The Highams Park Planning Group (HPPG) has responded to the Council’s consultation on the new Local Plan. In our response we have expressed our concerns that what the Council is proposing will, over time, completely change the character of Highams Park town centre and the streets radiating out from the town centre through intensification of development.
You can read our full response by clicking on the link below but we have included a brief summary on this page, which you may wish to read before reading our letter which is rather long and technical in places.
Click here to read HPPG’s response to the consultation: HPPG Response to LBWF Shaping The Borough 2020-2035 Regulation 19 Consultation – 27 Nov 2020
At the bottom of this page we have provided details of how you can read the Council’s consultation document and how to respond.
In our response we have opposed the number of new homes the Council is proposing to build in Highams Park and some of the locations where they are proposing to build them. We found the Local Plan to be vague on detail. However, it does strongly infer a target of more than 400 homes to be built on 2 strategic/key sites and 11 “Site Opportunity Locations” and such other windfall sites that maybe become available (i.e. additional floors on existing blocks of flats, etc).
The Site Opportunity Locations in the Council’s Local Plan includes Highams Park Station & Car Park and building on some garage sites at the end of people’s back gardens across the Highams Park Plan Area.
The potential sites the Council have identified for new housing in Highams Park are listed below (we have marked with a red * those sites that we believe are unsuitable for new housing). Maps of sites 3 to 13 are included at the bottom of this page:
- 472-510 Larkshall Road ; being the buildings from the Shell Garage up to the railway crossing. This site is included in the Council’s LP2 Site Allocations consultation as site SA62 and provides for 145 new homes.
- The Shell Garage at 470 Larkshall Road; This site is included in the Council’s LP2 Site Allocations consultation as site SA63 and provides for 10 new homes.
- BLR_151 – Highams Park Station and Car Park *; this site is not included in the LP2 Site Allocations consultation and no targets for housing have been suggested in the SLP.
- BLR_110 – 163 Centre Way; – Roberts Hall off Wadham Road to the rear of The Wadham Café and backing on to the grounds of the Peter May Centre. The site is currently occupied by a children’s day nursery.
- BLR_141 – Garages off Hale End Road *; the garages and garden to the rear of Swallow Court backing on to the gardens of 29-34 Beech Hall Crescent, 393-397 Hale End Road and 1-9 Forster Close.
- BLR_142 – County Hotel (SSA57); in Oak Hill (now known as the Epping Forest Hotel)
- BLR_143 – Garages off The Avenue *; backing on to the gardens of 121 to 129 The Avenue & 48 Richmond Crescent
- BLR_144 – 25. Wrigley Close (Adjacent to 85 The Avenue) *; garages backing on to the gardens of 8-14 Richmond Avenue, 2 Richmond Crescent, 75 & 85 The Avenue.
- BLR_147 – Garages between Castle Avenue and Handsworth Avenue *; comprised of two parcels of land:
- Garages to the rear of Briarview Court, Handsworth Avenue backing on to the gardens of 67 to 87 Handsworth Avenue and 22 to 28 Castle Avenue.
- Garages to the rear of Hedgemoor Court and Hewitt House, Castle Avenue backing on to the gardens of 67 to 87 Handsworth Avenue and 22 to 28 Castle Avenue.
- BLR R_148 – Garages off Richmond Avenue *; behind 3 and 5 Richmond Avenue, Marien Court and 49 to 57 The Avenue, backing on to the railway line.
- BLR_150 – Garages off Castle Avenue *; to the rear of the flats in Wentworth House, Bailey Court and 39 Castle Avenue. Backing on to the gardens of 35 Castle Avenue, 2-8 Falmouth Avenue and 106 to 104 The Avenue.
- BLR_152 – Garages to rear of Clivedon Rd *; backing on to the gardens of 1 to 27 Clivedon Road, 84 to 116 Forest Glade and 8 to 24 Sheredan Road.
- BLR_156 – Larkshall Timber Yard; 192 Larkshall Road. Currently in use as a garage repair and car wash and backs on to 194 and 196 Larkshall Road, St Anne’s Church and the railway line.
Note 1: The Site Opportunity Locations were not included in the Council’s Site Allocations Consultation (still running), so you may be surprised to see them in the Local Plan.
Note 2: Inclusion in the Local Plan as a Site Opportunity Location doesn’t mean these sites will be built on but it does give a green light from the Council for development on those sites.
We appreciate that people need affordable homes to live in and we support limited development on 5 of the above sites, however, we believe the other 8 sites the Council has included as Site Opportunity Locations in Highams Park are unsuitable for intensification without destroying what people love about the area.
We have proposed other sites where the Council could build new housing in Highams Park without significantly damaging the character of the area. We put these forward in their previous consultation round in 2019 and at a workshop in January 2020 consultation but they didn’t take them up in the submission version of the Local Plan. We have submitted our suggested Potential Sites for Development again in our response to the Council’s LP2 Site Allocations consultation (you can view these sites by clicking on this link: HPPG’s suggested Potential Sites for Development
How to respond to the Council’s Consultation
You may, or may not, agree with all the content of our letter, but the outcome of this consultation will be very important to the look and feel of Highams Park in the coming years, so we urge you to respond to the Council with your views before the closing date on 14th December 2020.
