Consultation on Local Plan Part 2 Site Allocations consultation Nov-Dec 2013

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1 Consultation on Local Plan Part 2 Site Allocations consultation Nov-Dec 2013 Summary of comments received and initial officer response. Introduction: 37 organisations or individuals submitted comments on the Site Allocations consultation. Many of these provided additional information on the sites proposed. Further work will be done on individual sites as we progress to the next consultation, and all information received will be considered as part of that further work, alongside the output of further evidence such as the level 2 Strategic Flood Risk Assessment currently underway. This next stage will include further work on the deliverability of each site, likely timescales, and the particular uses and capacity (how much development is appropriate to a site). As a result of an independent health check from the Planning Officers Society we will also be reviewing the proposed allocations to distinguish between sites described as allocations for a change of use and those which could be better described as policy areas. This may result in some categories being removed from the plan. We will also be combining the site allocations and development management policies into a single document. This summary does not report and respond to every individual comment but summarises key points raised and provides information about the next steps we expect to take as a result of those issues. Rather more detailed responses are provided for some of the Special Policy Areas and Town Centre sites at this stage because these are the major sites for delivering The Core Strategy, but further work will be done on all the sites before the next consultation. Full detail of comments relating to each site can be viewed online at

2 This summary begins with cross cutting or general comments and then goes on to consider comments on multiple sites and then on particular sites or type of site, ordered by chapter. After that is a list of additional sites proposed during the consultation process. General or cross cutting comments: Hertfordshire County Council Highways ask that certain transport documents be referenced and provide information on bus services to some sites. Hertfordshire County Council Property provide information on other community facilities provided by the county council, and note that there is no mention of waste management/recycling. WBC Additional information will be used as we do further work on each site, and documents will be referenced where appropriate. Waste management and recycling are covered elsewhere in the local plan. It is likely the site allocations and development management policies will be combined into a single document for the next stage which will make this clearer. Thames Water Utilities propose the use of Grampian conditions to secure appropriate drainage (i.e. conditions that require drainage to be in place before development begins) and to work with Council and developers to ensure appropriate water infrastructure. WBC we will continue to work with Thames Water Utilities to ensure appropriate infrastructure. These issues should be covered by existing Core Strategy policies along with new Development Management policies. The Environment Agency notes that a Level 2 Strategic Flood Risk Assessment is underway, the results of which will need to inform the final submission. Provided the Level 2 Strategic Flood Risk Assessment is completed prior to the formal submission, and the sequential approach is applied, there is no in principle objection to any sites proposed. WBC we will continue to liaise with the EA as the findings of the SFRA2 become available.

3 Natural England provide advice on site selection and object to proposed site allocations in close proximity to locally designated wildlife sites and corridors. They ask that we delete such allocations or ensure that sufficient mitigation or, as a last resort, compensation is available to ensure development will not have an adverse effect on locally designated wildlife sites, including areas of Ancient Woodland. They comment that that site allocations should also promote geodiversity and biodiversity and that developments should be required to achieve net biodiversity gain where possible. The Site Allocations Plan would also benefit from further consideration of soils, landscape and public rights of way WBC these comments will be fed into the site allocations process and Sustainability Appraisal as we progress with the site allocations. Geodiversity and biodiversity are promoted through the Core Strategy and Development Management policies. English Heritage make a general comment about seeking advice from the council s conservation staff and the county archaeologist, as well as from them on specific sites. They also note that the sustainability appraisal does not refer to conservation areas, and that it would be helpful for heritage assets including conservation areas to be shown on the map. WBC the council s conservation staff work within the team preparing the Local Plan and have been fully involved. The county archaeologist has also provided detailed comments. Information on conservation areas was provided for sustainability appraisal purposes although we agree that they have not been specifically referred to - such information will be added as we do further detailed work on each site. We are also reviewing the detail shown on the map. Dhiraj Pitamber comments that congestion at Bushey Arches is a major issue for that part of the town.

