page 83 agenda item 6 - sutton · out in table d2 of pps25 as it is considered that the...

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London Borough of Sutton

Planning Advisory Group – 29 June 2010

Report of the Executive Head of Planning, Transport and Highways

SITE DEVELOPMENT POLICIES DEVELOPMENT PLAN DOCUMENT –

REPRESENTATIONS FOLLOWING PUBLICATION

Ward Location: All wards Author: Keith Fraser (x6254) Area Served: All wards Lead Councillor: Jayne McCoy

Key Decision Report

Summary This Report summarises the main issues raised by the 29 respondents (listed in Appendix 1) following the publication of the Site Development Policies Development Plan Document (DPD) – Proposed Submission and a schedule of all the representations is attached as Appendix 2. The report also suggests where minor changes which would help with the legibility of the Plan might be made pending further discussions with stakeholders. In addition, the report indicates the need for any further evidence gathering prior to Submission of the Plan to the Secretary of State.

RecommendationsI recommend that the Planning Advisory Group:

(a) Considers all duly made representations and considers those representations that were not duly made in order to identify factual changes which should be proposed at submission;

(b) Notes the suggested way forward in the preparation of this DPD and agrees to consider any proposed minor changes at a later Meeting following detailed consideration of any representations by officers.

1. Background

1.1 The Planning and Compulsory Purchase Act 2004 requires local planning authorities to produce a Local Development Framework (LDF) guiding change over the next 10 to 15 years. The Core Planning Strategy was adopted by the Council in December 2009 following an Examination in Public that took place during that summer. The Site Development Policies DPD, which includes development management policies against which future development will be considered and allocates sites for future development must be in conformity with the adopted strategy.

1.2 Recent changes to the statutory procedures for preparing LDFs require the separation of publication of the revised DPD and submission to the Secretary of State. The publication of the Proposed Submission document is the third stage in the preparation/consultation of this DPD. The publication and formal representation period ran between 27 January and 10 March 2010.

1.3 At the same time as publication the Council made a formal request to the Mayor regarding the general conformity of the Core Planning Strategy to the London Plan.

1.4 Revised PPS12 is clear that the publication of a DPD should not be considered as an additional requirement to undertake public consultation, but allows representations

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relating to issues of soundness to be made and taken into account at Examination. Consequently, as there was little or no scope for changes to the submission document prior to Examination, the Council considered that interactive consultation techniques were not appropriate and therefore carried out the minimum publication requirements in accordance with the Council’s adopted Statement of Community Involvement. This included writing to consultees and making documents available for inspection at a range of locations.

1.5 To be sound a DPD must be justified (founded on a credible evidence base and the most appropriate strategy when considered against the reasonable alternatives), effective (the document must be deliverable, flexible and able to be monitored) and consistent with national policy. It must also be legally compliant (meet all necessary procedural requirements). A standard representation form was produced and sent to all general and specific consultees and posted on the web in order to encourage respondents to frame there responses against these tests of soundness.

2. General Conformity with the London Plan

2.1 In accordance with the requirements of the Planning and Compulsory Purchase Act the Council was required to request the Mayor’s opinion on general conformity with the London Plan. One of the Tests of Soundness is that any DPD must be in general conformity. The GLA indicates that the Site Development Policies DPD is, on the whole, consistent with the London Plan however, in relation to the strategic issues of proposed Loss of Metropolitan Open Land (MOL) [Site Allocation A24], Loss of Urban Green Space [Site Allocation A17], Loss of Housing [Policy DM23] and Car Parking standards [Policy DM22] the DPD is not in general conformity. Further discussion will be held with the GLA as changes were made prior to Publication which it was considered addressed two of these issues. Any outstanding issues will have to be considered by the Inspector at Examination.

2.2 In total the GLA has submitted 12 representations, the majority of which supports the changes made to the DPD since the Preferred Options Stage or suggests further minor changes.

3. Response from the Government Office for London (GoL)

3.1 GoL does not consider there to be any critical soundness issues with the DPD Proposed Submission draft however it has identified some points where amendments would improve the understanding or clarity of the Plan.

3.2 GoL welcomes the section in the DPD which details the relationship between the Development Management policies and the Core Strategy. However, it considers it would be more helpful to structure the DPD around the Core Strategy Policies. Comment was also made that a limited number of policies were expressed in negative terms citing DM2 (Protecting Amenity) and DM30 (Housing and Backgarden Development) as examples. It considers every effort should be made to express policies in a proactive and positive way and generally policies should be as locally distinctive as possible. Whilst accepting the latter is more difficult with Development Management Policies, it is considered the DPD lacks a locally distinctive dimension.

3.3 GoL considers the Plan needs to be updated to take account of PPS4 Planning for Sustainable Economic Growth which was published in December 2009 and replaced PPS6.

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3.4 GoL considers the Monitoring Framework (Table 5.1) makes good links with the Core Strategy and includes measurable indicators and targets.

3.5 No comments were made by GoL on individual site allocations.

4. Main Issues Raised in Response to Publication

4.1 In total there are 29 respondents as set out in Appendix 1 making 80 representations, although 4 of those respondents responded after the closing time (25 representations). Excluding the representations from the GLA and GOL and those representations in support of the Plan, there are 21 representations claiming that the Plan is not “sound” because a particular policy or site allocation is not justified, effective or consistent with national guidance, although some are only seeking minor changes to the document. A small number also considered the document not to be legally compliant. Eleven respondents considered the Plan to be “sound”.

4.2 4 representations were received late. These were from the PCT, the Highways Agency, English Heritage and Sutton United FC. Regulations make it clear that only representations made in time have the right to have their representations considered at the Examination in Public. All 4 respondents were advised that their representations were “not duly made” but that they would be forwarded to the Inspectorate along with all “duly made” representations and it would be for the Inspector to decide whether or not to consider those late representations. However, it is considered that any factual corrections contained within those “late” representations should be taken into account.

Main Policy Areas Where the Plan is Considered Unsound.

4.3 One key area is in relation to policies relating to environmental sustainability. Savills, the agents who act for the owners of the Felnex estate in Hackbridge, considers that the Plan is not consistent with national guidance with regard to the timescale set out in Policy DM5 [Sustainable Design and Construction] for introducing different sustainability ratings for new buildings. It considers the timescale lacks any flexibility to take into account the viability of development and the realisation of other policy objectives and hence the policy will stifle development. Additional policy wording is suggested by Savills to achieve this flexibility. Likewise in Policy DM6 [Climate Change Mitigation] Savills seeks the insertion of the phrase “where feasible” into the policy in relation to achieving zero carbon standards for all new buildings in Hackbridge to reflect the Core Planning Strategy (policy amplification to PMP7). Savills also objects to the prioritisation order set out in the accompanying text to this policy [para.3.55] which specifies that in relation to CHP all developments should be connected to existing CHP plant where this is available. Instead, developers should be allowed flexibility in the choice of renewable energy sources to serve new development. Otherwise Savills considers developers may be held to ransom if there is only one option.

4.4 Morrisons also considers Policy DM5 to be inflexible and unsound and should be amended to include the tests of viability and suitability in seeking to achieve the target timescale set out in the policy in relation to BREEAM standards for non-residential developments.

4.5 The Metropolitan Police Authority have suggested a minor wording change in relation to Policy DM7 [Flood Risk] to include the Flood Risk Vulnerability Classification set


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out in Table D2 of PPS25 as it is considered that the vulnerability classification of uses is an important consideration in determining whether a use is appropriate in a certain location.

4.6 Both the Metropolitan Police Authority and Morrisons consider the Car Parking Standards [Policy DM22 and Appendix 3] to be unsound as they are too restrictive and should be more flexible to allow additional car parking where it meets operational need/serves the whole town centre, whilst the GLA have stated that the standards are too generous for certain land uses.

4.7 The Metropolitan Police Authority considers Policy DM33 [Strategic and Established Industrial Locations] is not sound and that the list of acceptable uses in these areas should specifically refer to social infrastructure in order to be consistent with the London Plan. Policing facilities are considered to be social infrastructure by the London Plan. Furthermore, in relation to DM34 [Other Land in Industrial Use], the MPA wants one of the tests to allow the release of industrial land in such locations to be to meet a demonstrable need for social infrastructure including police facilities.

4.8 Turley Associates consider that the supporting text to Policy DM35 [Development in Town and Local Centres] is not consistent with national policy (PPS4) in that it could lead to an over concentration of retail development in Sutton Town Centre and preclude retail locations elsewhere in the Borough (para.3.249).

4.9 The Benhill Gospel Trust do not consider that the DPD is effective and hence sound because Policy DM41 [Site Allocations] refers to opposing other uses than those identified in the site allocation. It is therefore inflexible and does not allow changes to be made in response to changed circumstances during the Plan period.

4.10 In addition, a number of relatively minor changes have been requested by Her Majesty’s Court Service to recognise that criminal justice facilities are part of the social and community infrastructure (DM31/glossary) and the GLA would like Policy DM19 to include a commitment to completing, improving and maintaining the Strategic Walk Network.

Main Issues in Relation to Site Allocations

4.11 Savills wants the requirement for retaining 25% of the site area for employment uses within the Felnex Estate (Site Allocation 20) replaced with the allocation requiring “major employment opportunities including office and light industrial development” and that the indicative housing capacity in the allocation and paragraph 4.12/Table 4.4 raised from 440 units to 800 units. The Plan is not considered to be consistent with national policy as it will frustrate development coming forward and not make the best use of brownfield land.

4.12 The Epsom and St Helier Trust does not considered Site Allocation A27 is justified and conflicts with the details shown in the Core Planning Strategy in respect of the alignment of Tramlink and objects to the reference in the allocation as requiring any new development to retaining a 1930’s design. The Trust also considers there has been insufficient consultation between the Preferred Options stage and the Submission draft of the Plan and is not legally compliant. The Trust therefore wants the allocation amended to remove the requirement to have regard to the possible extension of Tramlink in the design and layout of the site and revised wording to be included which only requires the development to respect the existing 1930’s design.


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4.13 A local resident objected to the allocation on the former Sheen Way Playing Fields (Site A17) on the basis that he did not want the area used as a formal local park or any of the land used for housing. Rather the area should be left for the use of local residents. The GLA also considers that the allocation of this site for mixed use is contrary to the London Plan in that it is currently shown as urban green space on the UDP Proposals Map. The GLA also considers that the Council has not demonstrated sufficient exceptional circumstances to justify an area of MOL land within the existing BedZed development being allocated for educational or community use (Site A24).

4.14 The Benhill Gospel Trust wants the allocated use for the former BIBRA site in Woodmansterne Road to include a Residential Institution. It also wants the development requirements supporting the allocation for this site to recognise that the access road through the site to serve the new Orchard Hill school is not a requirement of the development of the BIBRA site.

