planning report PDU/LDF01/LDD04/01
Barking and Dagenham Council
Barking Town Centre Area Action Plan Development Plan Document
Preferred Options Consultation
1 August 2008
Town & Country Planning Act 1990 (as amended); Greater London
Authority Act 1999; Planning and Compulsory Purchase Act 2004, Planning
and Compulsory Purchase Act 2004, Town and Country Planning (Local
Development) (England) Regulations 2004
Strategic issues
Affordable housing: the 50% target is welcomed and the 60%:40% split is acceptable.
The provision of 40% family housing is supported.
Land use - Barking plays a strategic role not just in the Thames Gateway but also in
London and this should be reflected in Objective 1. Gascoigne Road & Hertford Road
Business Estates need to be identified in Fig 13.1 of the indicative map.
Climate change and mitigation: The Council should include a requirement to include
energy efficiency measures. The delivery of the district-heating infrastructure should be
explicitly stated and encouraged. The London Plan renewable energy target should also
be reflected in the AAP.
Transport - the following key issues and those mentioned in the report need to be
addressed in the Barking Town Centre AAP, from land use transport perspectives:
- The provision of terminating facilities for ELT services at Barking station.
- Bus services provision.
- Financial contribution to transport.
- Freight and servicing issues.
Recommendation
That the Mayor agrees that the comments set out in this report and attached as Appendix Three
should be submitted to Barking and Dagenham Council as the GLA response to the Barking Town
Centre AAP Preferred Options consultation.
Purpose
1 To assist the Mayor in making his representations to Barking and Dagenham Council’s
consultation on the Preferred Options for the Barking Town Centre Area Action Plan
1
Development Plan Document (DPD), which form part of Barking and Dagenham’s Local
Development Framework. The consultation period ends on 11 August 2008.
2 The Mayor of London’s comments on this document will be made available on the GLA
website www.london.gov.uk.
Background
3 The Planning and Compulsory Purchase Act 2004 (“the Act”) introduced a new system
of preparing development plans. This requires Boroughs to progressively replace existing
Unitary Development Plans with a portfolio of Local Development Documents (LDDs) that will
collectively form the Local Development Framework (LDF) for each of the Boroughs. The LDF
together with the London Plan provides the essential framework for planning at the Borough
level. The “development plan” in London for the purposes of section 38(6) of the Act is:
• The London Plan (Regional Spatial Strategy), and
• DPDs produced by the Boroughs (and saved UDP policies in transitional period).
4 There are two types of Local Development Documents: firstly, Development Plan
Documents, those spatial planning documents that are subject to a statutory adoption process
and Examinations and have development plan status. Examples of DPDs include Core
Strategies, Site Allocations, Proposals Map and Development Control Policies, and Area Action
Plans.
5 Secondly, there are Supplementary Planning Documents. These provide supplementary
guidance on policies and proposals in DPDs. They do not form part of the development plan
and are not subject to Examinations.
6 Barking and Dagenham’s Local Development Scheme identifies five DPDs that will be
produced. They are Core Strategy, Borough Wide Development Policies, Site Specific
Allocations, Barking Town Centre AAP and Proposals Map. In addition, a number of
Supplementary Planning Documents are proposed covering a range of topics.
The Mayor’s role
7 All LDDs must be in general conformity with the London Plan, in accordance with
Section 24(1)(b) of the Act. This requirement is also a key test of the soundness of the plan.
The Mayor welcomes early engagement with boroughs as LDDs progress through production
stages and will formally issue his opinion on general conformity at the submission stage in line
with Regulation 30(1) of the Town and Country Planning (Local Development) (England)
Regulations 2004 (“the Regulations”) and Section 24(4)(a) of the Act.
8 Regulation 26 of the Regulations requires consultation at the Preferred Options stage
of LDD production. The Mayoral representations made to Barking and Dagenham’s Council at
this stage will not go forward to the Examination. It is envisaged that the Borough Council and
GLA officers will meet to take forward the issues raised by the Mayor before the next formal
consultation stage, (Submission to the Secretary of State) so that general conformity with the
London Plan can be achieved and the DPDs are sound before the Examination commences.
2
Strategic issues
9 The draft AAP contains 24 policy issues, which fall under one of the eight overarching
objectives. However, this report concentrates only on strategic issues. More detailed comment
is included in the attached table (Appendix 3).
Housing
Housing supply
10 It is welcomed that the preferred option 1 (BTC 11: Housing Supply) sets a target of
delivering a minimum of 6,180 additional (net) new homes in the Barking Town Centre area
between 2007/08 and 2016/17. This target will assist the Council in the delivery of its overall
housing target of 11,900 additional homes, in line with the London Plan. This overall target has
been included within the Council’s Core Strategy preferred options.