4 WBC - Congestion will be a consideration as we take sites forward through the site allocations process particularly for site H1 at Bushey Arches. Mary Forsyth asks for a glossary. WBC formatting comments will be fed into the next version of this document. Comments relating to multiple sites: Herts and Middlesex Wildlife Trust provide detailed comments on a number of individual sites. WBC we will use this information as we progress the plan, liaising with HMWT as required. Hertfordshire County Council Archaeology detail which sites may require further archaeological assessment, either before allocation, before determination of a planning application or by way of a condition. WBC we will use this site specific information as we put together further information on each site. Archaeological assessment can be delivered through the Development Management process on a case by case basis as development proposals come forward. Existing resources, such as the Hertfordshire Historic Environment Record and the Watford Extensive Urban Survey Report (2000), will help initial assessment processes. Where sites have known archaeological remains, the Council can insist on pre-application or pre-determination archaeological assessment, and the list of sites provided will be passed on to development management to this end.

5 Comments by Chapter Special Policy Areas Hertfordshire County Council, in their role as Minerals and Waste Authority provide information on safeguarded waste management facilities within SPA2, 3 and 5 and Watford Business Park. WBC we will refer to this information as we progress the plan and consider the inclusion of the proposed paragraph as we redraft the document. Thames Water Utilities would like developer funded investigations of capacity at the Health Campus and Watford Junction. WBC this should be provided for by proposed development management policies. SPA1 Town Centre Hertsmere Borough Council have no objection to the proposed SPA1 boundary. Hertfordshire County Council suggest archaeological assessment may be required. Mary Forsyth suggests keeping the town centre boundary within the ring road. WBC - Support for boundary noted. Other comments relating to the boundary will be considered as the line of the boundary is finalised through the plan stages. Archaeology assessment can be delivered through the Development Management process on a case by case basis as development proposals come forward. Existing resources, such as the Hertfordshire Historic Environment Record and the Watford Extensive Urban Survey Report (2000), will help initial assessment processes. Where sites have known archaeological remains, the Council can insist on pre-application or predetermination archaeological assessment, and the list of sites provided will be passed on to development management to this end.

6 SPA2 Watford Junction HSBC / Dalton Warner Davies comment that it is useful to adopt a wider spatial definition for the Watford Junction SPA boundary. WBC support noted. London Concrete ask that the safeguarded concrete batching plant area be shown. English Welsh & Scottish Railways Ltd also stress the importance of safeguarding rail freight facilities and retaining the goods yard although they may consider relocating within Watford. WBC - We agree it would be useful to show the safeguarded concrete batching area and will consider the best way of showing this (and other safeguarded sites in the borough) as we further develop maps for the plan, and appreciate the provision of a detailed plan showing this area and the shared access to the site. We consider that the inclusion of the Option B site should help to provide additional masterplan/design flexibility in the vicinity of the concrete batching plant given the development constraints the plant imposes on the area. Mary Forsyth questions the idea of a school between a railway line and main road. WBC the site is currently being investigated and is therefore not proposed as a formal allocation at this stage. However a school will be needed somewhere within or close to SPA2. SPA3 Health Campus Watford Health Campus LLP (represented by Terence O'Rourke) support SPA3 Watford Health Campus and the removal of Cardiff Road from employment designation (E2) and propose additional wording relating to the primary school.

7 WBC - we welcome the support in relation to SPA3 and the removal of Cardiff Road from employment designation. In relation to the primary school, we agree with the additional wording suggested and will update this in the next version of the document. Consistent wording will also be used for SPA2. Sport England comment on the need to clarify that sports facilities at Wiggenhall Road Recreation Ground, which will be affected by the proposed link road, need to be replaced with an equivalent facility within an acceptable timescale. WBC the link road currently has planning permission. Outline permission for the rest of the scheme is likely to be sought before the adoption of Local Plan 2. The comment will therefore be passed to development management colleagues to be taken into account in considering relevant applications. Herts and Middlesex Wildlife Trust welcomes the inclusion of land beyond the core development area, subject to the habitat areas (including the Riverside Park, River Colne and Local Wildlife Sites) being restored, enhanced and managed in the long term to strengthen the ecological network and deliver a significant net gain for biodiversity. WBC we welcome the support for the principle of the approach set out here for Green Infrastructure and we will consider the more detailed matters as the master plan evolves through the development management process. SPA4 Lower High Street HSBC / Dalton Warner Davies comment that the SPA4 area should be significantly reduced in size to ensure that retail proposals in the town centre and at Watford Junction are not detracted by significant amounts of retail growth in the Lower High Street area. WBC Part of the Lower High Street area is identified as an edge of town centre location and the remainder is an established retail area with a