4.15 A local resident does not consider the Plan to be sound because Site Allocation C5 (Railway Approach and Car Park, Wallington) prejudices the construction of a terminus for a possible extension of the District Line from Wimbledon to Wallington via Sutton.

4.16 Two minor factual changes are suggested in relation to information supporting Site Allocations B6 (Institute of Cancer Research Land adjacent to Sutton Hospital) and D3 (Royal Marsden Hospital).

5. Suggested Way Forward

5.1 Guidance is clear that the Council should consider the Plan sound at publication and therefore consideration of changes post publication should be avoided wherever possible. However it is recognised that minor changes to the Plan may be required, for example to deal with typographical errors or to make the Plan more legible. These are the kind of changes, which could be made without consultation, and these changes should simply be listed as a schedule to accompany the DPD when it is submitted to the Planning Inspector with a request that the Inspector consider these recommending these changes as part of his/her report.

5.2 Meetings will be held with a number of those making representations to clarify their comments over the coming months. It is proposed to report back to PAG in September/October 2010 with a schedule of any changes that officers would wish Members to endorse and send along with the Submission version of the Plan to the Planning Inspectorate later in the year.

5.3 In the meantime, pending the outcome of these further discussions, officers consider the following action to be the most appropriate way forward.

Development Management Policies

5.4 GoL states that it would be more helpful to structure the document around Core Planning Strategy policies. However, the Council considers the current format is more user-friendly with policies relating to all forms of development (generic) appearing at the front of the section and then policies relating to specific land uses (housing, employment, retail and minerals) appearing at the end of the section. Furthermore, the document already contains a table cross-referencing Core Strategy and Development Management policies at the front of the document. Similarly, the


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presentation of certain policies, such as DM2: Protecting Amenity and DM30: Housing and Backgarden Land, in a negative manner provides the user with a more easily understandable checklist of criteria against which to judge a development than it would do in a positive manner. With regard to a lack of local distinctiveness, officers will give further consideration to whether there is any scope to accommodate such advice, but any significant changes to any policy at this late stage would be likely to delay the submission of the DPD as a result of possible further consultation. Officers will also aim to make any factual corrections to the DPD.

5.5 Further consideration will be given to the representations regarding environmental sustainability and it is anticipated that a number of policy amendments will be required as a result of further evidence gathering.

5.6 It is not anticipated that any changes will be proposed to the car parking standards as it is hoped that a further meeting with the GLA will confirm that the Council’s car parking standards are in general conformity with the London Plan. However, the Mayor’s Outer London Commission has recommended a selective review of car parking standards, which may give rise to a more flexible approach in outer London to assist town centre regeneration and help outer London town centres compete as office locations with those centres surrounding London. No changes are likely to be likely to be proposed in relation to Policies DM33 and 34.

5.7 It is not considered necessary to amend Policy DM41 in the way suggested. However, in response to this particular request and a similar comment in relation to the scope of a residential allocation, it may be possible to accommodate a degree of flexibility in the wording of the guidance on the proposed site allocations schedule. Any such flexibility would, however, need to be consistent with the Core Planning Strategy.

5.8 In respect to Policy DM31, it would seem appropriate to make changes to the glossary, but less appropriate to make the other changes suggested in paragraph 4.7.

Site Allocations

5.9 It is not considered necessary to make any changes to Site Allocation 20 as the percentage of land safeguarded for employment uses is consistent with the adopted Core Planning Strategy and its housing capacity, in common with all other sites involving an element of residential development, has been assessed in relation to the London Plan Matrix. The guidance on the Site Allocation Schedule already makes it clear that the Matrix only provides a guide to capacity, however there may be scope to provide further clarification within this guidance.

5.10 It is considered that it would be neither feasible nor environmentally acceptable to provide a route for Tramlink between Sutton and Mitcham Junction, that served the hospital, without passing through the hospital site but this issue will be discussed further with TfL. Further consideration will also be given to the comment on the design of any new building.

5.11 The former playing fields at Sheen Way (Site A17) are not currently a public open space. Rather it has become an area where people living adjoining the land send their children to play or exercise their dogs. The proposal would be to allow a small part of the site to developed for housing that would fund the creation of a new park


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with children’s’ play facilities to serve the local area. Further discussions will be held with the GLA over the need to create such an open space land along with the need to provide a new primary school to serve the Hackbridge area (Site A24) and the lack of alternative suitable sites. As a result additional work will be required including confirming the need for additional pupil places in Hackbridge and undertaking an assessment of suitable alternative sites.

5.12 Further discussion will take place with other persons objecting to the Plan although in the case of Site Allocation C5 the Council is not aware of any TfL proposals to extend the district line within the lifetime of this Plan or beyond.

5.13 As a result of a recent amendment to PPS3 (Housing), which is dealt with elsewhere in this Agenda, some additional changes may be required to the DPD to conform with national guidance.

6. The Next Steps

6.1 Discussions will be held with the Planning Inspectorate and GOL over the timetable for the submission of this document. It is estimated this might be late autumn 2010. Subject to meeting this timetable and agreement from the Planning Inspectorate it may be possible to hold any Hearings arising from the Examination in Public in April/May 2011.

7. Financial Implications

7.1 Costs of Submission and Examination are difficult to determine at this stage as it is not known how long the appointed Inspector will require to consider the DPD and the representations. The Core Planning Strategy cost for this stage was approximately £62,600 of which £52,600 was for the Inspector and the remainder for the Programme Officer. Based on the above and an assessment of the representations, it is estimated that the cost of the Inspector might be in the order of £30,000, with a further £5,000 for a Programme Officer although it is proposed that this latter cost can be absorbed by the Council as a result of temporarily deploying a member of exiting staff within Planning.

7.2 All costs associated with Submission and Examination of this DPD will be met from existing budgets.

8. Influence on the Council’s Core Values

8.1 The preparation of the draft Plan has involved consultation with the local community and all stakeholders. There has been a series of on-going one-to-one meetings with key stakeholders throughout the preparation of the Plan. Accordingly this has contributed to working in partnership with people living and working within the Borough and making the Council’s services open and accessible.

9. Contribution to the Achievement of Council’s Policy Aims

9.1 Preparing the draft Plan has contributed to the Council’s aim of Achieving Environmental Sustainability by protecting our environment for now and in the future.

10. Equalities Impact Assessment

10.1 The Council has produced an EqIA to accompany the Site Development Policies DPD: Proposed Submission, which sets out how equalities have been taken into account in the preparation of the document.


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APPENDIX 1

List of Organisations and Individuals Making Representations

Specific Consultees Government Office for London (GoL) Greater London Authority (GLA),- including Transport for London (TfL) Natural England Metropolitan Police Authority Her Majesty’s Court Service Coal Authority Surrey County Council Thames Water Property Services

English Heritage*

Highways Agency*

Sutton & Merton Primary Care Trust*

National Groups Theatres Trust

Local Groups Sutton Garden Suburb Residents’ Association

Sutton United Football Club*

Private Companies

and Landowners

SavillsWm Morrison Supermarkets PlcRoyal Marsden Hospital Trust Institute of Cancer Research Turley Associates Benhill Gospel Trust Epsom & St Helier NHS Trust

Individuals Mr Adrian Barry Mrs Angela King Mr Simon Longman Mr John Lowe Mr Alan Moody Miss Samantha Smith Mr Alan Thraves Mr Ian Wood

* received after the close of the representation period


APPENDIX 2a: Representations on the Site Development Policies Proposed Submission

Agenda Item 61

Representations on the Site Development Policies Proposed SubmissionPolicy, Para or Section/ Rep No

Respondent No and Name

Legally

Compliant?

DPD

Sound?

Unsound

because

it is not?

Representation Text and Changes Required

General

General

SDPPS15

Thank you for consulting The Coal Authority on the above. Having reviewed your document, I confirm that we have no specific comments to make on this document at this stage. We look forward to receiving your emerging planning policy related documents; preferably in an electronic format. For your information, we can receive documents via our generic email address [email protected], on a CD/DVD, or a simple hyperlink which is emailed to our generic email address and links to the document on your website. Alternatively, please mark all paper consultation documents and correspondence for the attention of the Planning and Local Authority LiaisonDepartment. Should you require any assistance please contact a member of Planning and Local Authority Liaison at The Coal Authority on our departmental direct line (01623 637119).

Ms Rachael Bust222877

The Coal Authority

General

SDPPS17

Yes Yes After careful consideration of the information provided, it is our opinion that the document is compliant with relevant legislation and has a credible evidence base. Natural England has previously commented on the ability of the document to be monitored and measured and this was and is deemed acceptable. Overall Natural England has no further comments to add to the Site Development Policies Consultation but would offer our support to the intention of the Council to establish the Wandle Valley Regional Park (Core Planning Strategy document, paragraph 2.9 refers). The document is acceptable to Natural England, compliant with relevant legislation and is in line with the approach adopted by oher London Boroughs, however, if you are aware of any reason why Natural England should comment further on this application please let us know as soon as possible.

Mr David Hammond32881

Natural England

General

SDPPS2

Yes Yes We have no concerns over the soundness of the Submission Draft. Nevertheless, we would obliged to be consulted on large scale proposals affecting Sites A11 and B6 in due course.

Mr Richard Evans32837

Surrey County Council

General

SDPPS43

Yes Yes Due to the specific nature of the Trust's remit we are concerned with the protection and promotion of theatres and, having read this comprehensive document, we have no particular comment to make but look forward to being consulted on further documents in due course.

Ms Rose Freeman33685

The Theatres Trust

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Policy, Para or Section/ Rep No


Legally

Compliant?

DPD

Sound?

Unsound

because

it is not?


General

General

SDPPS57

We would encourage you to consider the PINS learning from experience document "Examining Development Plan Document: Learning from Experience" and in particular paras 58-60. Overall, development management policies should be aimed at promoting the strategy that the authority is seeking to implement. A section is included in the document which details the relationship between the Development Management (DM) Policies and the Core Strategy, this is helpful. However, the subsequent table highlights the fact that the structure of the Site Development DPD does not link very well with the Core Strategy, as the related DM policies are interspersed throughout the document. It would be more helpful to structure the document around the Core Strategy policies. Albeit a limited number, some policies are negative eg DM2:Protecting Amenity and DM30:Housing and Backgarden Development. Every effort should be made to present policy in a proactive and positive way. Policies should also be as locally distinctive as possible, although we appreciate that this is more difficult in a DM DPD. The document current lacks a locally distinctive dimension. Policy DM1:Character and Design includes reference to locations where there is potential for taller buildings. The Inspector at Examination will require local evidence to support the location of tall buildings. We note references to PPS6. PPS4:Planning for Sustainable Economic Growth was published on 29 December 2009 and has replaced PPS6. Please ensure that the document is as compliant as reasonably possible with the requirements of the new PPS and that references to PPS6 are removed. The monitoring framework makes good links with the Core Strategy and includes measurable indicators and targets. We note that this document considers specific site allocations in the Borough. We have not reviewed individual site proposals and have no comment to make on the details presented.