Housing Mix
11 It is noted that the preferred option 1 (BTC 12: Housing Mix) proposes the target mix of
40% family housing (three and four bed). This is welcomed and is in line with the Core Strategy
preferred options.
Affordable housing
12 The preferred option 1 (BTC 13a: Affordable Housing target) states, “Ensure no loss of
social housing in estate renewal schemes and apply the Mayor’s 50% target for affordable
housing across the Plan area as a whole. This figure would apply to the number of additional
(net) homes provided.” London Plan Policy 3A.10 requires borough councils to seek the
maximum reasonable amount of affordable housing when negotiating on individual private
residential and mix-use schemes. In doing so, each council should have regard to its own overall
target for the amount of affordable housing provision. In this circumstance, the preferred
option 1, which applies the Mayor’s target of 50% is welcomed.
13 It is noted that the preferred option 2 (BTC 13b: Affordable Housing tenure split)
adopts a specific AAP target that of new affordable housing, 60% should be socially rented and
40% should be intermediate. Whilst the 60%:40% split does not conform with the London Plan
Policy 3A.9, the need for flexibility in setting these targets is recognised by the London Plan
and the GLA recongnises the current high proportion of socially rented housing in the Barking
Town Centre plan area. In addition, Policy 3A.10 of the London Plan encourages councils to
have regard to the need to encourage rather than restrain residential development, and to the
individual circumstances of the site. Targets should be applied flexibly, taking account of
individual site costs, the availability of public subsidy and other scheme requirements. The need
to create mixed and balanced communities is also acknowledged. As a result of this, the
60%:40% split is acceptable under these special circumstances.
Climate change and mitigation
14 BTC 22: Low Carbon Development: Given that the Council has done a number of studies
under the Energy Action Area programme on Barking Town Centre, the focus of this section
should be on the implementation of a low carbon district-heating network in the town centre.
Although this is implied in the 32% carbon dioxide reduction target for new development,
given the complexities associated with bringing forward district heating infrastructure in a
regeneration area such as Barking, the Council’s strategic plan for low carbon district heating
3
should be outlined in the AAP alongside requirements for applicants to contribute to its
implementation. Once the strategic objective of low carbon district heating is established, the
preferred option should better reflect the three elements of the London Plan energy hierarchy.
The London Plan’s energy hierarchy
15 None of the four preferred options fully reflect the London Plan’s energy hierarchy, as
they do not include any reference to reducing carbon dioxide emissions through energy
efficiency measures, and as such the AAP is not in general conformity with the London Plan.
Options 2 and 3 are options on renewable energy and option 4 is on renewable energy and
district heating.
16 London Plan Policy 4A.1 states that: “The following hierarchy will be used to assess
applications:
Using less energy, in particular by adopting sustainable design and construction
measures (Policy 4A.3)
Supplying energy efficiently, in particular by prioritising decentralised energy
generation (Policy 4A.6), and
Using renewable energy (Policy 4A.7).”
17 The GLA considers that all three elements of the hierarchy should be reflected in the
preferred option.
Energy efficiency
18 Although the document has a section on sustainable design and construction, the issue
of energy efficiency should be brought out clearly in the low carbon development section in
order to fully reflect the energy hierarchy described above.
19 The 32% carbon dioxide reduction target set for the Energy Action Area does not
include a requirement for developments to reduce energy demand through energy efficiency
measures (22% carbon dioxide reduction comes from connecting to a future low carbon district
heating network and 10% carbon dioxide reduction from renewable energy systems).
20 The London Plan adopts a ‘whole energy’ approach meaning that all energy uses, and
not just those covered by Building Regulations, should be calculated when setting carbon
reduction targets. This should be reflected in the AAP and the Council’s other local
development plan documents.
21 The AAP also provides an opportunity to state how existing buildings in Barking can be
retrofitted to reduce their energy consumption. While boroughs have significant control over
new buildings, there are significant savings to be made through improving the energy efficiency
and retrofitting renewable energy technologies to existing buildings. The Council may wish to
consider policies around the energy efficiency of existing buildings which apply for planning
permission, for example for extensions, in other parts of their LDF.
District heating infrastructure and energy efficient supply
22 The GLA is familiar with the Council’s work, as part of the Energy Action Area
programme, on a town centre wide low carbon district-heating network. This work is in line with
London Plan policy 4A.5 and is commended. However, we consider the Council’s plans and
requirements for applicants in the town centre should be more explicitly stated.
4
23 The work on the district heating network done by the Council should be referred to,
specifically the document Establishing a Community Heating Network in Barking Town Centre.