8 focus on large shed style units. It is therefore sequentially preferable to the out of town location of the Watford Junction regeneration area, which is less established as a retail location in Watford. We consider that it is reasonable to identify an area that encompasses the whole potential retail area of the Lower High Street area, including the Frogmore House site, which also has the potential for some retail use in this location dominated by larger retail units. Given the level of demand/need identified in our retail need studies it is entirely possible that a degree of redevelopment activity focussed on larger shed style units will come forward in this area as it may be difficult to accommodate significant new retail capacity of this nature in the town centre given the constraints on land availability. Retail redevelopment activity could quite easily lead to potential environmental and traffic circulation improvements in the Lower High Street area, and so again we prefer to retain the existing definition of the SPA4 area. The Croxley Rail Link passes through this area with a new Metropolitan line station stop at the High Street Station, which is well situated for both the town centre to the north and the Lower High Street area to the south. Therefore, both these established retail areas will benefit from significant public transport improvements in the near future, which will make them more sustainable locations. Environmental improvements in this area will focus on enhancing the quality of the pedestrian environment and links between the town centre and the SPA along with any river related improvements both in terms of flooding and ecology. Hertsmere Borough Council note they have no objection to the proposed boundary for SPA4 (Lower High Street). For SPA4, the river corridor should be paramount. Reinstatement is preferred as part of flood resilience measures and environmental improvements. WBC Noted. This should be covered by policy SD12 of the Development Management Policies. SPA6 Western Gateway (and MXD7 Ascot Road) Indigo support the allocation of Ascot Road area for mixed uses and concur with the amount and type of uses proposed for MXD7. They do make

9 specific comments on the potential content of regeneration proposals for the MXD7 site. It is suggested that the wording should take more account of the potential arising from the Croxley Rail Link project; in particular with regard to the need for significant amounts of additional car parking. It is also requested that the reference to the area being suitable for designation as a neighbourhood centre be picked up in the range of uses for this area; specific reference should be made to the suitability of the ground floor of units for retail use to support this. The comments also suggest that due to the complexity of bringing the site forward and its highly sustainable locations the amount of affordable housing required on the site should be dropped along with a relaxation in the standards for car parking. They also request that other requirements such as open space requirements and the mix of units be more flexible. WBC - The support for the allocation of the mixed use area is noted. The Core Strategy does allow some options for the redevelopment of the site which include both employment and residential uses. The site would be a sustainable location for both an employment led scheme or a residential led scheme. With regard to the specific comments based on various design issues we would respond as follows: - Car parking for the new CRL station is likely to be situated on the adjacent lozenge site owned by the HCC but this matter is still under discussion. We will consider whether to include this lozenge site in the MXD7 designation. - We could designate the site as a neighbourhood area as suggested in the Core Strategy, but this depends on the facilities that are eventually provided in the area, and whether further retail and other community facilities are provided. - The level of affordable housing should be considered at the time of preapplication and application discussions, and based on viability assessment at