Ms Julie Shanahan72077

Government Office For London

Policy DM1 - Character and Design


SDPPS37

Yes Yes The Metropolitan Police Authority (MPA) supports the need for new developments to ensure that the design of private and public spaces provides for natural surveillance, creates safe areas for cycle and car parking and ensure that design and layout of the development incorporates design principles that deter crime and reduce the fear of crime. The MPA welcomes the acknowledgement that promoting good design and layout in new development is one of the most important ways in which the Council can address crime issues, as it makes crime more difficult to commit, increases the likelihood of detection of criminal activity and improves perceptions of safety. The MPA also welcomes the inclusion of the reference to to the Council's "Designing Out Crime" SPD (2005). Recommendation: The MPA recommends that the wording of this Policy is retained in latter versions of the document in line with London Plan and PPS1 which states that Councils should prepare development plans which promote inclusive healthy, safe and crime free communities.

Mr John Smith107920

CGMS Consulting for

Metropolitan Police Authority

Achieving Environmental Sustainability


SDPPS16

Yes Yes Thames Water support the content of Policies DM5, DM7, DM8 and DM9. The policies combined with the policies in the Core Strategy are required to ensure that new developments reduce the impact on water and sewerage infrastructure, reduce all forms of flood risk and ensure that any water/sewerage infrastructure required to support development is delivered ahead of development. Without these policies

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Legally

Compliant?

DPD

Sound?

Unsound

because

it is not?



the DPD/LDF would not take account of the needs of utility infrastructure providers and the need to address environmental pressures as detailed in Section 5.1 of PPS12.

Thames Water Property

Services

Policy DM5 - Sustainable Design and Construction


SDPPS35

Yes No Consistent with

national policy

Policy DM5 sets out ambitious targets for the implementation of Code for Sustainable Homes levels and BREEAM ratings. We support the Councils ambition and understand the reasons why the Council is seeking such ambitious targets. However, Policy DM5 sets out targets in excess of what might be expected both nationally and London wide. Sutton, like all Councils, is subject to housing delivery targets and must demonstrate a 5 year supply of housing as required by PPS3. Development in Sutton will be subject to a range of costs, including s106 contributions and affordable housing. There may also be a Community Infrastructure Levy. The Council must ensure that it is able to take a balanced view of the various competing demands on development in line with the Governments national priority attached to housing delivery in PPS3. In short, Policy DM5 must be safeguarded to ensure that the ambitious targets do not stifle housing delivery or adversely affect other legitimate planning policy requirements. Accordingly, we consider that a subject to viability test should be included within DM5. Without such a test, we consider that the policy is not consistent with PPS1, PPS3, PPS12 and potentially, on implementation, Circular 11/95 or 05/05. We also note the Core Strategy Inspectors Report paragraph 3.127 which stated Hopefully, the high threshold set in the CS for achieving zero carbon standards for all new buildings in Hackbridge will be attainable but, since they are to be secured where feasible, I am satisfied that sufficient flexibility is provided in the policy for it to be consistent with government policy."

Mr Neil Rowley406419

Savills for Hackbridge Unit Trust


SDPPS44

Yes No Effective This policy requires that all major non-residential developments achieve a BREEAM rating of "Very Good" by 2010, "Excellent" by 2011 and "Outstanding" by 2017. Morrisions objects to such a requirement on the on the basis that the Council has not consulted with all sectors of industry to confirm whether the BREEAM standards are achievable or realistic. It is crucial that any such policy incorporates some flexibility to ensure that it does not represent an unreasonable burden on companies which could jeopardise investment, regeneration and employment creation in the Borough. Accordingly, our client requests that any such policy contains text which confirms that a requirement to meet the prescribed BREEAM standards are subject to tests of viability and suitability. As currently worded, we consider draft policy DM5 to be inflexible and therefore unsound.

Mr Roger Owen91457

Peacock and Smith for Wm

Morrison Supermarkets Plc

Policy DM6 - Climate Change Mitigation


SDPPS33

Yes Yes The Council's policy DM6 (Climate Change Mitigation) is supported. It exceeds the requirements of Policies 4A.1 (Tackling Climate Change), 4A.6 (Decentralised Energy: Heating, Cooling and Power) and 4A.7 (Renewable Energy) of the adopted London Plan and is in accordance with Policies 5.1 (Climate Change Mitigation), 5.2 (Minimising Carbon Dioxide Emissions) and 5.5 (Decentralised Energy Networks) of the replacement London Plan.Mr Boris Johnson32804

The Mayor of London



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Unsound

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SDPPS36


national policy

We note the Core Strategy Inspectors Report paragraph 3.127 which stated Hopefully, the high thresholdset in the CS for achieving zero carbon standards for all new buildings in Hackbridge will be attainable but, since they are to be secured where feasible, I am satisfied that sufficient flexibility is provided in the policy for it to be consistent with government policy. Accordingly, the phrase where feasible should be added after 2011 in Policy DM6(c) i.e. The Council will require all developments within Hackbridge to achieve net zero carbon standards by 2011 (where feasible) and promote. Without such a change we consider that the policy is not consistent with PPS1, PPS3, PPS12 or PPS22.



Paragraph 3.55 DM6

Paragraph 3.55 DM6

SDPPS51


national policy

We are concerned by the Councils potential requirement arising from para 3.55 (i) and (ii) for developers to connect to (or extend) an existing CHP system. This places developers in the position of having only one option for the delivery of low carbon development. This goes beyond the requirements of PPS22 andthe London Plan. Developers should be allowed a choice of renewable energy means to achieve the Councils policy requirements. To require adherence to a single option potentially reduces flexibility and increases costs. It will be very difficult for developers to negotiate the costs of connection to a district heating network if the operators of such a network are aware that the developer effectively has no other option.



Paragraph 3.73 DM7

Paragraph 3.73 DM7

SDPPS38


national policy

In considering flood risk, the vulnerability classification of uses is an important consideration in determining whether such a use is appropriate in a certain location. The Metropolitan Police Authority (MPA) notes that there is no reference with this Policy nor its supporting text which refers specifically to the Flood Risk Vulnerability Classifciation set out in Table D.2 of PPS25. Annex D, paragraph D5 of PPS25 states that "decision-makers identifying broad locations for development and infrastructure, allocating land in spatial plans or determining applications for development at any particular location should take into account the flood risk vulnerability of land uses. Recommendation: The MPA seeks the following amendments to Para 3.73 (additional wording in capitals): "Developers should also apply a sequential approach at a site level to minimise risk by directing the most vulnerable parts of the proposed development to area of lowest flood risk, matching vulnerability of land use to flood risk within the site. THE COUNCIL WILL HAVE REGARD TO TABLE D.2 FLOOD RISK VULNERABILITY CLASSIFICATION OF PPS25 'DEVELOPMENT AND FLOOD RISK'."

Mr John Smith107920

CGMS Consulting for the

Metroploitan Police Authority

Policy DM19 - Promoting Sustainable Transport and Accessibility


SDPPS32

Yes Yes In relation to Policy DM19 on Promoting Sustainable Transport, TfL would welcome a commitment to completing, improving and maintaining the Strategic Walk Network (SWN), and a requirement for new developments to contribute towards these improvements: "Key Walking Routes" should be promoted as route area walking initiatives and a commitment made to rolling out this project, or contributing to nearby schemes (either through development improvements or funding contributions). In addition, TfL would

Mr Boris Johnson32804


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Compliant?

DPD

Sound?

Unsound

because

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welcome a reference to Legible London as the pedestrian wayfinding system of choice. TfL would encourage developer contributions to be made towards its implementation or new developments to use the system for installing new pedestrian signage.

The Mayor of London

Policy DM22 - Parking


SDPPS31

Yes No Justified Under the parking standards proposed at Appendix 3, note 3, proposed residential development outside town centres could have parking provided at 1.3 spaces per unit as long as parking is allocated by the Borough. This would appear to be in excess of London Plan standards (1 space/unit) and should be reconsidered. In addition, parking standards A3-A5 uses are in excess of London Plan standards and should be reconsidered. Parking for B8 uses should be based on the floor area of associated office accommodation only, and some of the standards for community uses are above London Plan standards and should be reviewed.


The Mayor of London


SDPPS42

Yes No Effective Both Policy DM22 and the proposed changes to the Parking Standards in the UDP Schedule 7.2 (set out in Appendix 3) state that developers should not exceed the level of car parking indicated in the standards. No exceptions are provided. The Metropolitan Police Authority considers that, in some circumstances, additional parking may be required for operational reasons, and the application of parking standards should be considered flexibly on a site-by-site basis. Recommendation: The MPA recommends that the following changes are made to Policy DM22 (a) (additional wording in capitals): New developments will be expected to provide the appropriate amount of car parking necessary in accordance with the Council's restraint-based maximum car parking standards (as set out in Appendix 3), taking into account public transport accessibility levels (PTALs), existing publicly available parking provision and usage in the vicinity of the site and the need to deter unneccessary car use while avoiding over-spill parking problems, AND THE OPERATIONAL REQUIREMENTS OF THE PROPOSED USE.

Mr John Smith107920




SDPPS48


national policy

We note the parking standards for A1 food stores within Sutton Town Centre, as shown in Appendix 3, and consider them to be unduly onerous. Paragraph 56 of PPG13 notes that a balance has to be struck between encouraging new investment in town centres by providing adequate levels of parking and potentially increasing traffic congestion caused by too many cars. It is noted that where retail and leisure developments are located in a town centre, or on an "edge-of-centre" site that: "Local Planning Authorities should consider allowing parking additional to the relevant maximum standards provided the Local Authority is satisfied that the parking facilities will genuinely serve the town centre as a whole and that agreement to this has been secured before planning permission has been granted." In light of the above paragraph, the standards set out in Table 3.1 are unduly onerous and we consider them to be unsound.

Mr Roger Owen91457

J&J Design for Benhill Gospel

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SDPPS18

Yes Yes We support the proposed flexible approach to the provision of on-site car parking, in accordance with national planning guidance and the policies of the London Plan.

