Core Strategy Issues and Options Consultation Document (Read-only)

Search Representations

Results for Dooba Investments VI Ltd search

New search New search

Comment

Core Strategy Issues and Options Consultation Document (Read-only)

Question 2

Representation ID: 5757

Received: 28/01/2011

Respondent: Dooba Investments VI Ltd

Agent: Broadway Malyan

Representation:

Response: We do not think all the relevant issues have been identified clearly. This is because issues that address common subject matter (e.g the Town Centre) are not grouped together coherently. This is a consequence of grouping issues under "themes". The choice of the five themes is a major influence on the way in which issues are defined. The five themes tend to limit and categorise the issues and do not provide a sufficiently clear framework for the issues to be set out (see our response to the question on themes below). We have suggested, under Questions 7 and 8 below, that the "themes" be more specific and deal with definite topic areas, (rather than based on concepts such as "lifestyle" and "prosperity"). More importantly from our perspective, this would allow Town Centre issues to be grouped together under a "Town Centre" theme. Issues for Harlow Town Centre are currently dispersed under several different themes. Town Centre issues are also divided further according to whether they have been defined through community engagement or from the technical evidence base. The important point here is that the issues in Section 2 that affect the Town Centre cannot, at present, be read together as a coherent statement of matters the Core Strategy should address.



We therefore suggest that all the following issues be grouped together under a new Town Centre theme and for a number of changes to be made as we have indicated: New heading - "Town Centre issues"



Currently under "Prosperity" (identified from community and stakeholder representatives): "The Town Centre should be more attractive and vibrant"



the retail offer and choice in the town and neighbourhood centres need to be improved"



Currently under "Lifestyle" (identified from community and stakeholder representatives): ï‚Â*



Maintain the strong public art / cultural heritage of the town as it develops

Enhance and promote more art, culture and entertainment facilities in the town

Improve theatre provision for Harlow and the wider area Improve the evening use of the Town Centre by introducing more cultural and leisure activities"



Currently under "Placeshaping" (identified from evidence base studies):



Environmental enhancements along the key gateways to the town and particularly to the Town Centre should be endorsed"



Suggested Change - that the word "endorsed" be replaced by "encouraged"

Currently under "Prosperity" (identified from evidence base studies):

Harlow has below average provision of convenience and service units and of high quality retailers compared with the national average and competing centres in the region



An increase in the quantum and quality of the Town Centre's retail and leisure offer, along with other Town Centre uses, is required to reduce the proportion of shoppers and spend 'leaking' out of the district to other competing centres.



Suggested Change: - that the following words be added to the end: ......"and to provide an appropriate level of retail infrastructure as the population expands"



Diversification is needed in the Town Centre through mix use development comprising entertainment, leisure, food, drink and residential uses to help strengthen the town's evening economy



Suggested Change - we suggest that the above issue be replaced as it pre-empts the location and extent of town centre redevelopment. We suggest the issue be reworded as: "Appropriate and targeted Town Centre regeneration as part of a cohesive strategy of encouraging both private sector initiatives and public sector intervention, within the context of repairing the urban fabric and reinforcing the town's attraction, distinctive character and form"



Restructuring of the town-centre is needed to address service access, poor edge quality and the nature of the public realm to include possible re-introduction of through vehicle movement"



Suggested Change - We suggest this issue be re-worded as follows: Restructuring town-centre infrastructure to improve and rationalise service access and to address the current poor edge quality and including, where necessary, public realm quality enhancement and shopper circulation to strengthen circuits, should be a priority. Reviewing the prospects for introduction of vehicle movements, such as public transport routes and evening access to encourage greater use of the centre in the evening, should be fully explored".

Full text:

Questionnaire responses incorporated as part of a written submision

Comment

Core Strategy Issues and Options Consultation Document (Read-only)

Question 6

Representation ID: 5759

Received: 28/01/2011

Respondent: Dooba Investments VI Ltd

Agent: Broadway Malyan

Representation:

Response: We agree with the vision as defined in the "Harlow Regeneration and Social Inclusion Strategy (2010-15)" and in particular the statement defining Harlow as "a sub regional centre and retail destination" We would suggest that the Vision drawn from the Community Strategy should include the words "a strong Town Centre and retail destination".