The four development areas identified in this study (pg 14) as well as the individual building in
area five and six should be referenced. The Counci’s strategic plan for connecting developments
within each of the four development areas should be set out in order to explain the Council’s
intentions and help developers understand the role they are expected to play.
24 The Council’s existing and planned activities to help deliver the connections within the
four development areas should be explained so that appplicants know what assitance is
available.
25 The longer term strategy of connecting these separate four development areas and
individual buildings in areas five and six into a town-centre wide network should be explained,
with reference to the Barking Power Station heat off-take project or alternative plans the
Council may have for low carbon energy supply in the town centre.
26 The preferred option requires new developments to be compatible with a town centre
wide combined heat and power (CHP) system. This implies a town centre CHP is planned. If this
is the case these plans should be explained and land identified for this plant. Otherwise the
wording should refer to a town centre district heating system supplied by low carbon heat. The
source of the low carbon heat should also be identified.
27 The detailed technical guidance available on the Council’s website for developers,
should also be referenced to ensure new developments are compatible with the wider district
heating plans for the town centre.
28 In terms of efficient energy supply in the four development areas and buildings in areas
five and six (CHP/CCHP including district heating and cooling), the energy hierarchy in the
London Plan should be applied until the development of a low carbon district-heating network
in the town centre is more advanced.
29 The points raised by the Council in relation to the reduction of carbon dioxide emissions
by 20% from on-site renewable energy systems are noted. However, The London Plan
renewable energy policy 4A.7 should be reflected in the Area Action Plan in the context of a)
the energy hierarchy and b) compatibility with the low carbon district heating scheme planned.
As it stands the Area Action Plan is not in general conformity with the London Plan with regard
to renewable energy policy.
Land use
30 Paragraphs 2.5-2.7 reflect the role of Barking in London's town centre network, which
is supported. Objective 1 reflects the town centre's strategic role in the Thames Gateway.
Barking plays a strategic role not just in the Thames Gateway but also in London (as indicated
in the above paragraphs) and this should be reflected also in objective 1. It is suggested that
objective 1 ought to read: "…and fulfil its strategic role within Thames Gateway and the
London town centre network".
31 The GLA supports preferred option 2 (BTC1 The shopping role of Barking Town Centre).
encourages additional shopping in the Town Centre in line with the 2004 Retail and Leisure
Capacity Study so that, whilst maintaining its local distinctiveness, it can better perform its
Major Centre role.
5
32 The GLA welcomes and supports the policy statements for hotels and the evening
economy. Gascoigne Road and Hertford Road Business Estates are designated as Locally
Significant Industrial Sites within the AAP. It would be helpful to see these sites identified in
Figure 13.1.
Open space and biodiversity
33 The environment section seeks to address the natural and built environment and the
accessibility, connectivity and quality of parks and the wider rural resources, including, where
relevant, their biodiversity importance. Whilst the included policy issues are supported, there
are a number of gaps that the GLA consider should be addressed under this section. These
include dealing with contaminated land, hazardous substances and incorporating biodiversity
into developments.
34 The preferred option for BTC 19a which states, “Protect and improve the provision of
open spaces within the action plan area through protecting existing space, seeking additional
open space through the S106 agreements” is welcomed.
35 The preferred option BTC 20 which states, “Provide more facilities and undertake public
realm improvements” and the preferred option for nature conservation and biodiversity BTC 21
that states, “ Take a more flexible approach” are acceptable as they are more aligned to the
strategic policies of the London Plan.
36 The preferred option of the AAP should include the need to provide facilities for play
and recreation areas.
Waste management
37 Barking and Dagenham Council should ensure that all applicants minimise the level of
waste generated, in accordance with Chapter 4B of the Municipal Waste Management Strategy,
and by following the principles in the Sustainable Design and Construction Supplementary
Planning Guidance. This does not replace the Barking Code but should complement it
particularly with respect to waste.
38 It is recommended that the preferred option 1 is reworded as: “In implementing public
realm improvements developers should have regard to the Barking Code, the Sustainable Design
and Construction SPG and Policy BR 4: Sustainable Construction in the Borough Wide
Development Policies DPD”.
39 Barking and Dagenham Council should ensure that the AAP sets targets in line with the
London Plan target to achieve recycling and re-use levels in construction, excavation and
demolition waste of 95% by 2020, as set out in Policy 4A.1.
40 The GLA supports the Council’s commitment to sustainable waste management and the
promotion of recycling aimed at ensuring the infrastructure to support it (e.g. recycling
centres/bottle banks and the collection/disposal of street market waste) are provided in ways
that do not prejudice the quality of the public realm. There is however no policy statement to
support this. DPD policies should require the provision of suitable waste and recycling storage
in all new developments in order to exceed the recycling or composting levels in municipal
waste of 35 per cent by 2010, 45 percent by 2015 and 70 per cent recycling and composting of
commercial and industrial waste by 2020.