Mr Johnathan Porter406059

Barton Wilmore for Royal

Marsden Hospital NHS

Foundation Trust

Policy DM23 - Loss of Housing

Policy DM23 - Loss of Housing

SDPPS23

Yes No Justified The GLA previously objected to Policy 23 (Loss of Housing). Whilst the Council has made changes to the policy, an objection is maintained as the exceptional circumstances to justify housing loss as put forward by the policy which includes where it would meet the housing needs of the borough by providing new housing at a higher quality or design do not meet the London Plan or SPG requirements. Policy 3A.15 (Loss of Housing and Affordable Housing) of the London Plan resists the loss of housing, including affordable housing, without its planned replacement at existing or higher density. Paragraph 3.75 of the London Plan gives advice on the Mayor's approach to estate renewal. This approach is carried through to the consultation draft replacement plan in policy 3.13 (B) and paragraph 3.75. More detailed guidance is set out in Section 20 of the Housing SPG. This clarifies that there should be no net loss of affordable housing, which can be calculated on a habitable room basis and should exclude right to buy properties. Replacement affordable housing can be of a different tenure mix where this achieves abetter mix of provision. The Council's supporting text makes reference to maintaining the overall quanitityof affordable housing across the borough but this is not sufficient.


The Mayor of London

Policy DM26 - Housing Mix

Policy DM26 - Housing Mix

SDPPS22

Yes Yes Following the Preferred Options stage, changes to the housing mix policy have been made so that a reference to a threshold of 10 or more before the policy is applied has been deleted. This is welcomed.


The Mayor of London

Paragraph 3.228 DM31


SDPPS55

No No Effective Her Majesty's Court Service (HMCS) currently operates Sutton Magistrates Court in the Borough. It is within this context that we make the following representations to the Site Development Policies document. HMCS plays a key role in the delivery of safe and secure neighbourhoods and communities, alongside other delivery partners such as the Metropolitan Police. HMCS therefore welcomes proposed Policy DM31 and its intended aims. However, it is our experience that whilst schools and healthcare services are typically addressed as part of the community infrastructure needs, the role that courts play in the community is often overlooked. In addition, flexibility is sought in the policy to enable HMCS to adapt its court estate as required to ensure appropriate service delivery: whether this be for instance through court extension, relocation, consolidation or through the provision of new facilities. On this basis,

Ms Amy Jones406951

DPP LLP for Her Majesty's

Court Service


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we request that the wording of paragraph 3.228 which contains the pre-amble to Policy DM31 is amended to recognise explicitly criminal justice facilities as a valuable type of social infrastructure: "Further to Core Planning Strategy Strategic Objective 3, the Council, in principle, supports the provision of new facilities to provide education, healthcare, CRIMINAL JUSTICE FACILITIES OR similar services. Therefore, the Council will seek to protect and enhance social and community infrastructure in accordance with London Plan Policy 3A.18 (Protection and Enhancement of Social Infrastructure and Community Facilities) and Core Policies BP4 (Education and Skills) and BP5 (Improving Health and Well-Being)".

Policy DM33 Strategic and Established Industrial Locations & Policy DM34 - Other Land in Industrial Use


SDPPS39

Yes No Justified This Policy states that within the main industrial locations the Council will only grant planning permission for B1, B2 and B8 uses or other similar industrial uses. Other similar uses will be granted permission provided it can be demonstrated that the use would not adversely affect the industrial status or operation of the area. The Metropolitan Police Authority (MPA) considers that this needs to be refined to allow social infrastructure including policing facilities on surplus industrial land for the reasons set out below. The MPA has identified the potential of relevant employment space in helping them meet the goals of their estate strategy. In particular, the provision of patrol bases, custody centres and relevant pan-London policing facilities are vital to the successful implementation of the MPA's estate strategy. The nature of these uses are similar to that carried out on most industrial sites and therefore are ideally suited to Light Industrial Land and Employment Zone locations. Whilst falling outside the "B" Use Class definition, these policing uses are employment-generating uses. Generally the policing uses represent nomaterial alteration for an Employment (B1) or Warehousing (B8) uses as they possess an employment density similar to or in excess of "B" Class uses. Vehicles movement will also be similar to a typical employment/industrial uses. These facilities do not require continued public access and therefore have no requirement to be located in town centre areas. The requirement to provide employment uses within designated existing light industrial land and employment zones can be met through the provision of appropriate policing facilities on designated industrial land. Furthermore, it is considered that a planning policy basis as suggested below to support appropriate policing facilities on designated land in the London Borough of Sutton would not prejudice current or future employment land supply across the borough, as such uses are compatible with the requirement to provide employment opportunity. This is supported by a number of London Boroughs which have approved policing facilities on employment/industrial land, including Enfield (Cambirdge Business Park), Haringey (Quicksilver Place) and Greenwich (Warspite Road). The approach is supported by the strategic development plan within Policy 3B.4 Industrial Locations which states that policies in DPDs "should develop local policies and criteria to manage industrial sites having regard to helping meet strategic and local requirements for.. social infrastructure." Furthermore, Policy 2.17 Strategic Industrial Locations of the emerging London Plan defines inter alia "other industrial related activities" as being acceptable within Preferred Industrial Locations. It is demonstrated above that particular policing uses are essentially "B class" in nature and that the emerging DPD should therefore reflect this. It is also further demonstrated that certain policing uses will also fulfil the strategic requirement regarding the provision of social infrastructure. Recommendation: The MPA recommends that the following changes are made to Policy 33a (additional

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wording in capitals) to ensure compliance with London Plan 3B.4: "(a) Within the main industrial locations (as shown on the proposals map), the Council will only grant planning permission for B1 (excluding freestanding offices), B2 (general industry) and B8 (storage and distribution) uses, other similar industrial uses, or SOCIAL INFRASTRUCTURE. Other similar industrial and SOCIAL INFRASTRUCTURE uses will only be granted permission provided it can be demonstrated that the use would not adversely affect the industrial status or operation of the area.

Policy DM34 - Other Land in Industrial Use

Policy DM34 - Other Land in Industrial Use

SDPPS40

Yes No Justified Policy DM34 indicates that the Council will not grant planning permission for proposals resulting in the loss of industrial/business floorspace unless it can be demonstrated that the retention of existing use will have a significant adverse impact on residential amenity which cannot be alleviated; and there is evidence that site is no longer suitable for such uses. For the reasons set out in the Metropolitan Police Authority's response on Policy DM33, the MPA would again seek to ensure that social infrastructure is considered an acceptable use on surplus employment/industrial land, to ensure compliance with London Plan Policy 3B.4. Recommendation: The MPA therefore recommends the inclusion of an additional bulletpoint under Policy DM34(a): THERE IS A DEMONSTRABLE NEED FOR SOCIAL INFRASTRUCTURE, INCLUDING POLICE FACILITIES.

Mr John Smith107920





SDPPS34


national policy

Paragraph 3.249 states that Retail Study (2007) identifies the need for additional convenience floorspacein the Borough and the Core Planning Strategy, it then goes on to say that "Accordingly, Sutton town centre will continue to be promoted as a Metropolitan Centre and has been identified for growth." Policy EC3.1 (b, i) of PPS4 warns of the need to avoid an overconcentration of growth in particular centres. Therefore, proposals for retail development in Sutton town centre should not preclude retail development in other locations in the borough, subject to the sequential test.

Mr Amandeep Kellay34201

Turley Associates

Policy DM41 - Site Allocations

Policy DM41 - Site Allocations

SDPPS46

Yes No Effective As stated elsewhere, Benhill Gospel Trust have participated in the preparation of the draft DPD and so far as they are aware are satisfied that the DPD has met the legal requirements. Policy DM41 Site Allocations is considered to be unsound due to the final sentence The development of these sites for other uses will be opposed. It is concluded that this policy is unsound being both unjustified and ineffective, due to lack of flexibility. Also in determining planning applications the LPA is required by law to have regard to the provisions of the development plan and other material considerations. Policy DM41 precludes the weighing of other material considerations which in accordance with Government advice in the accompanying document to PPS1 may outweigh the development plan proposal.

Mr John Shephard102182


Trust

Paragraph 4.12 Housing Supply


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SDPPS49


national policy

Table 4.4 The potential contribution made by the Felnex Trading Estate is underestimated. The current outline application for the site proposes an indicative mix of some 800 dwellings. This figure may change in the course of reserved matters applications but to suggest 440 is a gross underestimation. Development on the Felnex Trading Estate must make the best use of what is a sustainable, brownfield site (in accordance with PPS1 and PPS3). Council policy should ensure that the most efficient use of land is achieved.



Paragraph 4.35 Health Well Being anad Recreation

Paragraph 4.35 Health Well Being anad Recreation

SDPPS19

Yes Yes We support the recognition of the Royal Marsden Hospital as a site for redevelopment to meet changing patterns in cancer treatment and care.




Foundation Trust

A11: Sutton Hospital, Cotswold Road, Belmont


SDPPS3

Yes Yes We have no concerns over the soundness of the Submission Draft. We note the current document includes Sites A11 Sutton Hospital. Development of [this site] would be relatively close to the County boundary and there may be some impact on the County's highway system in particular.



A17: Former Playing Fields, Sheen Way, Wallington


SDPPS29

Yes No Justified At the former playing field, Sheen Way, Wallington, the DPD proposes that a site designated as "Urban Green Space" on the proposals map should be for mixed use: open space and residential. This is contrary to London Plan policy 3D.8 (Realising the Value of Open Space and Green Infrastructure). However, this objection may be withdrawn if the Council can demonstrate that there is not an open space deficiency in this location.Mr Boris Johnson32804

The Mayor of London


SDPPS53

No No Consistent with

national policy

According to your own information, there is currently not enough open space per head in the borough. If the field is used for housing this will reduce it further. The field is currently used by dog walkers and the children of the Chase estate for recreation and would only need the addition of bins and a new fence to make it secure for all. If turned in to a Park this would encourage people from out side of the area to come in to the estate producing more traffic and the possibility of undesirables coming into the area. Thisfield has been used in this way for the last 10 to 15 years.

