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November 2009

Bromley Town Centre Area Action PlanSubmission DocumentStatement of Consultation - Regulation 30 (d)

Bromley Town Centre Area Action Plan

STATEMENT OF CONSULTATION

November 2009

| L O N D O N B O R O U G H O F B R O M L E Y S T A T E M E N T O F C O N S U L T A T I O N

TABLE OF CONTENTS

EXECUTIVE SUMMARY

1 INTRODUCTION

2 STAGES OF CONSULTATION

APPENDICES

Appendix 1: List of Consultees at each stage of the AAP

Appendix 2: Issues and Options: Stage 1 Workshops (May-September 2005)

Appendix 3: AAP: Preferred Options (January-February 2006): Summary of Consultation Responses

Appendix 3.1: AAP: Preferred Options (January-February 2006): Responses to Consultation

Appendix 3.2: AAP: Preferred Options (January-February 2006): Report to Committee

Appendix 4: Revised Preferred Options (November 2007-January 2008): Responses to Consultation

Appendix 4.1: Revised Preferred Options (November 2007-January 2008): Report to Committee

Appendix 5 Consultation Draft AAP (November 2008- January 2009): Responses to Consultation

Appendix 5.1: Consultation Draft AAP (November 2008- January 2009): Report to Committee

Appendix 6 Proposed Submission AAP: Invitation for Representations on Soundness and Legal Compliance

Appendix 6.1: Pre-Submission Document: Representation Form

Appendix 6.2: Pre-Submission Document: GLA: Request for General Conformity

Appendix 6.3: Pre-Submission Document: Example Consultation Letter

Appendix 6.4: Pre-Submission Document: Notice of Publication

Appendix 6.5: Pre-Submission Document: Committee Report

Appendix 6.6: Letter to Planning Inspectorate

| L O N D O N B O R O U G H O F B R O M L E Y S T A T E M E N T O F C O N S U L T A T I O N

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1. INTRODUCTION 1.1. OVERVIEW

1.1.1. Bromley Council’s Statement of Community Involvement (SCI) sets out the Council’s standards in relation to involving the community in the preparation of local development documents. Its purpose is to ensure that all sections of the community have the opportunity to get involved from the earliest stages.

1.1.2. The purpose of this document is to set out how the Council has complied with Regulation 25 of the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 relating to public consultation on a Development Plan Document in preparing the Bromley Town Centre AAP. It sets out the following:

• Which bodies and persons were invited to make representations under Regulation 25;

• How those bodies and persons were invited to make representations;

• A summary of main issues raised;

• How representations have been taken into account

1.1.3. The Proposed Submission Bromley Town Centre AAP has been prepared in accordance with the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008, which makes provision through transitional arrangements for consultation already undertaken at previous stages in the AAP to act as a proxy for consultation requirements of the new regulations.

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2. STAGES OF CONSULTATION 2.1. OVERVIEW

2.1.1. The preparation of the AAP commenced in Spring 2005 and has been developed in accordance with PPS12. Development of the AAP can be divided into the following stages:

Stage 1: Pre-production- survey and evidence gathering- this involved workshops attended by invited stakeholders;

Stage 2: Production- preparation of Preferred Options supported by continuous stakeholder involvement followed by a six week period of formal public consultation on the options (January 2006)- this involved a public exhibition and questionnaires;

Stage 2A: Production- review of Preferred Options in light of consultation and further technical studies and preparation of Revised Preferred Options followed by a six week period of formal public consultation on the options (November 2007)- this involved a public exhibition and making information available on the Council’s web site.

Stage 2B: Production- review of Revised Preferred Options in light of consultation and preparation of Consultation Draft AAP for a twelve week period of formal consultation (November 2008-February 2009)- . This involved a public exhibition and making information available on the Council’s web site.

Stage 2C: Publication of Proposed Submission – document consulted on for a further 6 weeks between 9th June and 17th July. This involved a public exhibition and making information available on the Council’s web site and letters were sent out to individuals and organisations who have previously made representations.