10 the time. This will be in the context of the affordable housing policy HS3 in the Core Strategy. - Parking standards for any potential residential development on the site should be discussed and agreed at the time of the pre-application and application discussions if appropriate, in conjunction with the relevant development management policies. We do not consider that Policy MXD7 should be specific about parking standards. - Play space provision is also subject to negotiation as part of any comprehensive development scheme put forward to the Council. Mixed Use Sites The Environment Agency stresses the need to demonstrate that the sequential approach has been used to inform the layout of mixed use allocations in the context of flood information. This is particularly important for SPA3, SPA4, MXD3 and MXD4. Hertsmere Borough Council raises no objection to the boundary of sites MXD3 and MXD4 but note that the flood risk issue is paramount. They also express concern about the amount and scale of retail development in general and therefore potentially on these sites. WBC flood risk issues will be taken into account in the light of the level 2 Strategic Flood Risk Assessment. Retail issues are responded to under the town centre/retail section. Mary Forsyth notes that any development at MXD3 also needs to be compatible with the listed building. Peter Brett Associates support the allocation of MXD4 Nissan Garage, Lower High Street on behalf of the owner of most of the site. They propose that the

11 site be extended to include the Watford Film House and Pump House along with the car park and some residential properties to square off the site. WBC nearly all of the properties (1-4 Local Board Road; 1a Local Board Road and the Pump House) are buildings of local interest. As such the inclusion of these properties would be resisted on the basis of their heritage value to the town. Under national policy guidance (NPPF) development proposals which did include their demolition would be required to demonstrate more public benefit from the new use than from the locally listed buildings. Sport England propose that MXD5 (also H6) should be excluded unless the skate park can be relocated. WBC comment noted, the council is looking for an alternative site for the skate park. Herts and Middlesex wildlife Trust comment on the need for avoidance and mitigation measures to protect biodiversity at MXD3 and 7. WBC comment noted, the protection and enhancement of biodiversity is covered by Core Strategy policy GI3. Town and Local Centre/Retail Hertsmere Borough Council express concern about the level of retail floorspace, particularly out-of-centre stores. They feel there is a clear danger of exaggerating floorspace needs in the light of trends in home shopping and expenditure patterns (connected to the wider economy). They express particular concern that there should be no further detrimental impact on facilities in Hertsmere, in particular Bushey village. Intu, the owners of the former Harlequin centre, support the focus on town centre retailing and the Charter Place allocation, but raise concerns about the potential scale of retail development coming forward at retail locations outside of the town centre which may detrimentally impact on the vitality and viability of the town centre.

12 WBC - The comments supporting town centre retailing and the Charter Place allocation are noted. With regard to retail provision outside of the town centre, given the scale of long term retail need identified in our evidence base we have an ongoing duty to identify sites that could become available for retail purposes and that would be suitable for retail purposes. Our preference is for this provision to be located in the Primary Shopping Area (PSA) of the town centre in line with the NPPF and the sequential test. However there are constraints to the various sites that we have identified as having this potential in the PSA. Therefore it is considered appropriate to make provision for and be open to appropriate and limited retail provision coming forward in locations outside of the PSA, with a preference for the SPA4 - Lower High Street as this is an established retail location. The scale and location of retail provision coming forward in the future is difficult to predict and therefore our approach is to be market led and work with landowners/developers where applicable to help unlock suitable sites, particularly in the PSA. Along with this approach, for sites outside of the PSA we would require a retail impact assessment with a sequential test approach to justify that the scheme in question will not have an adverse impact on the vitality and viability of the town centre, which the council is committed to retain as the primary location in Watford's retail hierarchy. We do recognise the inherent uncertainty of ongoing changes in consumer spending habits and overall direction of the economy. We will look again at proposals for MXD1 and 2 with a view to removing any reference to retail. R1 Sainsburys Sainsbury note that they would expect to see a store of at least comparable size to their existing store as part of any redevelopment. WBC - We agree that the potential redevelopment of this site should incorporate a supermarket of the same size as the existing supermarket but this would need to be integrated well with the other retail facilities on the redeveloped site and also with the town centre. This level of detail can be added as we progress the site allocations process.