Mr Ian Wood404479

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A20: Felnex Trading Estate, London Road, Hackbridge


SDPPS50


national policy

(1) Bullet point 3: Retaining a minimum of 25% of the site area for employment uses It is not clear from where the 25% employment uses requirement has originated. It is accepted that the site should include some level of employment development as part of a genuinely mixed use scheme, particularly given the current employment use on the site. However, our recent survey found that only 70 people are currently employed on the Felnex site. There is an opportunity to much improve the employment generation of the site through mixed use development, but a 25% site requirement may prove onerous and adversely affect the viability of the scheme. The provision of traditional employment generating floorspace on the site (such as office and light industrial space) is unviable on its own and will rely on cross subsidy from other elements of the mixed use development. Accordingly, an overly onerous requirement for employment floorspace is likely to affect delivery of other planning benefits such as affordable housing and energy efficiency and renewable energy measures. This would not be consistent with national policy in PPS1, PPS3, PPS4 and PPS12. 25% of site area is potentially a disingenuous measurement. A small single storey building with a large car park could effectively meet the criteria. It is better therefore to set a different requirement for employment generating development on the site. We propose that bullet point two is replaced with: Major employment opportunities, including office and light industrial development The Council should also consider the positive effect that other forms of employment generating development, in particular retail and care development, could have on employment generation. This would be in line with the uses that are identified as 'economic development' by PPS4. (2) Indicative Housing Capacity The potential number of dwellings on the site is underestimated. The current outline application for the site proposes an indicative mix of some 800 dwellings. This figure may change in the course of reserved matters applications, but to suggest 440 is a gross underestimation. 440 appears to have been the result of the crude application of the London Plan Density Matrix. Development on the Felnex Trading Estate must make the best use of what is a sustainable, brownfield site (in accordance with PPS1 and PPS3). Council policy should reflect that the most efficient use of land is achieved. Whilst it is accepted that the capacity is indicative, we consider the achievable number of dwellings on the site is far in excess of 440. For the Site Allocations Document to suggest 440 dwellings will lead to confusion and uncertainty of stakeholders.



A24: Open Land Within BedZED and Land North of BedZED, Hackbridge

A24: Open Land Within BedZED and Land North of BedZED, Hackbridge

SDPPS28

Yes No Justified The council has maintained an area of open land within BedZED as suitable for education or community use. The land is within MOL. The Council has not demonstrated sufficient exceptional circumstances to justify this approach. It is noted that the Inspector in his report forollowing the Core Strategy EiP in which land contiguous with this was proposed to be designated from MOL stated about a school development that: "The need for a site to provide for a new primary school in Hackbridge would need to be justified on its merits when the need for additional places becomes clearer." The case for the school has not yet been made clear and therefore, at this time, the land should remain MOL. There is therefore a conformity issue in relation to London Plan policy 3D.10 (Metropolitan Open Land).


The Mayor of London

A27: St Helier Hospital, Wrythe Lane, Rosehill

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SDPPS52

No No Justified The Trust objects in A27 to "The proposed possible future extension of Tramlink to Sutton in the design and layout of the site" on the basis that the Site Allocations DPD is unsound in that there is conflict with the detail set out in the Core Strategy (Fig 9 - Rosehill) and that the proposals the Council are now indicating it wishes to safeguard are different to Map 3.1 of the Site Allocations DPD. Also that there has been insufficient consultation in the change between the Preferred Options which was the subject of consultation in Feb - March 2009 and the Proposed Submission Version which is the current document. The Trust also objects in A27 to "Retaining a 1930s design in any redevelopment, required in order to respect the history of the development of the area and the iconic status of the hospital as a key element of the 1930s St Helier Estate ASLC" on the basis that there has been insufficient consultation in the change between the Preferred Options which was the subject of consultation in Feb - March 2009 and the Proposed Submission Version which is the current document. This is too prescriptive a constraint on the design of any significant redevelopment of the St. Helier Hospital site. There are many examples of new developments that can successfully relate to the history and context of an area or buildings without adopting the specific design rationale of the existing.

Mr Alan Cordingley67344

Epsom and St. Helier NHS Trust

B2: All Saints Road/ Benhill Wood Road, Sutton

B2: All Saints Road/ Benhill Wood Road, Sutton

SDPPS47

Yes Yes Benhill Gospel Trust are grateful for the opportunity to participation in the preparation of the draft DPD, following adoption of the Sutton LDF Core Strategy. The Trust consider that the DPD has met the legal requirements under S20(5)(a) of the 2004 Act, so far as they are aware. With regard to Site B2 : All Saints Road/Benhill Wood Road Sutton the Trust considers the draft Site Allocation to be justified and effective. The proposed redevelopment will be deliverable subject to the current use relocating to Site B5. The Trust is unaware of any realistic alternative to the chosen approach for this site, which is situated in a predominantly low-rise residential area. The Sustainability Appraisal includes a Site Assessment in which the site scores well under the various criteria and constraints.



Trust

B5: Former BIBRA Site, Woodmansterne Road, Carshalton


SDPPS45

Yes No Justified ALSO NOT SOUND ON EFFECTIVE GROUNDS. The Benhill Gospel Trust are grateful for the opportunity to participate in the preparation of the draft DPD, following adoption of the Sutton LDF - Core Strategy. The Trust considers that the DPD has met the legal requirements set out at S20(5)(a) of the 2004 Act, so far as they are aware. With regard to Site B5: Former BIBRA Site Woodmansterne Road Carshalton and having due regard to the text of Policy DM41 - Site Allocations, whilst the Trust broadly support the proposed allocation they consider the DPD is not sound in that the Site Allocations Schedule text fails to explore other alternatives that have been discussed with the LPA. In particular, following the recent appeal inspector's rejection of a suburban housing scheme, the LPA Development Management team is proposing a design-led approach to the redevelopment of the site, based possibly on a modern country mansion house style development with the buildings up to three storeys high set in grounds to give a parkland setting. In addition to a Gospel Hall which was accepted by the Inspector it is suggested redevelopment could be for flats or luxury apartments, or more likely a residential care or nursing home within Use Class C2. It is submitted that this is a realistic design led solution to the 'residential' element of the preferred option and should be reflected in the Site Allocations Schedule text in order to not



Trust

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preclude this option by reason of Policy DM41. In the light of the above, it is submitted that the DPD fails the soundness tests of both 'justified' and 'effective'.

B6: Institute of Cancer Research Land, Adjacent to Sutton Hospital, Belmont


SDPPS4

Yes Yes We have no concerns over the soundness of the Submission Draft. We note the current document includes Site B6 Royal Marsden Hospital. Development of [this site] would be relatively close to the County boundary and there may be some impact on the Country's highway system.




SDPPS54

No No Justified In December 2009 the Council granted outline planning consent (ref. B2009/61542/OUT) for an extension to the existing ICR Campus. The application determined access, landscaping, layout and scale of three research and development buildings (B1), with a total floorspace of 20,400 SQ.M gross, with ancillary support accommodation to include offices and write up spaces, two associated service buildings for mechanical plant and storage, access arrangements, associated car, motorcycle and cycle parking and landscaping. The development will be phased over a ten to fifteen year period to reflect funding. A further application for Construction of earthworks associated with a landscape bund (ref. B2009/61541/FUL) was also approved on 17 December 2009 and is to be implemented within three years of that date. Principally our comments are made in accordance with Planning Policy Statement 12 (PPS12) Preparation of a Local Development Document and the tests set out in paragraphs 4.23 and 4.24, for assessing whether a development plan document is sound. Specifically, the ICR wishes to ensure that the emerging policies within the new LDF are the most appropriate in all the circumstances, they are founded on a robust and credible evidence base, accord with the policies of the London Plan and ensure that the LDF is reasonably flexible to enable it to deal with changing circumstances. The ICR notes that Core Policy BP5 supports the development at the Royal Marsden Hospital and Institute of Cancer Research in the south of the Borough. Proposed site allocation B6 details an expansion of the Institute of Cancer Research to ensure it remains at the forefront of research and development into cancer treatment. Accordingly the ICR supports the aims of the proposed site allocation B6, which allocates the Institute of Cancer Research Land, Adjacent to Sutton Hospital, Belmont for research and development uses. The ICR, however, wishes to clarify the indicative phasing referred to within the policyand requests that this is amended to reflect the fact that initial works on the landscape bund will commence within the next three years. Additionally the ICR requests clarification within the policy wording to confirm that the submission of reserved matters will be phased over a ten year period, which will be strictly influenced by the availability of funding. This in turn means that the development of the site will be completed over a 10 to 15 year period.

Ms Mary-Jane O'Neill406801

Renaissance Planning for

Institute Of Cancer Research

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SDPPS5

No No Justified ALSO NOT SOUND ON EFECTIVE AND NATIONAL POLICY GROUNDS. C5 violates the proposed terminus of the District Line via St Helier and Sutton as per the Underground Railways Act 1911 and all but complete. The Underground Railways Act of 1911 was much built pre-World War I but could not be financed post-war. The Southern Railway got their act to complete it and built it as a "blocking line" that they didn't want, British Rail never wanted it and Thameslink would be better without it. Most passengers alight to interchange at Wimbledon and new passengers board Thameslink trains. All logic has been for the St Helier line to be District Line as originally intended. All that is needed is a new line linking the northside of Wimbledon Station to the south side, presumably west of the station but the original intention was east of the station. The St Helier line is overcrowded with train passengers who don't want to go beyond Wimbledon station except by interchanging. There's little scope for a better service on the existing route.The District Line can provide a vastly better service on the St Helier line even if it's only the Edgware Road service and not via London. There has always been, for most of a century, allocated space for a platform behind Platform 1 at Sutton Station but the railway bridge needs rebuilding and road diversion will allow for this. That's not enough for a terminus but OK for through trains. The obivous terminus is Wallington Station Goods Yard Car Park Policy C5 and diagram. There's space for several platforms and it would make an ideal terminus. Frankly, it's more use as a car park than used for housing. PS: The Northern Line was originally intended to use the St Helier to Sutton but it's too overcrowded whereas the District Line to Edgware Road has 50% spare capacity for extra trains to run. Platforms were built for Northern Line quadrupling but tunnels between them never built. Were that completed the Northern Line could come to Sutton.

Mr Alan Thomas Moody33441

Private


SDPPS6

No No Justified ALSO NOT SOUND ON EFFECTIVE AND CONSISTENT WITH NATIONAL POLICY GROUNDS.The site is better as a car park than used for housing. As a car park, it will still be there for development as a terminus for the District Line when extended from Wimbledon.

Mr Alan Thomas Moody33441

Private

D3: Royal Marsden Hospital, Downs Road, Belmont

D3: Royal Marsden Hospital, Downs Road, Belmont

SDPPS20

Yes Yes We wish to note that the Planning History and Delivery Mechanism need to be updated. The Translational Research Centre planning application was approved at Committee on 24 February 2010. Inaddition, the CYPC, electrical infrastructure building, medical records and temporary theatre have all nowbeen implemented.