You can respond by email to: planning.policy@walthamforest.gov.uk
If you respond by email, please include this header in the subject line “Shaping the Borough Waltham Forest Local Plan (LP1) 2020-2035
Proposed Submission Document (Regulation 19) October 2020″
And, please include your name and address at the bottom of your email after your comments.
As your response will be reviewed by the Planning Inspector in accordance with the Regulation 19 requirements, you need to state what parts of the Local Plan you think are unsound or where there has been a failure to cooperate by the Council.
These points are highlighted in our letter, so you may wish to comment as follows:
“I have reviewed the letter submitted by the Highams Park Planning Group and agree with the points highlighted as unsound or failure to cooperate”
If you wish to respond in more detail, we have included at the bottom of this page a summary of the key points from our letter. (Note: the site reference numbers on this page and in our letter are our numbering not the Council’s so, if you refer to any of the sites it is best to say the names of the sites e.g. Highams Park Station & Car Park)
If you prefer, you can reply by reading the consultation document on the Council’s consultation portal and typing in your comments. The link to the Council’s consultation portal is: LBWF LP1 Local Plan Consultation
If you have trouble navigating the Council’s consultation portal, you can download a copy of the consultation document (draft Local Plan) on the link below and respond by email.
Click here to view the Council’s draft Local Plan: Council’s Draft Local Plan – October 2020
If you are busy it is acceptable to just email the Council stating that you agree with, and support, HPPG’s letter to the Council dated 27th November 2020. If you wish to respond in more detail we have included below a summary of the key points in our letter.
Summary of Key Points in HPPG Letter:
- The submission version of the Local Plan (“SLP”) is lacking in clear detail as to where development will take place in the HP Plan Area.
- Swingeing changes to the character of the HP Plan Area are both unwelcome and unwanted and do not accord with the SLP’s stated objective to “Ensure Waltham Forest’s network of cultural, inclusive and sustainable neighbourhoods are safe and diverse, celebrating their locally distinctive character and heritage”.
- The target of 400 homes (and most likely more) is an unsustainable target, as the HP Plan Area has already been subject to significant development over the past ten years and most of the remaining viable sites have been taken up.
- The site suggestions submitted by HPPG in the first round of consultation in 2019 and in this LP2 Site Allocations should be considered as alternative locations to meet housing growth in the HP Plan Area.
- The criteria used to the select the Opportunity Site Locations (Figure 4.1) in the HP Plan Area are not provided. It is our assessment that most of the sites are not suitable for inclusion as Site Opportunity Locations in the SLP.
- The references to Site Opportunity Locations and the Brownfield Land Register need to be more clearly articulated in the SLP and the procedure by which sites will be added to that register; including whether it is the intention to add some or all of the Opportunity Site Locations to the register over time.
- Sites 5, 6, 7 ,8, 9,10, 11 and 12 should not be included in the SLP, as they are not likely to become available or cannot be feasibly developed. It is also important to note that none of these sites are street facing and have limited access to the surrounding streets which means these sites would essentially be back garden developments! We do not believe that such sites will provide the appropriate amenity space or the high-quality homes and environment that the Council aspires to for incoming and existing residents in the SLP.
- In view of the importance of the Highams Park Station building to the character of Highams Park District Centre, Site 3 should also be removed from the Site Opportunity Locations in Figure 4.1 and added to the Council’s list of locally significant buildings (and our other suggestions also considered).
- We suggest that the Council undertakes a thorough review of the uses throughout area BEA 1 and that some plots are taken out and allocated to housing.
- Some parts of area BEA 1 could be better utilised for employment purposes.
- Given that we are the Neighbourhood Development Forum for the HP Plan Area, we are very disappointed with the almost total lack of engagement that the Council has undertaken with us for those parts of the SLP that relate to the HP Plan Area.
You can view a map of each site below:
(note: apart from Figure 4.1 these maps are not included in the Local Plan consultation documents we requested them from the Council for our review)
Extract from Fig.4.1 of the Local Plan of Site Opportunity Locations in HP Plan Area
- 472-510 Larkshall Road (no map)
- The Shell Garage at 470 Larkshall Road (no map)
- BLR_151 – Highams Park Station and Car Park
- BLR_110 – 163 Centre Way
- BLR_141 – Garages off Hale End Road
- BLR_142 – County Hotel (SSA57)
- BLR_143 – Garages off The Avenue
- BLR_144 – 25. Wrigley Close (Adjacent to 85 The Avenue)
- BLR_147 – Garages between Castle Avenue and Handsworth Avenue
- BLR R_148 – Garages off Richmond Avenue
- BLR_150 – Garages off Castle Avenue
- BLR_152 – Garages to rear of Clivedon Rd
- BLR_156 – Larkshall Timber Yard