Full text:

Questionnaire responses incorporated as part of a written submision

Comment

Core Strategy Issues and Options Consultation Document (Read-only)

Question 8

Representation ID: 5761

Received: 28/01/2011

Respondent: Dooba Investments VI Ltd

Agent: Broadway Malyan

Representation:

Response: We disagree that the Core Strategy themes cover the range of planning issues in Harlow. The five themes cover both specific topics such as "housing"and "infrastructure" and broad concepts such as "placemaking", "prosperity" and "lifestyles"

We feel that it would be better for the themes to deal more specifically with recognised topics that more clearly reflect Harlow as a place. This would make it easier for the issues, objectives and policy areas to identify matters that are specific to Harlow.

We would suggest that the very broad theme of "prosperity", be broken down into more specific and identifiable themes as follows:

Job and Economic growth
Regeneration
Town Centre

In particular, the future of the Town Centre will be a major theme in the new Core Strategy and should be identified as such. This would make it easier to define and group together all the relevant Town Centre issues, objectives and possible policy areas, under the "Town Centre" theme.

Full text:

Questionnaire responses incorporated as part of a written submision

Comment

Core Strategy Issues and Options Consultation Document (Read-only)

Question 10

Representation ID: 5763

Received: 28/01/2011

Respondent: Dooba Investments VI Ltd

Agent: Broadway Malyan

Representation:

Response: Subject to the comments we have made above in response to questions on the issues and themes, and the other matters we have raised in response to this consultation, we largely agree that the Core Strategy objectives provide a framework for the regeneration of Harlow. However, the Core strategy should provide the strategic aspiration for improvement to the town centre generally to meet the needs of residents and the growing population, to attract greater levels of visitors and should not seek to identify, at least at this stage, how, where and through what mechanism such will be achieved. The Council should be clear about the distinction between the role of the Core Strategy in setting a framework and the possible role of SPD or an Area Action Plan in providing greater detail.

Full text:

Questionnaire responses incorporated as part of a written submision

Comment

Core Strategy Issues and Options Consultation Document (Read-only)

Question 12

Representation ID: 5764

Received: 28/01/2011

Respondent: Dooba Investments VI Ltd

Agent: Broadway Malyan

Representation:

Response: We consider that, for the most part, the policy areas cover the range of issues relevant to regeneration of Harlow Town Centre. However, these policy areas are listed under the three different themes of "placeshaping", "Prosperity" and "infrastructure". This echoes the concerns we have raised above about issues and themes. This structure has the effect of dispersing and diluting policy that applies to the Town Centre.

To address our concern, we would suggest that all the policy areas that address the Town Centre be grouped under a Town Centre theme and under objectives that specifically concern the Town Centre.

Full text:

Questionnaire responses incorporated as part of a written submision

Comment

Core Strategy Issues and Options Consultation Document (Read-only)

Question 20

Representation ID: 5774

Received: 28/01/2011

Respondent: Dooba Investments VI Ltd

Agent: Broadway Malyan

Representation:

We are concerned that the Core Strategy document does not properly fulfil its role as an "Issues and Options" consultation because it only deals with options for spatial growth around Harlow. It does not deal with options in a wider sense in terms of development and regeneration of the whole town. In particular, we consider that the document must define options for the Town Centre and consult upon them.

We consider this to be an essential requirement that must be addressed before a new Town Centre Strategy SPD is prepared and finalised. Defining options for the Town Centre in the Core Strategy is also an essential basis for the council to choose a developer partner for Town Centre redevelopment.

It is clearly the role of a Development Plan Document to define options. Para 4.26 of PPS12 states it will in the Government's view be appropriate to involve the community in considering the options for the strategy before the final document is produced". The Plan Making Manual produced by the Communities and Local Government Department, states: "Public participation early in the process and involvement of the public in considering different options and their impacts will help to ensure that the draft plan published under Regulation 27 is the 'best plan' and commands wide support".

Paragraph 4.28 of PPS4 states that: "There is no point in proceeding with options for the Core Strategy which cannot be delivered as a result of failure to obtain the agreement of key delivery agencies."

Town Centre SPD

It is clearly difficult for a Town Centre SPD to proceed before the Core Strategy has defined options for Town Centre development and assessed the responses from key stakeholders and the public.

In our view, the council needs to consider the role and level of detail in the Core Strategy relative to that of an SPD and /or an Area Action Plan. The current economic climate predicates against early physical intervention and consequently time should be allowed to prepare policy foundations to assist appropriate intervention in due course.