Foundation Trust

D4: Sutton United Football Ground, Gander Green Lane, Sutton

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SDPPS1

Yes Unfortunately I cannot comment on whether the DPD is legally compliant. However I support the soundness of this DPD because - I have read and digested the development scheme and what it should pay particular regard to and I believe this ticks all boxes. (Apart from Collingwood Road vehicular access). This is a fantastic opportunity to redevelop part of West Sutton that has been allowed to stagnate for years. I believe that both the London Borough of Sutton and Sutton United FC would both like to redevelop this site for their own reasons and local residents will benefit from this plan being approved. Win, win, win for all three parties. West Sutton is in need of more leisure facilities to keep their youngsters fit, healthy and out of trouble. Collingwood recreation ground has been run down for years. More football/cricket pitches and modern changing facilities are desperately required in the borough. So, why not here? At the moment Collingwood recreation ground just seems to be a shortcut to and from the Sutton main shops. Also these plans will give more community facilities back to West Sutton. A community meeting hall sounds great as does the indoor sports facilities and improved conditions for Sutton United FC spectators. Sutton United FC has a great history and tradition in local non-league football and is always looking to provide better facilities and football standards for the residents on a shoe-string budget. They are a well-managed organisation with a Board that has their feet on the floor and who are desperate to achieve FA Standard-Community Status for the Club. These plans will put the football club in the centre of the community. Sutton United FC needs your help, as it plays a large part in enabling the youth of the borough to try and live their dreams. The level of football coaching at Sutton United FC is as good as anywhere, if not better than most. Many youngsters pass through the colts/youthsections and progress to higher football. The plan to enclose the football ground on all four sides has been a dream for too long and will also add a higher level of security. I have been watching Sutton United FC since the mid 1960s and unfortunately money has been in short supply to progress their ground as other clubs have done at their level. This proposal, if agreed, will go a long way to achieving a more modern ground with facilities to match. I hope as many people as possible, who live or have lived in the London Borough of Sutton, vote for this plan as soon as possible. This is too good an opportunity to miss for the London Borough of Sutton's residents, young or old. Local football and cricket teams will have more green space suitable for their games and this could also be a meeting place for indoor clubs as well as catering for weddings, birthdays and musical events for the local people. This legacy could liveon forever and become the focal point for leisure facilities in the Borough for many years to come.

Mr Allan Thraves329782

Private


SDPPS11

Yes Yes I believe the DPD to be sound and compliant and feel this development would be of massive benefit to the whole of the local community. Bringing back into use the open space is long overdue and would help bring the park back to life. It would also give the local children a safe and controlled area to do sport, getting them more active and healthy and reducing the crime that occurs in the park at present. This in conjunction with the development of the swing park and a local community centre or indoor sports hall for multi function use would create a sporting hub for hopefully not only football, but other sports that could use these facilities. There is currently ample land to build these facilities within the boundaries of the football ground so would retain the open ground and would make the park a more appealing place for the whole community to visit.

Miss Samantha Smith399031

Private

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SDPPS12

Yes Yes I believe the DPD to be sound and compliant and feel this development would be of massive benefit to the whole of the local community. Bringing back into use the open space is long overdue and would help bring the park back to life. It would also give the local children a safe and controlled area to do sport, getting them more active and healthy and reducing the crime that occurs in the park at present. This in conjunction with the development of the swing park and a local community centre or indoor sports hall for multi function use would create a sporting hub for hopefully not only football, but other sports that could use these facilities. There is currently ample land to build these facilities within the boundaries of the football ground so would retain the open ground and would make the park a more appealing place for the whole community to use.

Miss Samantha Smith399031

Private


SDPPS13

Yes Yes As a lifetime resident of Sutton, I think this is an excellent idea. This particular area of Sutton is crying out for some form of practical development and this seems to have much merit. Much of the space behind the existing covered terrace of the football ground which faces onto the recreation ground is a sterile area and the idea of turning it into a complex to encourage our local boy and girls in sport is commendable. It would also be good to see the old recreation football pitches brought back into use and facilities improved at the football ground itself.Mr John Lowe335833

Private


SDPPS21

Yes Yes I wish to express unequivocal support for the proposed development of this site as featured in your Site Development Policies document. As a long-standing London Borough of Sutton resident and frequent visitor to this part of town to watch our local football team in Gander Green Lane, I firmly believe that the regeneration of this area has become a great priority and the opportunity to turn the site into a real fulcrum of leisure provision for ALL residents in the Borough a particularly forward-thinking and vital one. I recall playing Sunday morning football on Collingwood Rec years ago since when the area has deteriorated year after year and is now fast becoming a no-go zone for residents. The proposed development would provide the whole community with a much needed qualitative focal point for leisure pursuits and provide the opportunity for establishing a solid framework for, amongst other things, football development at all ages and levels for residents in the Borough.

Mr Adrian Barry333497

Private


SDPPS8

Yes Yes I believe the DPD to be compliant and sound and think this plan is a good opportunity for the local football club to bring back into use the pitches on Collingwood Recreation ground for the use of the whole community. At present the recreation ground isn't being used to its full potential which for such a large and centrally located open space is a complete waste and the lack of use is causing the park to become run down and vandalised on a regular basis. The recreation ground needs to be brought back into use for the whole community. The fact the buildings will be built on the current land and will not encroach on any of the parkland is also encouraging as no open space will be lost under bricks and mortar. It would also be beneficial for the local community to have a community centre or indoor sports centre for use by the local residents. The development will hopefully rejuvenate the recreation ground and if coincided with re-developing the swing park and hard courts it would reduce the vandalism in the park and also reduce the risk of crime in the evenings and would create a hub of activity and sport for everyone to enjoy.

Mr Simon Longman329807

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Table 4.6 Sites Withdrawn from the Site Development Policies Preferred Options Document


SDPPS24

Yes Yes A6: Land adjacent to A217, Sutton has been withdrawn from the Site Development Policies DPD as a potential area for development. This is welcomed.


The Mayor of London



SDPPS30

Yes Yes A9: Sutton Bus Garage. TfL support the removal of Site A9: Sutton Bus Garage, Bushey Lane, Sutton.


The Mayor of London



SDPPS25

Yes Yes A21: Part of the Sewage Treatment Works, Beddington Lane has been withdrawn from the Site Development Policies DPD as a potential area for development. This is welcomed.


The Mayor of London



SDPPS26

Yes Yes A22: Thames Water Land, Beddington has been withdrawn from the Site Development Policies DPD as a potential area for development. This is welcomed.


The Mayor of London


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SDPPS14

Yes Yes B1: Former Allotments, Aultone Way. I understand that during the previous stage of the LDF process in 2009, a letter of objection was received by Mr A Webb, Antler Homes Southern plc, re: The Former Allotments Site, Aultone Way, Sutton. I know that this objection letter will not probably come before this final part of the LDF to be submitted to the Government, but having now read it, I really have to correct some of the facts stated in that letter, just in case the same inaccurate points are submitted to you again. As a resident since 1967 and a former alltment holder of 20 years, I was incensed to read Mr Webb's view of how the site has become overgrown and "financially unviable". In my and many other residents' view, this has been done on purpose by the Directors of Woodend Estate Ltd so that they could sell the land for development. The correct and documented version of events is as follows:- After Sutton Garden Suburb Ltd (Chairman: Thomas Wall) and Rose Hill Park Ltd were wound up and the remaining plots of land in the Sutton Garden Suburb were sold off privately, including the "Recreation and Tennis Courts" land, an offer was made by the newly formed "Woodend Estate Ltd" to all local residents in the Sutton Garden Suburb to purchase shares to buy the said "Recreation Ground". Only 37 residents took up the offer and then the land was for their private use until the "Dig for Victory" Campaign was launched during the Second World War. After that, local residents could pay to rent an allotment and the plots were almost continuously occupied until plotholders were give a year's notice to quit in September 1997. This was a result of Woodend Estate Ltd accepting an offer from Wimpey to build houses on the land, NOT as has been stated by the Antler Homes letter due to a dwindling take-up. This could not be further from the truth. In fact, 85% of plots were worked in 1997 and there was actually a waiting list so there was most certainly a demand for an allotment. But, as the Secretary of Woodend Estate Ltd knew the complany's plan to develop the site and that eviction plans were imminent, no-one else was allowed to come on the site and that is why the allotments "closed". In my 20 years as an allotment holder, I had always been told by the Secretary that our rents were worked out each year by the total running costs (ie water, insurance etc) and then divided up by the number of plot holders. Woodend Estate Ltd was not apparently supposed to make a profit. Therefore, it is quite clear that the allotment holders bore the cost of running the site and it is only since we were evicted that the company has borne the costs involved. The only time that I can remember any shareholders were asked for any contribution was in 1976 when 34 x ú10 shares were issued to pay for the cost of felling diseased elm trees. This actually made room to create more plots! The fact that the site is so overgrown is because the company has let it get like that, even though the allotment holders offered to stay on after the Notoice to Quit expired on a pro-rata basis, which was refused. It is also incorrect to say that no further interest has been shown in purchasing the site after Greenshaw High School was offered it. I know that after Wimpey withdrew from the sale, several more developers approached London Borough of Sutton planners to see what the chances of getting planning permission were, but apparently when told that Wimpey had withdrawn, they lost interest, not because of the cost of re-instating the land for building, but it was said: "If Wimpey could not do it, no-one could." Also, the Sutton Garden Suburb Residents Association made an offer to buy the land which was refused. If it had been accpeted, the land would have been used for its original purpose, ie a recreation ground for Sutton Garden Suburb, which could have included space for allotments. I have documentary evidence for virtually all the points I have made in this letter, including many Companies House Registers, dated between 1934 and 2006, letters to and from Woodend Estate Ltd, to allotment holders (the Woodend Circle of Allotment Holders) and the company's Articles of Association and Memorandum, which show that many of the details in Anter Homes objection letter are incorrect and give

Mrs Angela King167732

Private

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a false impression of how important this site was, and still is, to theconservation area. I also have many photographs up to 1997, showing how well kept the allotments were. Lastly, I refute that this site has limited views from the surrounding area. All the trees can be seen from the gaps between the houses, especially as Aultone Way and Woodend boundaries consist of bungalows and taking into consideration the fact that the site is on a hill, affording views of the site from most points round the suburb. This is still our "green lung" and deserves to be protected as such. I am very grateful for Sutton Council's support in this matter, as are all of us who have the priviledge of living in the Garden Suburb.


