[image credit - Google streetview].
Waltham Forest Council is considering plans from a private developer to build almost 600 homes on the Homebase site at the junction of Forest Road and Fulbourne Road. WFLDs support the construction of high-quality homes to meet our current housing crisis, but the current plans fall short of the standards set out by the Council. Read the letter to the planning committee from our housing and planning spokesperson, Thomas Addenbrooke, below.
Re: planning application for the redevelopment of 2c Fulbourne Road
Your Ref: 202512FUL
Dear Sir or Madam,
I am writing to you both in my role as planning spokesperson for Waltham Forest Liberal Democrats and as a neighbour of the proposed development. We recognise the need for new housing in the borough, and appreciate the effort of JTP and Inland Homes to propose a development with a number of attractive features. However, the development as planned falls short of a number of recently published Council targets and guidelines. We therefore believe that planning permission should not be granted at this stage.
Our objections fall under three categories. Firstly, the proposed homes do not reflect Waltham Forest’s needs (as identified in the 2017 Strategic Housing Market Assessment ), both in terms of the size distribution and the share of low cost affordable provision. Secondly, the plans fall well short of the non-residential floorspace envisaged in the recently circulated Draft Site Allocations Document . Finally, the extreme height of the tallest buildings cannot, we feel, be justified against the criteria laid out in the 2019 Draft Local Plan .
Types of homes proposed
Waltham Forest’s 2017 Strategic Housing Market Assessment  is clear that "households with dependent children are over-represented in comparison to London and England" in Waltham Forest, and that there is a “high level of overcrowding in Waltham Forest compared to the national average”. As a result, a mixture of home sizes are required, and “the required size breakdown of the housing stock in the borough in 2039 will be 18% one bedroom dwellings, 30% two bedroom dwellings, 35% three bedroom dwellings, and 17% four bedroom dwellings.” Consistent with these requirements, policy 4C of the Draft Local Plan  states that development proposals will be expected to “provide a broad range of housing choice by size and tenure”, and policy 26 specifies that this “broad distribution” translates to a requirement of 40-50% of homes with three or more bedrooms. The current proposal for the Patchworks development falls far short of this target, with only 12% of proposed homes having three or more bedrooms.
In addition, the Draft Local Plan  indicates “a strategic housing target of 50% of all new homes to be genuinely affordable across the Plan period” (policy 24). The recently circulated “Planning your neighbourhood” document  states that the developments along Forest Road Corridor are expected reach this 50% threshold as a group. The Draft Site Allocations document  shows that the Wood Street Library and Fellowship Square developments within the Forest Road Corridor have individual targets of 50% affordable homes. The large shortfall at the Homebase site, which promises 35% affordable homes, must therefore be compensated by Hylands Road (100% affordable) and any future developments at Willow House and Sterling House. In total, the current plans on the Forest Road Corridor (excluding hypothetical developments at Willow House and Stirling House) are approximately 48% affordable homes. This number is close to what is required, but it should be noted that any future development of Willow House and Stirling House would need to be approximately 50% affordable (and not 35% as suggested in ) to meet the overall target for the Forest Road Corridor.
Importantly, however, the Draft Local Plan  goes beyond simply specifying a fraction of “affordable” homes. These homes should be “genuinely affordable”, corresponding to social rent, London affordable rent, London Living Rent or London Shared Ownership. It is not clear from the planning application whether the affordable homes proposed fall under these categories, or under weaker definitions of “affordable”, which can be up to 80% of market value. Moreover, policy 25 of the Draft Local Plan  indicates that schemes over 10 units should have a split of 70/30 between low cost affordable rent (Social Rent, London Affordable Rent) and intermediate products (London Living Rent, London Shared Ownership). The submitted proposals fall well short of this target, having either a 50/50 split or a 0/100 split, depending on the exact definition of affordable rent being used by the developers.
Lack of non-residential floorspace
The proposed development will replace a retail site that is of value to the community. Moreover, a large influx of residents will place additional strain on amenities such as GP surgeries. These facts are reflected in the Draft Site Allocations document , which specifies a minimum of 5270 sqm non-residential floorspace (including new public realm, workspace and community uses) for the site encompassing 2c Fullbourne Road, Willow House and Stirling House. Given that 2c Fullbourne Road constitutes well over half of the area in question, the majority of this 5270 sqm of non-residential floorspace should be provided by the Patchworks development. However, the current proposals only allow for 595 sqm of employment space, well below what is required.
The inclusion of extremely tall buildings in the proposals
The developers propose to include a 15-storey and an 18-storey building as part of the development. These buildings would be among the tallest in the borough, even in the context of other recent developments. The Draft Local Plan  allows for tall buildings, but notes that they “present a number of challenges” and that they should be assessed against a criteria outlined in policy 63 and policy 64. Of particular relevance to the Patchworks development are the following requirements:
- Proximity to transport interchanges and nearby facilities such as shops, community facilities and other services. The sites identified for tall buildings in the Draft Local Plan  are unified by their extreme proximity to transport hubs. New and proposed developments involving tall buildings are situated immediately adjacent to Walthamstow Central Station, St James Street Station, Blackhorse Road Station and Lee Bridge Road Station. By contrast, 2c Fullbourne Road is approximately 1km from the nearest station (Wood St Overground, a secondary hub relative to Blackhorse Road or Walthamstow Central). The criterion of adjacency to a transport interchange is therefore not satisfied.
- [The design should] prevent overshadowing of surrounding public open space, private outdoor space, private amenity of neighbouring properties, watercourses and canals. The properties and private gardens along Hale End Road (at the Eastern edge of the development) will inevitably be overshadowed by the taller buildings. It is worth noting that the non-technical summary of the environment statement concedes that there will be “a limited number of moderate adverse effects” in this regard. Troublingly, p135 of the Design and Access statement (section 5.9) states “technical analysis found no negative daylight/sunlight impacts on surrounding buildings and neighbours.” This inconsistency is not encouraging.
- [The design should avoid] adverse impacts through overlooking, enclosure and the loss of privacy, outlook and daylight/sunlight to adjacent residential properties. This policy makes clear that loss of privacy for the residents of Hale End Road, whose houses and gardens will necessarily be overlooked by the tall buildings, is a relevant consideration in addition to possible loss of sunlight or overshadowing. We were unable to find comments addressing this issue in the proposal.
In conclusion, therefore, the proposed development is currently incompatible with the Council’s development plans as laid out in recent publications -. We therefore believe that the planning permission should not be granted for the proposed development in its current form.
Waltham Forest Liberal Democrats Planning and Housing Spokesperson
 “Your chance to shape our borough (Central Waltham Forest)” 4-page leaflet/advertisement for the local plan consultation, delivered to residents during Sep-Oct 2020.