2.1.2. Each stage of consultation has been taken into account in preparation of the Proposed Submission AAP.

2.1.3. A list of bodies consulted at each stage of preparation of the AAP is attached as Appendix 1.

2.2. STAGE 1: PRE-PRODUCTION

2.2.1. Consultation has formed a critical element at each stage in the preparation of the AAP. The Council has been working from the outset with key stakeholders including representatives of local community groups and businesses. This involved 3 stages of consultation prior to preparation of the Preferred Options.

I. Issues and Opportunities Review (May 2005);

II. Creating a Vision for Bromley (July 2005); and

III. Developing the Options (September 2005).


2.2.2. The vision has been developed through the AAP process in consultation with stakeholder groups including local businesses, community groups and residents. Of particular importance is the need to build on the town centre’s considerable assets and to make it a more competitive and attractive location for retail, leisure, business and investment. The town centre’s character is considered to be a particular strength and future development in the town centre should reinforce and enhance this.

2.2.3. This collaborative approach included a number of focused workshop events which have assisted in the preparation of the AAP by involving key stakeholders in the identification of key issues and opportunities and in the development of a vision and the Preferred Options for the Town Centre. Stage 4 of the AAP process has comprised the development of the Preferred Options which are presented in this document.

2.2.4. The workshops were attended by a large number of invited stakeholders including representatives from the following organisations:

• Members and officers of Bromley Council;

• Local community and residents’ groups: LB Bromley Residents’ Federation, Heart of Bromley, Bromley South Action Group, Bromley North Residents Association, Community Links, Age Concern, Bromley Christian Centre, Friends of the Earth and Bromley Town Church;

• Emergency services: London Fire Brigade, London Ambulance Service and Metropolitan Police Service;

• Statutory Organisations: English Heritage, Transport for London and Licensed Taxi Drivers Association;

• Local organisations and businesses: Cystic Fibrosis Trust, Bromley Adult Education College, Churchill Theatre, Bromley My time, Bromley PCT, South London Business, Bromley Court Hotel, Woolworths, Prospects and Capital Shopping Centres, Pellings; and

• Other interested parties: landowners, property developers, surveyors and agents.

2.2.5. On the basis of the Stage 1 analysis and consultation with key stakeholders, a vision was identified for the future development and enhancement of Bromley Town Centre. The AAP seeks to create:

• A more vibrant centre with an extended offer;

• A more sustainable centre- a place to shop, work, spend leisure time and live;

• A high quality safe environment;

• A distinctive centre with high quality buildings and public spaces;

• An accessible and inclusive centre;

• A centre with the capacity for planned growth;

• A daytime and night time centre; and

• A centre which celebrates its heritage.


2.2.6. Copies of the reports of these workshops and summary of the issues raised are attached in Appendix 2.

2.3. STAGE 2: PRODUCTION

2.3.1. Public consultation was undertaken over a six week period from 13 January to 24 February 2006. A staffed exhibition was held over three days in The Glades after which a static exhibition with leaflets was placed in the Bromley Public Library, the Civic Centre main reception and at Bromley Adult Education Centre. The consultation process also included other ways of inviting comments via the local press and online. The Council received responses from 1420 individuals and companies including 1264 completed freepost questionnaires, 57 written responses and 97 responses via the website.

2.3.2. A copy of the responses to consultation and a summary of the issues raised and how these were addressed by the Council is contained in Appendix B together with a copy of the Report to Development Control Committee (April 2006).

2.4. STAGE 2A: PRODUCTION

2.4.1. A review was undertaken of the Preferred Options in light of consultation and further technical studies and a further six week period of formal public consultation on the Revised Preferred Options was undertaken between November 2007 and January 2008. This involved a staffed exhibition was held over three days in The Glades after which a static exhibition with leaflets was placed in the Bromley Public Library, the Civic Centre main reception and at Bromley Adult Education Centre. The consultation process also included other ways of inviting comments via the local press and online.