SDPPS7

Yes Yes B1: Former Allotments, Aultone Way. I am writing on behalf of the Sutton Garden Suburb Residents' Association to support the soundness of the Council's submission draft of the DPD, with specific reference to to site B1 (former allotments Autone Way). The Council has quite correctly concluded that this site should remain as currently designated (urban greenspace) and not designated for residential development as previously proposed by those with a financial interest in seeing the land built on. The overwhelming majority of the residents of this area consider that any development on this site would have a harmful impact on the character and appearance of the Sutton Garden Suburb Conservation Area for the detailed reasons put forward in the Resdents' Association's representations made at previous stages of the LDF process. In making this response to the current consultation we also wish to refute inaccurate and misleading comments made by Mr Andrew Webb of Antler Homes Southern PLC in his response to the previous consultation round. He says that the site is 'derelict and overgrown...and serves no appreciable function to the wider community' In relation to its previous use as a community allotment he states that 'take-up dwindled over a period of time....the operation of the allotments became financially unviable and with demand being so slow, the allotments closed'. This is absolutely not the case. At the time of the closure of the allotments there was buoyant demand for the allotments and the vast majority of the plots were being actively worked. The reason the allotment site was closed was that the allotment-holders were given notice to quit by the owners in preparation for an intended sale of the site to building developers. This is also why, over 12 years on, the site is overgrown and unused. If the allotment holders had not been evicted to make way for a development that never happened, it would stilbe in beneficial community use. This site lies at the heart of the Sutton Garden Suburb Conservation Area. One of the founding principles of the Garden Suburb 100 year ago was the provision of green openspaces. To allow the largest green open space in the area to be built on would be to abandon that principle and to take the heart out of the area. Notwithstanding the fact that there is no current active use of the site (a situation brought about entirely by the site owners and not by the Council as stated by Mr Webb) its passsive presence still fulfills the role of a green lung, allowing views of sky, trees and greenery (contrary to Mr Webb's comments), which would be destroyed by residential building. Indeed the most recent decision of the Planning Inspectorate (APP/P5870/A/09/2109972) relating to the Conservation Area dismisses an appeal against refusal of an application to build one additional dwelling between existing houses bordering the site. The Inspector states that 'it would signifcantly erode one of the visual gaps between dwellings that help to maintain the spacious feel of this carefully laid out Garden Suburb and in so doing would have a harmful impact upon the character and appearance of the street scene. The Inspector also refers to 'the harmful effect... the propsoal would have upon the character and appearance of the Sutton Garden Suburb Conservation Area.' This application relates only to a single dwelling bordering the site. The building of a large number of houses on the site itself would produce

Mr Chris Carter33393

Sutton Garden Suburb

Residents' Association

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infinitely more damage to the Conservation Area. For these reasons, and the reasons previously put forward by the Residents' Association, we support the Council entirely in its decison to maintain the existing designation of this site and consider that, in this respect, the Council's Site Development PoliciesSubmission Document should be confirmed.



SDPPS27

Yes Yes D2: Land to North West of Jessops Way, Beddington Lane has been withdrawn from the Site Development Policies DPD as a potential area for development. This is welcomed.


The Mayor of London

Paragraph 5.5

Paragraph 5.5

SDPPS41

Yes Yes The Metropolitan Police Authority welcomes the inclusion of Indicator (64) "Number and Proportion of Major Developments within the Borough adopting 'Secured by Design'", and the Borough target to achieve 100 per cent of major development within the Borough adopting 'Secured by Design'.

Mr John Smith107920



Glossary of terms - Appendix 9

Glossary of terms - Appendix 9

SDPPS56

No No Effective Appendix 9 of the document provides a definition of Social and Community Infrastructure (Facilities). [In accordance with our submission to paragraph 3.228 HMCS urges] that this definition be amended to state: "including education; health and social care facilities; leisure facilities; children's services; community services, including community halls, meeting places, places of worship, youth services and libraries; police shops, CRIMINAL JUSTICE FACILITIES, safer neighbourhood accommodation and general police facilities nad other emergency services."

Ms Amy Jones406951

DPP LLP for Her Majesty's

Court Service

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APPENDIX 2b: Representations on the Site Development Policies Proposed Submission – Not Duly Made


Representations on the Site Development Policies Proposed Submission - Not Duly MadePolicy, Para or Section/ Rep No


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SDPPS64

NOT DULY MADE. As character often derives from the surviving built form as well as natural features, English Heritage suggests that the need to respect and retain should also include built environment where appropriate. This is particularly important as the policy specifically includes reference to extensions as well as new development. Reference to the English Heritage/CABE "Building in Context Toolkit" and or CABE's "Building for Life " aaessments in paragraph 3.15 could assist in the promotion of good design.

Mr Graham Saunders32844

English Heritage

Policy DM3 - Enhancing the Street Scene and Public Realm

Policy DM3 - Enhancing the Street Scene and Public Realm

SDPPS65

NOT DULY MADE. The importance that the public realm plays in sense of place is rightly emphasised bythis policy but specific reference to the contribution of historic surfaces and features of the public realm isnot mentioned. Restoration and repair of historic street furniture, eg horse troughs or traditional sign posts etc, should be eligible environmental iimprovements under planning obligations. English Heritage welcomes the reference to reducing clutter in paragraph 3.20 particularly with Areas of Special Characterand the settings of heritage assets.


English Heritage

Policy DM4 - Historic Environment

Policy DM4 - Historic Environment

SDPPS66

NOT DULY MADE. The current wording of the policy is ambiguous and potentially in conflict with the adivce in PPG15. Proposed demolition of listed buildings should be regarded as exceptional (as recognised in paragraph 3.26 of the justification) and the demolition of buildings making a positive contribution to the special character or appearance of Conservation Areas is subject to the test set out in PPG15 parapgraphs 3.16-3.19). These should be distinguished in the policy from locally listed buildings or that that make a contribution to Areas of Special Local Character, where retention is presumably justified because they are key elements that contribute to local distinctiveness. In addition, point (e) needs greater amplification. The following should be used to help achieve this: "(e) The Council will grantplanning permission for development with archaeological priority areas (as shown on the Proposals Map)if accompanied by an archaeological evaluation, which assesses the archaeological implications of the development and which proposes effective mitigation measures to safeguard the area from adverse development. The Council will expect the applicant to have sought pre-application advice from the Greater London Archaeological Advisory Service before submitting an archaeological evaluation. WHERE MITIGATION INCLUDES ARCHAEOLOGICAL EXCAVATION, A SCHEME SHOULD BE SUBMITTED FOR EXCATION, ANALYSIS, PUBLICATION AND ARCHIVE DESPOSITION OF THE RECORDS MADE, AND FOR THE PUBLIC DISSEMINATION OF THE RESULTS, TO FURTHER UNDERSTANDING."


English Heritage



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SDPPS67

NOT DULY MADE. English Heritage recognises and supports the need for sustainable design and construction. However, the re-use of historic buildings is inherently sustainable as it retains embodied energy and reduces consumption from demolition, provision of new materials and associated transport. The repair and re-use of buildings can also support local skills and employment. English Heritage is therefore concerned to see that the implementation of performance standards for conversions is promoted without regard to the wider sustainability points above and also the specific exemption that listed buildings and historic buildings in Conservation Areas currently have under Part L of the Building Regulations. Whilst we recognise that the environmental performance of historic buildings does need to be addressed the policy wording and justification should promote a balanced approach taking due regardof impact on character and historic interest. Information on the thermal performance of historic residential buildings can be accessed on the English Heritage "Climate Change and Your Home" website


English Heritage

Policy DM13 - Light Pollution

Policy DM13 - Light Pollution

SDPPS68

NOT DULY MADE. English Heritage supports the advice relating to the potential impact of inappropriate lighting and suggests that the potential adverse impacts on the character and appearance of the historic environment should also be specifically referred to. There is also potential for sensistive lighting proposals to enahnce historic buildings and areas, reinforcing civic pride and the quality of place and the promotion of such schemes should also be considered.


English Heritage

Policy DM15 - Green Belt/Metropolitan Open Land

Policy DM15 - Green Belt/Metropolitan Open Land

SDPPS61

NOT DULY MADE. The Highways Agency would recommend that an apporpriate assessment of infrastructure requirements is performed for proposed development sites in greenbelt land. Funding towards the necessary public transport infrastructure improvements should be sought and secured prior to construction of any new development on greenbelt land. Furthermore, the occupation of such developments should be phased in line with necessary transport infrastructure.Mr Patrick Blake32774

Highways Agency

Policy DM16 - Open Space

Policy DM16 - Open Space

SDPPS69

NOT DULY MADE. It is essential that this policy explicitly recognises the heritage value of the Borough's open spaces. It should be recognised that many of the open spaces in the Borough, including those which may have nature conservation value, may also be of historic importance. PPG15 makes reference to the need for local planning authorities to consider the heritage value of historic parks and gardens and the wider historic landscape when defining planning policies (paragraphs 2.24 and 2,26). In addition, many of the open spaces identified may have an integral relationship with the significance of other heitage assets, such as the special character and appearance of a Conservation Area or the setting of a Listed Building. The historic interest of open space is not considered in this policy and it should be included, for example, when considering planning permission for small-scale structures.


English Heritage

Policy DM17 - Biodiversity, Habitats and Species


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SDPPS70

NOT DULY MADE. Consideration of the historic interest of river corridors and walkways should also be incorporated into proposals for physical works (including culverts) and also in management.


English Heritage

Policy DM30 - Housing and Backgarden Land

Policy DM30 - Housing and Backgarden Land

SDPPS71

NOT DULY MADE. English Heritage welcomes the provision of a balanced framework for the consideration of housing in backgarden land. However, there is a concern that the extensive discussion of biodiversity and ecological crieria obscures the important issue of the contribution that backgardens make to the character of Conservation Areas and Areas of Special Local Character. Even small gardens can have an important role in demonstrating urban morphology and imparting distinctive character. It is therefore important that up-to-date appraisals are in place for residential Conservation Areas and those urban areas where residential use is a significant element of retail or other uses. We suggest that cross references to the chracterisation studies and also Conservation Area appraisals etc in the justification would provide further clarification.


English Heritage

Policy DM35 - Development in Town and Local Centres


SDPPS62

NOT DULY MADE. The Highways Agency supports Policy DM35, however, we suggest the policy shouldgo further in recommending that travel-intensive uses such as supermarkets and larger shopping centres, offices and businesses should be located in or close to town centres and near public transport hubs. This would help ensure that the Strategy is in line with PPG13 paragraph 20(2).

Mr Patrick Blake32774

Highways Agency



SDPPS72

NOT DULY MADE. English Heritage welcomes the explicit regonition of the historic and cultural significance of Cheam and Carshalton District Centres which has led to their designation as Conservation Areas, but the historic environment has an important contribution to make to the majority oftown centres in the Borough as recognised by PPS4. There is a danger that in the explicit reference to the two district centres without appropriate reference to the historic environment in the other centres the wrong message will be sent.


English Heritage



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SDPPS60

NOT DULY MADE. Paragprah 4.34 and the development brief should acknowledge that Area B will only become available following the outcome of a public consultation that supports alternatives to inpatient provision at Sutton Hospital provison for inpatients.