13 R3 BT Telephone Exchange Telereal Trillium comment that the site should be either retail and/or residential led as retail development has not come forward since the allocation in the District Plan JM Rowe Investments Ltd support development of the land allocated as Site R3 for retail led mixed use development. However, they note that the site includes a number of separate sites in different ownerships in addition to the BT Telephone Exchange and this should be acknowledged in the plan. The plan suggests a comprehensive development is proposed but no details are provided regarding how this development will be delivered within the plan period. More information is required about the Council's strategy for bringing forward development and how it proposes to work with landowners to achieve the objectives set out in the Local Plan. Mary Forsyth asks if this site is no longer being considered for a potential bus station. WBC - We agree that a broadening of the policy wording to include retail led and/or residential led development on the site would provide useful policy flexibility in a part of the town centre where both retail and residential development are an acceptable and beneficial use for the town centre. Where feasible, we see this site as one which is well situated in the town centre to contribute to the medium to long term retail need that is forecast in our evidence base, but recognise that this needs to be market driven and viable due to the physical complexities of making this site available for redevelopment. Further work will be undertaken on the delivery issues of specific sites before the next consultation. A bus station is not currently considered a likely component. R4 Church Car Park English Heritage suggest a mixed use scheme may be appropriate, to preserve and enhance the setting of St Mary s Church and conservation area.

14 WBC - Any redevelopment plans would be guided by consideration of the potential for a mixed use scheme. The status of the adjacent Conservation Area and other heritage assets must be considered in the design of any potential new development. Hertsmere Borough Council comment that they have no objection to the Bushey Arches Neighbourhood Centre shopping frontage designation. WBC noted. Mary Forsyth considers that St. Albans Road shopping parade is much too long and unsustainable. She suggests it should be broken into sections and some of the shops returned to residential use. WBC The extent of the shopping parade will be reviewed in the light of applications for the Verulam Arms site at the northern end of the centre. At this stage it is intended to retain the remainder as a shopping area and work through the redevelopment of Watford Junction to strengthen the vitality and viability of the area. Housing Sites Hertsmere Borough Council recognises the need to encourage regeneration in Watford and to plan for more than 1,330 dwellings as a contingency against some sites not coming forward. Hertfordshire County Council Property provides information on the school requirements likely to be generated by new housing developments, and seeks greater certainty about what will be delivered on each site. WBC we will be looking at each site in further detail with a view to providing a clearer idea of the likely yield and delivery timescale for each and will continue to liaise with HCC on school requirements. Thames Water Utilities provide additional information on specific sites, including concerns about capacity on some housing sites.

15 WBC we will use this information as we review our list of sites for the next stage. Herts and Middlesex Wildlife Trust provide detailed information and comments on a number of individual sites. WBC we will use this information as we progress the plan, liaising with HMWT as required. Tim Williams comments on H12 Dome Roundabout - proposed site already contains private housing. WBC - comments are noted, there is no intention to demolish existing houses. We will reassess site boundaries as we take sites forward to the next stage. Hertfordshire County Council Property support the allocation of H16 Bill Everett Community Centre, while Sport England ask that the allocation ensure changing facilities are retained or reprovided. WBC Comments are noted and will be considered in the review of the sites for the next stage. The Architects Corporation made some comments regarding the boundaries of housing sites H1 and H5. WBC the comments are noted and will be considered as the sites are reviewed for inclusion at the next stage. Gypsy and Traveller Site Hertsmere Borough Council supports the site identified. Hertfordshire County Council agrees in principle and assumes the twenty pitches would be provided in stages to lessen the impact on the residents of the adjacent HCC site and neighbours. Suitable screening should be incorporated into any scheme.