2.4.2. A copy of the responses to consultation on the Revised Preferred Options and a summary of the issues raised and how these were addressed by the Council is contained in Appendix C together with a copy of the Report to Development Control Committee .

2.5. STAGE 2B: PRODUCTION

2.5.1. A review was undertaken of the Revised Preferred Options in light of consultation and further technical studies and a Consultation Draft AAP prepared for public consultation. A twelve week period of formal public consultation on the Consultation Draft AAP was undertaken between November 2008 and February 2009. Bodies and individuals who had previously commented on earlier stages of the AAP were contacted in writing and advised of the main changes to the document.

2.5.2. A copy of the responses to consultation on the Consultation Draft AAP and a summary of the issues raised and how these were addressed by the Council is contained in Appendix D together with a copy of the Report to Development Control Committee.

2.6. STAGE 2C: PRODUCTION

2.6.1. The Proposed Submission AAP was published on the 8th of June and made available for public viewing at the Council offices, on the Council website, and through written correspondence to 1000 consultees. CD’s containing all the relevant documents were also published and distributed to specific consultees. Representation forms with comprehensive guidelines on the Tests of Soundness were made available along with the following supporting documents.


i. Sustainability Appraisal

ii. Equalities Impact Assessment

iii. Updated Retail Capacity Assessment

iv. Transport Strategy

v. Strategic Flood Risk Assessment

vi. Statement of Consultation

vii. Baseline Report

viii. A letter on Appropriate Assessment provided by Natural England

DATE

MEDIUM DISTRIBUTION

3 June News Release Local media and LBB website Average 4,500 hits everyday `

3 June Statutory Public Notice in News Shopper X 2 weeks 98,356 Average net circulation

8 June AAP Published Letters/Documents – Hard Copies and CDs Letters Documents on a CD – Specific Consultees Letters – other consultees All borough libraries (1 of each documents for view or loan plus CDs) Planning/main receptions Email notification CDs Distributed during the exercise

4 32 751 17 2 215 25

bromley.gov.uk Home page visual plus all supporting documents published

Internet availability

Onebromley – intranet homepage All Staff 10 June News Shopper local paper article 98,356 Average net circulation 20 June UPDATE – Residents Association & Community groups

newsletter (including Members and media)

Direct Mail News item

17 July LBB web site announcing the close of the invitation period

LBB website

2.6.2. * Includes hits on all pages of the web site

2.6.3. The closing date for the receipt of representations was the 17th of July and in accordance with advice of the Government Office London (GoL), a period has been allocated for the Council to assess and analyse these representations.

2.6.4. The main issues raised are being summarised and will be submitted in a separate document with the AAP, along with all supporting documentation, the representations received and a schedule of minor amendments to the Secretary of State for examination.