Mr Andrew Grimes67320

Sutton and Merton Primary

Care Trust

A12: Orchard Hill, Carshalton Beeches

A12: Orchard Hill, Carshalton Beeches

SDPPS73

NOT DULY MADE. The buildings of heritage value should be identified - presumably for retention? The significance of landscape to historic and present uses on the site should also be considered. Under the heading "The site is allocated for" development schemes should pay regard to the opportunities for the tnterpretation of and imprvements to the setting of the scheduled ancient monument. The following amendmenrs should be made: "Any development should pay particular regard to... Enhancing the settingand interpretation of the Scheduled Ancient Monument."


English Heritage

A18: Council Offices, Denmark Road, Carshalton

A18: Council Offices, Denmark Road, Carshalton

SDPPS74

NOT DULY MADE. Any development scheme should pay particular regard to the evaluation of the archaeological priority area at and early stage.


English Heritage

A19: Council Car Park, Denmark Road, Carshalton

A19: Council Car Park, Denmark Road, Carshalton

SDPPS75

NOT DULY MADE. Any development scheme should pay particular regard to the evaluation of the archaeological priority area at and early stage.


English Heritage



SDPPS58

NOT DULY MADE. The draft development proposals should reflect 4.33 of the DPD which shows strong support for a health facility on the Felnex site. The word "possible" should be deleted from the phrase "possible healthcare facility".




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Care Trust

A25: Wallington Square, Off Woodcote Road, Wallington

A25: Wallington Square, Off Woodcote Road, Wallington

SDPPS76

NOT DULY MADE. Any development scheme should pay particular regard to the setting of the Grade II Listed Town Hall. If proposals exceeding the Core Strategy Area of Taller Building Potential guidance arebeing contemplated (ie 4-6 stroeys) early evaluation of the potential zone of visual influence should be required.


English Heritage

A31: Victoria House, London Road, North Cheam

A31: Victoria House, London Road, North Cheam

SDPPS59

NOT DULY MADE. The PCT would like the Vicotria House to include the potential to accommodate a health facility in the event that site A3 (Cheam Leisure Centre) does not come forward for development. The PCT aniticpates a need for improved health facilities in North Cheam and is seeking to improve the likelihood of a suitable site coming forward.



Care Trust

A32: Wandle Valley Trading Estate, Mill Green Road, Hackbridge

A32: Wandle Valley Trading Estate, Mill Green Road, Hackbridge

SDPPS77

NOT DULY MADE. Any development scheme should pay particular regard to the setting of the listed building and the three villas. There should also be early evaluation of the archaeological priority area.


English Heritage

C4: The War Memorial Hospital/ Ashcombe House, The Park, & Cedar Close, Carshalton

C4: The War Memorial Hospital/ Ashcombe House, The Park, & Cedar Close, Carshalton

SDPPS78

NOT DULY MADE. English Heritage suggests the wording be amended to preserving and enhancing the special character of the Conservation Area. There should also be an early evaluation of the Archaeological Priority Area.


English Heritage

C9: Road Improvement Scheme, Beddington Lane, Beddington


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SDPPS79

NOT DULY MADE. Impact upon the setting of the conservation should be included and particular regard should be had for the potential impact of signage and street furniture - eg railings.


English Heritage

C10: Traffic Management Scheme, Carshalton District Centre

C10: Traffic Management Scheme, Carshalton District Centre

SDPPS80

NOT DULY MADE. Particular regard should be paid to the impact of signage and street furniture on the character and appearance of the Conservation Area and opportunities for reducing street clutter. Guidance from the "Manual for Streets" and/or English Heritage;s "Streets for All" should be referenced.


English Heritage



SDPPS82

NOT DULY MADE. Sutton United Football Club would like to record its support for the above proposal but would like to set out why we believe this to be such an excellent idea worthy of being adopted as partof the Borough's development plan. Collingwood Recreation Ground, not so long ago, used to provide a sports facility enjoyed by junior teams of all ages. The park was also enjoyed by local residents as an amenity for walking their dogs, as a cut-through into Sutton or simply as a nice place to sit and watch the world go by.The deterioration of this amenity has not only deprived residents of these pleasures, the parkhas become a much less safe place. Consequently, residents do not always feel confortable about using the Recreation Ground as a thoroughfare; it is not necessarily the safest place in which to have a children's playground and at Sutton United we have suffered several break-ins where people have accessed the stadium from the recreation ground, most recently in January this year. The proposed development would, we believe, go a long way to address these issues. In fact we believe the benefits of the development would be significant: (1) New pitch, including a modern artificial surface, that would provide training and match facilities for residents of the borough to participate in sport; (2) Sutton United already has 15 boys teams and is proposing to run additional teams that would provide sporting opportunities for girls, women and disabled people that are not currently available; (3) The increased usage of the recreation ground, including controlled evening use, would bring better lighting levels, with more people in the vicinity, and so discourage crime and encourage residents to use the park more frequently again and in safety; (4) The development would provide cafeteria facilities available to the general public and also a local community facility as requested by the Metropolitan Police; (5) The safety of the children's play area would be greatly increased. The scheme is fuflly supported by the Police and by the Surrey County Football Association and also by Sutton Cricket Club, and we think their suggestionfor a cricket square in the park is very sensible. The development would benefit from significant grant aid from the Football Association that would make the scheme much more affordable and cost effective. Furthermore, with Sutton United FC taking on the operation and maintenance responsibilities for the

Mr David Farebrother335625

Sutton United FC


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facility, there would be no ongoing costs for the London Borough of Sutton. Indeed, there may even be a small net income to share. We believe that this opportunity is too good to overlook. The circumstances might never again line-up in favour of such a development.

Monitoring

Monitoring

SDPPS63

NOT DULY MADE. Table 5.1 identifies the Borough's targets for promoting sustainable transport and accessibility. Although the Highways Agency is fully supportive of these targets, we suggest that further consideration is given to the following indicator as part of promoting sustainble transport and accessibility: "The proportion of trops made by non-car modes."Mr Patrick Blake32774

Highways Agency

Monitoring

SDPPS81

NOT DULY MADE. The indicators and associated targets relating to buildings at risk should be amendedto refer to Heritage Assets at Risk in recognition that the historic environment is holistic and to reflect the approach set out by English Heritage in the national "Heritage at Risk Register". The heritage assets at risk will include listed buildings, conservation areas, registered parks and gardens and scheduled ancientmonuments - these could be referreed to explicitly as a subset of indicators if required.


English Heritage


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APPENDIX 2c: Representations on the Site Development Policies Proposed Submission – Sustainability Appraisal


Representations on the Site Development Policies Proposed Submission Sustainability AppraisalPolicy, Para or Section/ Rep No


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Paragraph 4.13 Introduction to the Borough

SA: Site Development Policies Proposed Submission

SDPPSSA1

NOT DULY MADE. In Paragraph 4.13 reference is made to the heritage assets of the Borough and in particular Conservation Areas and Areas of Special Local Character. Cross referencing to or the provision of an appropriate map would aid clarity.


English Heritage

Paragraph 4.153 Archaeological Sites & Scheduled Ancient Monuments


SDPPSSA2

NOT DULY MADE. Paragraph 4.153 lists the Registered Parks and Gardens - these should appear in the evidence base, ideally in map form and be cross referenced.


English Heritage

Paragraph 4.171 Renewable Energy and Sustainable Design and Construction


SDPPSSA3

NOT DULY MADE. Paragraph 4.171 should distinguish between new build and conversion/retrofitting as they have different impacts and potentially different outcomes.


English Heritage

Map 4.1 Borough Context


SDPPSSA4

NOT DULY MADE. This map of the Borough context does not present the historic environment in a clear manner. What is the definition of a Strategic Heritage Area in the key and how does this differ from Conservation Areas or other area-based historic assets, eg parks and gardens. How does this map correlate toother Borough context maps in the accompanying documents?


English Heritage


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Map 4.6 Characterisation in LB Sutton Local Setting


SDPPSSA5

NOT DULY MADE. The Conservation Areas are not easily distinguished on this map and without a key giving the names it is of limited use. Cross referencing or replicating the Conservation Areas map provided elsewhere would assist. Local green designations and nationally registered parks and gardens are not included here (or elsewhere)


English Heritage

Theme 2 Strategic Objectives


SDPPSSA6

NOT DULY MADE. Theme 2 Strategic Objectives. The potential of the inherent sustainability of re-using and recycling buildings is not adequately recognised. The potential impact of inappropriate application of performance standards on historic buildings requires consideration.


English Heritage

Table 5.1 Policy Issues in Relation to the Five Themes of the Core Planning Strategy


SDPPSSA7

NOT DULY MADE. Table 5.1. English Heritage suggests that the historic environment could equally apply under Theme 2 - Achieving Environmental Sustainability.


English Heritage

Proposed Changes to Development Management Policies


SDPPSSA8

NOT DULY MADE. |See other observations in relation to the proposed targest and the conversion of historic buildings.


English Heritage

Policy DM4 Historic Environment


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Policy DM4 Historic Environment


SDPPSSA9

NOT DULY MADE. Policy DM4. Suggest clarification of what is meant by unlisted building of merit - is this positive contributor in a Conservation Area or a building in Area of Special Local Character, or both?


English Heritage

Objective 2a.1 Historic and Cultural Environment


SDPPSSA10

NOT DULY MADE. Objective 2a.1. Subject to consideration of how to apply targets, Policy DM5 relating to conversions could have small beneficial effects. Policy DM24 controlling the provision of HMOs etc could also be beneficial for the historic environment.


English Heritage

Objective 3.2 and 3.3 Public Open Space and Landscape Quality


SDPPSSA11

NOT DULY MADE. Objective 3.2 and 3.3. Subject to providing information on where open space and landscape quality includes the historic environment Policy DM4 could also have smaller beneficial effects


English Heritage

Objectives 4.1, 4.2 and 4.3 Energy Efficiency, Decentralised Energy Networks and Renewable Energy, Sustainable

Design and Construction


SDPPSSA12

NOT DULY MADE. Objectives 4.1, 4.2 and 4.3. Without recognition of the potential adverse impacts that adaptation can have on sustaining the historic environment (see other observations), the beneficial effects of the proposed policies could be overstated.


English Heritage

Objective 6.1 Sustainable Waste Management


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Objective 6.1 Sustainable Waste Management


SDPPSSA13

NOT DULY MADE. Point 6.1. Retention of positive buildings and re-use of buildings as envisaged under the historic environment policy DM4 could also reduce waste generation.


English Heritage

Paragraph 11.15 Policy DM4 - Historic Environment


SDPPSSA14

NOT DULY MADE. Paragraph 11.15. In addition, Policy DM4 will assist in reducing carbon emission by encouraging re-use and recycling buildings, rather than demolition and rebuild, saving embodied energy. It will also reduce waste production.


English Heritage


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APPENDIX 3:Letter to the Council from the Mayor of London


APPENDIX 4:Letter to the Council from the Government Office for London


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