A new Town Centre SPD should, by definition, supplement statutory plan policy. PPS 12 defines the role of SPD as to provide greater detail on the policies in DPDs and clearly indicates that it should not deal with matters that should be covered in a DPD (as SPD does not have the benefit of public examination).

At present, the SPD must supplement saved local plan policies as it cannot pre-empt major new decisions about the nature and extent of Town Centre redevelopment that should be made through the Core Strategy process.

This means the SPD can only bring forward specific development proposals (particularly those involving comprehensive redevelopment and the use of CPO powers) that are consistent with the Town Centre and Edge of Town Centre Redevelopment Areas as defined in saved Local Plan policies RTCS6/1-3 and RTCS8 and as shown (as blue areas) on the proposals map Town Centre inset.

However, these saved Local Plan policies are now many years out of date and the themes, issues, objectives and policy areas now defined in the Core Strategy consultation document are clearly intended to move well beyond Town Centre policy as defined in the local plan. There seems little point in preparing an SPD on the basis of saved local plan policies that are about to be superseded.

We understand that consultants have been appointed to prepare the Town Centre SPD and we have discussed the principles of this with them as well as provided a statement of the matters we feel the SPD could address. We have also written to Harlow Council planning officers to set out our views on the scope and limitations of this SPD.

We are of the opinion that, rather than prepare an SPD at this stage, it would be advantageous for the consultants to assist the preparation of Town Centre options as part of the Core Strategy process (with inputs from key Town Centre stakeholders including CEG).

We are concerned that the Council is rushing into preparing a new SPD as a knee jerk reaction to the recent disappointment of the loss of their selected development partner for the regeneration of the northern quarter and that the council is concerned to be "seen to be doing something" where, in our experience, patience and proper preparation will maximise the prospects of appropriate and earlier intervention.

Overall, should the Council proceed with an SPD, there is a need for a clearer distinction between the role and content of the Core Strategy on Town Centre matters and that of the proposed Town Centre SPD. We consider the Core Strategy should very clearly define the different roles of the DPD and SPD.

Town Centre Redevelopment - Preferred Developer Selection

It is also very difficult to envisage the Council beginning any procedure to appoint a new preferred developer partner in advance of the definition of Town Centre options in the Core Strategy. The selection process is likely to involve the submission of proposals and the selection of preferred developer will be partly on the basis of the strength of those proposals.

The definition of options for the Town Centre in the Core Strategy (and views expressed about them by key stakeholders and the public) would provide a more informed basis both for the preparation of submissions and their assessment. Crucially, it would begin to provide a proper statutory footing for this process.

Any process of selecting a preferred developer in the short term is in danger of pre-judging the proper identification, assessment and selection of options for Town Centre redevelopment through the Core Strategy process. It would therefore be premature to the statutory development plan process.

There is also limited appetite in the current climate for extended development selection competitions or for projects involving large scale land assembly or CPO risk. Consequently, we would envisage few capable delivery partners committing the extent of resources Harlow deserves to secure the regeneration it aspires to.

Premature remarketing will enhance the risk of a repeat of the recent process and is likely to lead to disappointment or inappropriate development.

Options

On the basis of the above assessment, we consider the Core Strategy must set out options for Town Centre improvement. These could include the following:

A greater or lesser extent of growth in retail floorspace (linked to the conclusions of the updated Retail report, the uncertainty associated with the growth of the town and the scope for retail development to capture / retain retail spending)

Options for the extent of growth in supporting uses including leisure, entertainment, culture, recreation, employment and residential

Redevelopment confined to the areas proposed in the Local Plan or proposed over a wider area of the Town Centre

Re-development proceeding comprehensively across the Town Centre by a single developer partner or by way of proposals from a collective of individual landowners and developers that comply with an overarching planning, masterplanning and design framework

Different options as to how developments and regeneration might proceed in phases and how these phases should be defined

Choice of Options

We have stressed the importance of defining options for Town Centre improvement and we now return to address the question of how we think Harlow Council should encourage future shopping development within the Town.

We made the following points in our written response to questions asked of key stakeholders by Entec as part of their work on a new Town Centre SPD. These points are more directly relevant to the Core Strategy and have therefore been repeated for the purposes of this consultation:

1. The Council has a clear ambition to transform the environment, offer and attraction of Harlow Town Centre to serve a growing community, in parallel with the town's wider growth and regeneration agenda. We very much support these objectives.