APPENDIX 1

BROMLEY TOWN CENTRE AAP

LIST OF CONSULTEES


Consultee Issues &

Opportunities Workshop

Invitees

Visioning Workshop

Invitees

Options - Workshop

Invitees Preferred Options Revised Preferred Options Draft

Consultation Invitation for

Representations on Soundness

Statutory Consultees

Natural England X X X X

English Heritage X X X X X X X

The Environment Agency X X X X X X X

Transco X X X X

Countryside Agency X X X

Metropolitan Police X X X X X X X

British Gas X X X X

Transport for London X X X X X X X

British Telecoms X X X X

Air Transport Users Council X X X

Kent Wildlife Trust X X X

Museum of London Archaeology Service X X X

Thames Water Plc X X X X

Bromley Mental Health Services X X

Civil Aviation Authority X X X X

Bromley Primary Care Trust X X X X X X X

House Builders Federation X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




English Sports Council X X X

EDF Energy X X X X

Capitec (Part of NHS Estates) X X X

London Fire and Emergency Planning Authority X X X X

Bromley Hospitals NHS Trust X X X X

Network Rail X X X X X X X

OXLEAS NHS Trust X X X X

Post Office Property Holdings X X X X

Powergen X X X X

SOLOTEC X X X

South East London Strategic Health Authority X X X X

Bromley Magistrates Courts X X X X

Bromley Community Health Council X X X X

NATS X X X X

Highways Agency X X X X

Sport England X X X X

London Ambulance Service X X X X X X X

Government Departments


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




Inventures (NHS Estates) X X X

Strategic Rail Authority X X X X

Planning Inspectorate X X X X

Parliamentary, Correspondence and Briefing Unit X X X X

London Development Agency X X X X

ETSU, Department of Trade and Industry X X X

Department of Trade and Industry X X X X

Secretary of State, Department for Children Schools and Families (Formerly Department of Education and Skills)

X X X X

Commission for Architecture and the Built Environment X X X X

The Crown Estates Commissioners X X X X

Department for Transport X X X X

Department of Child Health X X X X

Government Office For London X X X X

Secretary of State Communities and Local Government X X

Regional Bodies

London Councils X X

Homes and Communities Agency X X

English Partnerships X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




GLA X X X X

Sustrans X X X X

The Mayor of London X X

Political

Ward Members X X X

All Bromley Councillors X X X

Bob Neill MP X X

Biggin Hill & Darwin Branches of the Labour Party X X X

National Liberal Club X X X X

Beckenham Constitutional Club Ltd X X X X

Conservative Future X X X X

Conservative Penge Action Team X X X X

Chislehurst Constituency Labour Party X X X X

Chislehurst Conservative Association X X X X

Beckenham Constituency Conservative Association X X X X

Bromley & Chislehurst Labour Party X X X X

Beckenham Liberal Democrats X X X X

Bromley Conservative Club X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




Chislehurst Social & Liberal Democrats X X X X

Central Beckenham Liberal Democrats X X X X

Bromley Labour Party Local Government Committee X X X X

Social and Liberal Democrats X X X X

Adjoining Local Authorities

London Borough of Bexley X X X X

London Borough of Croydon X X X X

London Borough of Lambeth X X X X

London Borough of Greenwich X X X X

London Borough of Lewisham X X X X

London Borough of Southwark X X X X

Kent County Council X X X X

Surrey County Council X X X X

Tandridge District Council X X X X

Swanley Town Council X X X X

Westminister City Council X X X X

Other London Wide Agencies

London Green Belt Council X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




London Travel Watch X X

Royal Mail X X X X X X

South East London Museums Service X X X X

Stagecoach Selkent X X X X

Tree Council X X X X

Urban Regeneration Partnership X X X

Visit London X X X X

Airports UK Ltd X X X X

Civil Aviation Authority X X X X

English Sports Council X X X X

Housing Corporation X X X X

London Central Bus Company X X X X

Corporation of London X X X X

British Motorcyclists Federation X X X X X X X

National Trust X X X X

The Theatres Trust X X X X

National Car Parks Ltd X X X X

National Playing Fields Association X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




National Childminding Association (NCMA) X X X X X X X

South London Business Forum X X X X X X X

Royal Horticultural Society X X X X

Bromley Strategic Partners

Metropolitan Police Bromley X X X X X X X

Bromley Borough Road Action Group (BBRAG) X X X X X X X

Bromley Asian Cultural Association X X X X

Bromley Magistrates Court X X X X

Bromley Muslim Association X X

Age Concern Bromley X X X X X X X

Bromley Autistic Trust X X

Bromley Community Health Council X X X X

Bromley Learning Disabilities Forum X X X X

Bromley Mencap X X

Bromley Racial Equality Council X X X X

Bromley Somali Community Association X X

LGBT Forum X X

Bromley Police Station X X X X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




Bromley Physical Disability & Sensory Impairment Forum X X

Bromley Mind X X X X

Bromley Youth Council X X

Community Links Bromley X X X X X X X

Deaf Access Bromley X X

Stakeholders

Bromley Mytime X X X X X X

Disability Voice Bromley X X

Bromley Civic Society X X

London Transport Users Committee X X X X X X X

Town Centre Chaplain X X X X X X X

London Walking Forum X X

Metrobus X X X X X X X

Churchill Theatre X X X X X X X

Bromley Little Theatre X X

Bromley Christian Centre X X X X X X X

Northpoint X X

The Glades Merchants Association X X X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




