocations Topic Paper.
Qn1d.
Should estimates of the capacity of each allocation be
included in the Local Plan to demonstrate whether the provision will
address identified needs and to facilitate monitoring?
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Qn1e.
If the capacity figures are described as estimates would
that still allow for flexible interpretation at the planning application
stage?
1.4
On mixed uses sites the Local Plan allocations generally do not estimate what
proportion of a site would be put to which use. The Site Allocations Topic
Paper IMP02 includes an appendix with further information on the likely split of
uses on each site as well as other information. However it appears to be
intended that some sites which are described as mixed use (eg school and
residential) may be developed entirely for one or other purpose as discussed
at Session 10.
Qn1f.
Should the allocations include further clarification as to
which sites may be developed for mixed or alternative uses and how
uses would be accorded priority eg by reference to another plan
policy?
Qn1g.
What, if any, would be the status of the Site Allocations
Topic Paper IMP02 for development management on the allocated
sites and would any further policy or guidance document be published
that would allow public consultation on the form of development?
1.5
Some allocations refer to ‘an appropriate retention of employment use’.
Qn1h.
What policies could be applied to determine what would be
‘appropriate’?
1.6
An indication is given for each site as to the phasing of development.
Qn1i.
How has development been allocated to each phase?
2.
SITE SPECIFIC ISSUES
2.1
Representations on the Submission version of the Local Plan (Document LP01b)
caused the Council to make a number of detailed amendments to the text
relating to the allocations as set out in Document LP56.
2.2
Further Representations were submitted in response to the Schedule of
Changes consultation on the changes made in Document LP56. In its response
Document LP61 the Council has agreed to support some changes suggested by
Representors, particularly in relation to matters of fact.
2.3
The Council has not agreed to other changes proposed by Representors during
the Minor Changes consultation. Where those representations did not relate to
the changes that had been subject to the consultation the representations were
not duly made and thus do not create a right to appear at the hearing.
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2.4
Those Representors who support allocations and do not seek changes are not
entitled to appear at the hearing. However the Council may choose to invite
them to appear as a Council witness should changes to the allocation be sought
by other Representors.
2.5
The following issues in respect of site specific matters have been raised by
Representors seeking a change to the allocation and who have asked to appear
at the hearing.
Chiswick
Site Allocation 03 – Empire House
2.6
3016 Chiswick High Road Action Group objected to the submission plan’s
reference to ‘large plate retail development’. That was removed in the
Document LP56 Minor Changes which now refers instead to ‘improving the
quality of retail units’.
Qn2a.
Has the wording amendment in relation to retail
development suitably addressed the Representor’s concerns?
2.7
The group also considers the site unsuitable for tall buildings. However the
allocation does not specify any height of building and no change to the
allocation has been requested.
Site Allocation 05 – Wheatstone House
2.8
The allocation is for ‘mixed use - residential and commercial’ but 2189 Telereal
Trillium seeks an amendment to ‘residential-led mixed use’. It is suggested
that the loss of employment use has previously been accepted.
Qn2b.
Why would this requested change be necessary to
soundness?
Qn2c.
What uses would be within the scope of commercial use?
Hounslow
Site Allocation 39 – High Street Quarter
2.9
Legal and General (1177) consider that the residential element should have
flexibility with regard to housing standards and affordable housing provision.
They also state that the allocation should be amended to reflect the existing
Phase 1 of the Blenheim Centre to the north, and integrate the Blenheim
Centre with the High Street. The Council responds that housing development
will be expected to meet the standards set out in the Sustainable Communities
chapter, and any departure from standards will need to be justified. In
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addition, the allocation refers to integrating the High Street Quarter and High
Street - the Blenheim Centre will be considered in this context.
Qn2d.
Does the Representor have any comment on the
Council’s response?
Site Allocation 49 – Hanworth Road
2.10
This 1.1ha vacant site is allocated for ‘Housing and Education – Proposed Use
Residential and Education’. The Education Topic paper (CI04) indicates that
the site could accommodate a 1FE Secondary School by a free school provider.
The Site Allocations Topic Paper indicates that it has a capacity for 48
dwellings. The Policy CI2 and IMP1 criteria for development on sites with dual
use allocations will be discussed in Hearing Session 10.
2.11
TfL Property Development (179) Transport for London Property Development
objects to the site being allocated for education use, noting that the final
version of the Sequential Assessment of Potential School Sites (2014) became
available at a late stage of the plan-making process, and therefore claims it
has not been properly considered. The Council responds that the Sequential
Assessment for Potential School Sites informed the identification of sites
suitable for an education allocation in the Local Plan Proposed Submission; and
was made available during the consultation period for this document. This is to
be subject to regular reviews to ensure that the ongoing school place planning
strategy is based upon up to date information.
Qn2e.
When was the Sequential Assessment made available?
Qn2f.
Does the Representor have any comment on the Council’s
response?
Site Allocation 50 – Hounslow Bus Garage
2.12
This 1.14ha site is proposed to be allocated for a retained bus interchange and
a retained bus garage or housing. London Utd Busways Ltd (318) wish that the
allocation makes clear that redevelopment could only occur if the garage was
relocated to a site nearby (within a one mile radius of Hounslow town centre).
In addition, they want it made clear that agreement regarding any relocation is
needed with London United as well as TfL. In Document LP56 the Council
made a Minor Change in justification to "can be secured at an appropriate site
in the locality (in terms of the bus garage this means within a one mile radius
of Hounslow town centre) with the agreement of TfL and the bus garage
owner, London United Busways Limited, TfL's agreement, then residential
development will be acceptable".
Qn2g.
Has a site been identified for the relocation of the bus
garage within 1 mile and, if not, how deliverable is the residential
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allocation for 285 houses as estimated in the Site Allocations Topic
Paper IMP02
Cranford & Heston
Site Allocation 65 – Master Robert Hotel
2.13
This existing hotel is a mainly single storey building with the main facilities
in a building fronting the main road and motel style rooms to the rear. It is
not located in or adjoin a town centre. The allocation first proposed the
redevelopment of the entire site for housing
2.14
SB Hotel Group (3249) requested that the allocation be amended to
promote a mixed use scheme with ‘reprovision’ of the existing hotel at the
front of the site, with housing to the rear. They say that a housing only
development is not deliverable. The Council responded by amending the
Allocation to : Leisure and Housing Proposed use: Hotel and Residential
Justification: This site has been identified through The London SHLAA 2013
as it has a potential housing capacity during the plan period. The hotel
should be ‘retained’ where the site fronts onto the A4.
Phasing: 2021-30 2015-30.
Qn2h.
Is the difference between ‘reprovision’ and ‘retention’
significant given the Local Plan policy on the location of new hotels
and tall buildings?
Qn2i
How would the Representor envisage the reprovision
of the hotel and would this involve redevelopment as a taller
building?
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