16 CPRE object to GT1 as inappropriate development within the Green Belt. HWMT also object to loss of open space and potential habitat loss. WBC - after an extensive search throughout the borough the only identified potential Gypsy and Traveller sites were within the Green Belt. The provision of a site in the vicinity of the existing Gypsy site at Tolpits Lane and within the Green Belt was agreed at Core Strategy examination and is therefore part of the adopted Core Strategy. Employment E1 - Threadneedle investments support the continued allocation of E1 for employment and Northumberland Estates support the proposed extension of E1 by the removal of the car park from the green belt (G6). WBC support noted. It will be made clearer at the next stage that G6 is proposed for employment allocation. Bugler developments 77 Clarendon Road should be included as part of the SPA2 designation in line with the 2004 brief and to help stimulate regeneration at Watford Junction. WBC 77 Clarendon Road is now considered to be an important site within the Clarendon Road employment area which is subject to an Article 4 direction removing permitted development rights relating to change of use to residential. The 2004 brief is now out of date. It recognised that 10 years would be its maximum life-span. The planning issues have changed over this period of time and it is considered more important to retain this site for employment purposes than to consider it as part of SPA2 Watford Junction regeneration area. Hertfordshire County Council, as Minerals and Waste Authority, support the protection of Watford Business Park (E1) and Greycaine Road (E6) for employment both being identified as areas of search in the waste allocations document currently in progress. An additional paragraph is proposed for clarification.

17 WBC we will consider including the additional text as we redraft the plan. Primary School S2. Lanchester House English Heritage comment that as a Locally Listed Building Lanchester House should be brought back into beneficial use. The open space around the building is also important to the quality of the townscape and the whole forms part of the setting of the neighbouring listed building to the southeast. They consider the allocation should be omitted from the plan. WBC - The planning application for the new Free School in the Lanchester House building has already been approved by the Council. A specific site allocation may not therefore be required. Hertfordshire County Council property support the inclusion of primary schools at SPA2 Watford Junction, SPA6 Western Gateway, (Site S1 Ascot Road), Site S2 Lanchester House and Site S3 Orchard. They also suggest the chapter be renamed either Schools or Education. WBC agree the chapter could have a better title this will be reviewed as we amalgamate site allocations and development management policies into a single document. Herts and Middlesex Wildlife Trust would like to see green space retained at S2 and S3. WBC Green space along the frontage of S2 will be retained and actively managed as green space in connection with the use of the site as a primary school; S2 now has planning permission for use as a school and detailed landscape plans are being drawn up as part of the discharge of conditions on this permission. In terms of S3, the retention of green space will be considered as part of any redevelopment proposals for that site.

18 Green Infrastructure Hertfordshire County Council provides extensive information on ecology and wildlife sites and corridors, including comments on methodology and evidence. WBC we will use this information as we progress the plan. Hertfordshire County Council Property express concern about green belt designation washing over school sites as this may restrict school expansion. WBC this matter was discussed as part of the Core Strategy examination and it was agreed to retain the green belt status. CPRE note that the green belt is not shown on the plans for SPA3 and G11. WBC This was an unintentional omission - the plans were primarily to show the location and boundary of sites, but green belt will be shown on the Local Plan Policies Map CPRE object to the removal of G6 from the Green Belt into the employment area site should remain Green Belt to separate the Business Park from the Moor Park industrial area. WBC- the small site does not currently provide an effective open space to separate the Moor Park industrial centre, as it is fenced off and covered in hard surfacing. The adjacent open green area is wholly contained with Three Rivers Green Belt. Three Rivers District Council, supported by Warner Bros propose Green Belt changes, and a specific Leavesden Studios Operations allocation in connection with Leavesden Studios. These are necessary for consistency with the Three Rivers Site Allocations plan incorporating changes recommended by the inspector examining that plan. WBC we agree that the proposed changes should be made to enable consistency across the two authorities.