Pelling Ltd X X X X X X

Churchill Insurance X X X X X X X

Sainsbury’s Supermarkets X X X X X X

Bromley Borough Road Action Group X X

Bromley Wheelchair Users Group X X

Capital Shopping Centres Plc X X X X

Bromley North Residents’ Association X X X X X X X

Bromley College X X

Bromley College of Further and Higher Education X X X

Bromley Green Party X X X X

Affinity Homes Group X X X X X X

APCA X X X X X X

Key Local Groups

West Wickham Residents’ association X X X X

St Mary Cray Residents’ Association X X X X

Beechwood Residents’ Association X X

Florida Court Residents’ Association X X X X

Broad Oaks Residents’ Association X X

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Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




Stirling Drive Residents’ Association X X X X

Fernwood Close Residents’ Association X X X X

Eden Park Residents’ Association X X X X

Bromley Common 2468 Residents’ Group X X X X

Downe Residents’ Association X X X X

Sundridge Residents’ Association X X X X

Stradella and Springfield Residents’ Association X X X X

Crofton Residents’ Association X X X X

Shortlands Residents’ Association X X X X

Crystal Palace Community Association X X X X

Sundridge Park Residents’ Association X X X X

Farnborough Park Estate Ltd Residents’ Association X X X X

St Mary Cray Action Group X X X X

Cudham Residents’ Association X X X X

Durham Avenue Residents’ Association X X X X

Bromley Common Village Residents’ Association X X X X

Farwig Area Residents’ Association X X X X

Babbacombe Road Residents’ Association X X X X

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Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




Bromley Common Lane Association of Residents’ X X X X

Biggin Hill and District Residents’ Association X X X X

Hilda Lane Community Association X X

Chelsfield Village Society X X X X

North Point Sherman Road Residents’ Association X X

Chancery Lane / Limes Road Residents’ Association X X X X

Old Hill & Cudham Lane North Residents’ Association X X X X

Copers Cope Area Residents’ Association X X X X

Chelsfield Park Residents’ Association X X X X

Cherrycot Residents’ Association X X X X

Bromley South Action Group X X X X X X X

Chinbrook Estates Residents’ Association X X X X

St Pauls Cray Tenants and Residents’ Association X X X X

Chislehurst Village Society X X X X

South Penge Residents’ Association X X X X

Goddington North Residents’ Association X X X X

Elmers End Residents’ Association X X X X

Southill Residents’ Association X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




Rowan Park Residents’ Association X X X X

St Pauls Cray Community Association X X X X

Crowborough Drive Residents’ Association X X X X

Links Estate Residents’ Association X X X X

Palace Road Residents’ Association X X X X

Park Langley Residents’ Association X X X X

Parkside Avenue Residents’ Association X X X X

Penge East Residents’ Association X X X X

Ramsden Residents’ Association X X X X

Rookery Residents’ Association X X X X

Garden Estates Association X X X X

Bickley Park Residents’ Group X X X X

Oregon Park Residents’ Association X X X X

The Chenies Road Association X X X X

The Federation of Broomleigh Residents’ X X X X

The Gardens Residents’ Association X X X X

Grove Park Community Group X X X X

The Groves Residents’ Association X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




The Highway and District Residents’ Association X X X X

The Knoll Residents’ Association X X X X

Ringers Court Residents’ Association X X

Badgers Mount Residents’ Association X X X X

Mottingham Residents’ Association X X X X

Mottingham Estate Tenants Association X X X X

Andace Park Residents’ Association X X X X

Albyfield Residents’ Association X X X X

Aldersmead Road Residents’ Association X X X X

Place Farm and Sparrows Drive Residents’ Association X X

Palace Estate Residents’ Association X X X X

Petts Wood and District Residents’ Association X X X X

North Bromley Residents’ Association X X X X

Barnmead (Cator Estate) Residents Association X X X X

Beckenham Place Park Residents’ Association X X X X

Beckenham Village Residents’ Association X X X X

Bickley Park Residents’ Association X X X X

Old St Paul’s Cray Village Residents’ Association X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