6
41 Option 4 of the issues and options report requires new developments to be compatible
with a combined heat and power (CHP) system that utilises the waste produced from the
Jenkins Lane waste facility as a way of delivering CHP to new developments, which the GLA
strongly supported. This has not been addressed in the preferred options report. It is not clear
whether this approach being taken on board. More clarification is therefore required.
Transport for London
42 TfL welcomes the proposed Barking Town Centre Area Action Plan preferred options
document. However, TfL would like to highlight the importance of further discussions regarding
the following points, which should be addressed in the submission document. A full set of
detailed comments on the document is attached in Appendix 3 to this report.
43 TfL suggests that the document puts more emphasis on increasing the public transport
accessibility of some areas within the town centre. In addition, there is a concern that no
reference to the provision of terminating facilities for ELT services at Barking station is included
in the transport draft policy statement 12 of the document. TfL also wishes to make detailed
comments regarding the ELT proposals, which are attached in Appendix 3 to this report.
44 TfL encourages the Council to give more consideration to freight and servicing issues
and improvements to pedestrian and cycle environments in the town centre.
45 Finally, TfL welcomes the chapter on developer contributions but advises that more
emphasis is placed on the need to collect transport-related planning obligations.
London Development Agency
46 BTC1 “ The shopping role of Barking Town Centre”: The LDA supports the preferred
option 2, which encourages additional shopping in the Town Centre as this is in line with the
London Plan's designation of Barking a Major Centre in the hierarchy of town centres.
47 BTC3 ”Edge of town retailing”: Option 2, which does not allocate a site for a large food
superstore is supported. Option 1 is contrary to national and regional policies.
48 BTC4 “Office Development”: Barking Town Centre is not considered of strategic
importance for provision of office space. However London Plan policies 3B.1 and 3B.2 support
the rejuvenation and provision of a range of office premises, particularly those to meet the
requirements of small and medium enterprises to renovate, increase and enhance the quality of
the existing office provision is supported. More specifically the provision of a variety of type,
size and cost of premises to meet the needs of all sectors.
49 BTC5 “Hotel Development”: The principle of development of a hotel in the town centre
is supported, as it will help contribute to the vitality and vibrancy of this town centre location.
50 BTC6 “The future of street market”: The LDA supports the preferred option 2, which is
in line with policy 3D.3 of the London Plan.
51 BTC8 “Employment Land”: The LDA supports the preferred option to allow parts of the
Fresh Wharf Estate and the use of the Gascoigne Business Park to be lost to industrial ues and
developed for mixed use including housing.
52 BTC15 ”Health, education and training, and community facilities”: The LDA supports
the preferred option.
7
53 BTC24 “ Developer contributions towards community benefits”: The LDA supports the
preferred option however any section 106 contributions will need to be in accordance with the
priorities set out in policy 6A.4 of the London Plan.
54 Section C: Site Specific Allocations: The LDA suggests that as part of the site specific
allocation provided in Section C, that a map illustrating the sites and locations of the individual
sites should be included in the document.
Other Comments
55 No comment received from Design for London (DfL).
Conclusion
56 There is much to be welcomed in the draft Barking Town Centre AAP preferred option
development plan document. However, the following issues are raised.
Land use - Barking plays a strategic role not just in the Thames Gateway but also in
London and this should be reflected in Objective 1. Gascoigne Road & Hertford Road
Business Estates need to be identified in Fig 13.1 of the indicative map.
Climate change and mitigation: The Council should include a requirement to include
energy efficiency measures. The delivery of the district-heating infrastructure should be
explicitly stated and encouraged. The London Plan renewable energy target should also
be reflected in the AAP.
Transport - the following key issues and those mentioned in the report need to be
addressed from land use transport perspectives:
- The provision of terminating facilities for ELT services at Barking station.
- Bus services provision.
- Financial contribution to transport.
- Freight and servicing issues.
57 Although many of the Barking Town Centre AAP preferred options conform with the
London Plan, the above issues and those detailed in the report and in Appendix 3 need to be
addressed satisfactorily before the submission stage of the document.
For further information, contact the Planning Decisions Unit
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email giles.dolphin@london.gov.uk
Christine McGoldrick, Strategic Planning Manager (Development Policy)
020 7983 4309 email christine.mcgoldrick@london.gov.uk
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email justin.carr@london.gov.uk
Tefera Tibebe, Strategic Planner
020 7983 4312 email tefera.tibebe@london.gov.uk
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Appendix 1: Boundary of Barking Town Centre Area Action Plan (Source: LBBD BTC AAP doc)
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Appendix 2: A map of the correct ELE2 route alignment
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