19 Natural England note that site G7 is currently Green Belt land set aside for the Croxley Rail Link and ask that we ensure ecological assessment is undertaken as part of any development proposal and mitigation measures secured to minimise impacts on local biodiversity. They also welcome designation of site G9 as Green Belt. WBC This should be sufficiently covered by the Core Strategy policy GI3 Biodiversity. Sport England support the Sports Hubs and suggest cross referring to Policy GI6 of the Development Management policies. Clarity needs to be provided on what development is acceptable. Hertfordshire County Council are concerned about the proposed allocation of sports hubs. HCC property also express concerns about the proposed sports hubs and potential conflict with existing school uses. WBC - we are currently working with our leisure department to clarify what is needed at each sports hub. There is no intention to conflict with green belt policy. We are also reviewing whether sports hubs need or are appropriate to be a local plan allocation or if they would be better delivered through the council s sports strategy. Amalgamation of site allocations and development management policies into a single document should reduce need for cross referencing. Decathlon support the sports hub concept and consider that the Knutsford Fields area should be one of the sports hubs identified in the document, and that this should incorporate their large retail store concept as well as other sports activities. WBC we support Decathlon s desire to operate a retail store in Watford at one of the existing retail locations in the town. However the Knutsford Fields site is in the Green Belt and so not considered suitable for large scale retailing

20 for sports products. We are currently facilitating the relocation of the hurling club to this location from the Oxhey Park area as part of the Health Campus redevelopment, and this is therefore the priority for the council in this area at the current time. Cemetery proposal Bucks Meadow Riding School consider the site is not suited to being a green burial site. Hertsmere Borough Council note that this small proposal is in Hertsmere Borough and should be included in Hertsmere s Site Allocations if it is practical and thus progressed. In principle there is no objection, although there may be a need for a better access route, particularly if there are any intentions to enlarge the area shown, either as a woodland cemetery or conventional burial space. This will need to be discussed further between the two authorities. WBC Hertsmere Borough Council are consulting on this site through their Local Plan process as a site to meet the needs of Watford. Unfortunately the consultation process has not yet thrown up any alternative sites for green burial within Watford. The proposal will not ultimately feature in Watford s Local Plan as it is outside our boundary, but was flagged up to show where our needs might be met. Additional Proposed Sites Brazier Freeth, acting on behalf of Affinity Water, promote the redundant covered reservoir site at Paddock Road for residential use (12-15 units). WBC - This site is located within the Green Belt and is also a locally listed structure. We are not currently looking to review the green belt for the purposes of accommodating our housing needs. This is not therefore considered to be a suitable site for housing at the current time.

21 Hertfordshire Property propose additional sites for allocation, with further information: 3-5 Estcourt Road, 74 Sandringham Road, Land at 44/46 Woodford Road, Magistrates Court, 501 St Albans Road /Beechwood Family Centre, North Watford Library/Garston Fire and Ambulance Station, 36 Clarendon Road. WBC we will investigate these sites further before the next consultation Watford Community Housing Trust proposes the strip of land west of Croxley View housing estate, adjacent to Watford Business Park, running from Tolpits Lane to Ascot Road. WBC we will review the potential allocation of this site before the next consultation. Area bounded by Grove Mill/M25/canal/Hempstead Road (comment submitted against development management policies consultation) WBC This proposal lies within the green belt. We are not currently looking to review the green belt for the purposes of accommodating our housing needs. This is not therefore considered to be a suitable site for housing at the current time. Wakelin Associates Land to the rear of 2-34 and Gade Avenue. These sites were previously been submitted to the site allocation process but were discounted as they are garden land. WBC - Garden land is not included in the housing site selection criteria. The site was discounted for this reason, which still stands. Savills An initial site at the Nissan Garage was included in the consultation document proposed as MXD4 site, representations have been submitted to widen the area to include Pump House. WBC- see response under MXD4 in the mixed use section above proposal not accepted. Transport for London- late submission on land at Metropolitan Station which will become redundant after the Croxley Rail link comes in. WBC this submission will be considered before the next consultation

22 Conclusion: We thank all those that kindly submitted comments to us on our first Local Plan Part 2 consultation. These have been very useful for us to make progress on the plan. The Site Allocations and Development Management Policies will be combined into a single document for further consultation, which is expected to take place in autumn Before this takes place we will be undertaking further detailed work on the sites to ensure all sites we propose are deliverable, and to provide additional information such as the amount of development and likely timescales. We will also be taking account of additional evidence as soon as it becomes available.