2. However, substantial housing growth at Harlow will only be realised in the longer term and, following revocation of the East of England Plan, both its scale and location are subject to major uncertainty.

3. This uncertainty extends to the related growth in retail expenditure and the scope to regenerate the Town Centre.

4. It is therefore important that the Core Strategy, whilst setting an overarching framework for major change, is realistic in defining what can be achieved in the short and medium term.

5. Market confidence remains fragile. If the Town Centre strategy is too ambitious it will be dismissed by those responsible for its delivery. On the other hand, if the strategy is too conservative it will fall short of the Council's ambition. Balance is needed in laying the foundations and expectations need to be managed carefully.

6. The Stockland strategy, whilst expressing a commendable ambition for the future of the town, was over-ambitious and ill conceived and could not have been realised in the form proposed.

7. We are concerned that in seeking to re-establish the commitment and purpose associated with the Stockland proposals, lessons will not be learned from that process and the Council could rush though a new policy approach which does not establish the essential "buy in".

8. Overall, following changes in the direction of strategy for the Town Centre over the last few years, it is vital to place future proposals on a sound footing and ensure they are capable of implementation.

9. Key drivers of the Town Centre policy are the need to ensure realistic, viable and flexible proposals that are capable of implementation with a clear distinction between short, medium and longer term plans.

Terminus House

We consider that the Terminus House office building and car park have redevelopment potential. The Council's 2007 Town Centre Strategy indicated the development potential of this site and there is merit in repeating some of the principles defined in that document (as we have done in our recent statement for Entec on the new SPD). The previous strategy included the following references to Terminus House.

The area around Terminus House and the bus station also represents a significant opportunity within the Town Centre. The area is currently an important Town Centre gateway for visitors arriving by bus and by car. It is relatively isolated from the Town Centre because of the barrier of the open bus station, and pedestrian routes across the area are poor." (para 5.19)

The objectives for Town Centre East set out in paragraph 5.20 included a key role for Terminus House in acting as a gateway to Harlow Town Centre.

The third objective is to "Re-inforce key Town Centre gateways through built form at the junction of Fourth Avenue, Fifth Avenue and along Velizy Avenue including Terminus House"

Paragraph 5.25 referred to the development potential of Terminus House as follows:

"Terminus House also represents an important redevelopment opportunity to provide a mix of uses. A taller building that responds to the height of the existing tower would be potentially acceptable. Development must include a mix of ground floor uses with strong frontage development to Velizy Avenue and surrounding streets and walks."

Paragraph 4.47 refers to the opportunity to provide "a more efficient modern on-street bus interchange facility" with the benefit of "reclaiming some of the land that the facility currently occupies to provide a new mix of development opportunities within an enhanced setting.

Paragraph 5.20 states that one of the objectives is to "provide a modern on-street bus interchange facility that is easy to access, fronted and well overlooked by adjoining development".

Whilst we would wish the Core Strategy to recognise the development potential and future role of Terminus House in relation to the rest of the Town Centre, great care needs to be taken before inadvertently frustrating urban renewal through incorporation of the site as part of a comprehensive redevelopment scheme.

Terminus House could form part of a wider development framework for the Town Centre but we are concerned that a comprehensive redevelopment may not be appropriate and, at this stage, should constitute no more than an option which should be fully tested as to whether it is actually necessary to secure beneficial improvements to the Town Centre.

We would welcome the opportunity to set out specific principles for the development of Terminus House, including its integration with the defined Town Centre development areas. These principles include the potential role of the site in providing a more efficient and effective east-west orientation of retail locations, points of attraction and pedestrian flow, together with potential to diversify Town Centre land uses and provide a much improved outward face and point of entry to the Town Centre.

Finally, in response to this question, we welcome the statements in section 5 "Guiding Future Development" sub section 5.10 Retailing, and in particular:

"The Core Strategy will consider the role and function of the town's retail centres at all scales (including the Town Centre........."

"The Core Strategy will define the role of these centres so that they can continue to meet the changing needs of the community as well as contributing to the regeneration of the town."

"The Town Centre should remain the main focus for retail development and initiatives to regenerate and improve the retail offer of the Town Centre are essential to its success and will be supported."

Full text:

Questionnaire responses incorporated as part of a written submision

If you are having trouble using the system, please try our help guide.