North Street Residents’ Association (Bromley) X X X X

Turpington Community Association X X X X

Alexandra Residents’ Association X X X X

London Borough of Bromley Residents’ Federation X X X X X X X

The Mead and the Mead Way Residents’ Association X X X X

Kevington Residents’ Association X X X X

Keston Village Residents’ Association X X X X

Hazelhurst Residents’ Association X X X X

Hayes Village Association X X X X

Green Street Green Residents’ Association X X X X

Knoll House Residents’ X X X X

Queen Adelaide Court Tenants and Residents’’ Association X X X X

Beckenham Civic Society X X X X

Nash Residents’ Association X X X X

Glen View Road and The Glades Residents’ Association X X X X

Mountview & Perry hall Residents’ Association X X X X

Geffreys Estate Steering Group X X X X

Oakfield Lane Residents’ Association X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




Green Street Green Association X X X X

Monks Orchard Road Residents’ Association X X X X

Felmingham Road Residents’ Association X X X X

Vinson Close Residents’ Association X X X X

Wickham Common Residents’ Association X X X X

Windsor Drive Community Association X X X X

Woodlands Valley Residents’ Association X X X X

Kelsey Park Estate & District Protection Association X X X X

Yester Park Residents’ Association X X X X

The Royston Estate Residents’’ Association X X X X

Mead Road Residents’ Association X X X X

Lullington Road Residents’ Association X X X X

Lowood Court Residents’ Association X X X X

Lower Amherst Residents’ Association X X X X

Leave’s Green and Keston Vale Residents’ Association X X X X

Beadon Road Residents’ Association X X X X

Leesons Residents’ Association X X X X

Friends of the Earth X X X X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




Carers Bromley X X X X

Bromley Housing Advisory Service X X X X

Bromley Small Business Club X X

Salvation Army X X

The Open Spaces Society X X X X

Youth Housing Forum X X X X

Beckenham Place Park Society X X

The Garden History Society X X X X

St Mark’s (Church of England) Primary School X X X X

St. Mark’s Church of England X X X X

Ravensbourne Valley Preservation Society X X X X

BRONSPART X X X X

Religious Society of Friends X X X X

Penge Forum X X X X

Anerley Association X X X X

Housing Associations

Broomleigh Housing Association X X X X

Moat Housing Group Ltd X X X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




Burnt Ash Housing Association X X

Chislehurst & Sidcup Housing Association X X X X

Hexagon Housing Association X X X X

Kelsey Housing Association X X X X

South London Family Housing Association X X X X

Bromley Federation of Housing Associations X X X X

Beaver Housing Association X X X X

Hyde Housing Association X X X X

Family Housing Association X X X X

London & Quadrant Housing Trust X X X X

Radcliffe Housing Association X X X X

Anchor Housing Association X X X X

Presentation Housing Association Limited X X X X

Sanctuary Housing Association X X X X

Tower Homes Ltd X X X X

Businesses

John Lewis X X

The Abbeyfield Beckenham Society Ltd X X


Consultee Issues &


Invitees

Visioning Workshop

Invitees

Options - Workshop




JEMA Fund Management Limited X X X X

Orange Personal Communications Services Ltd X X

Palmer Johnson Design X X X X

Asda Stores Ltd X X

WM Morrison Supermarkets Plc X X

Waitrose X X X X

Computer Cab plc X X

Bromley Court Hotel X X X X X X X

House of Fraser X X

Marks and Spencers X X X X X X X

MacDonalds Restaurants Ltd X X X X X X

Halifax Building Society X X X X

Capital ShoppingCentres Plc X X X X


APPENDIX 2

ISSUES AND OPTIONS: STAGE 1 WORKSHOPS (MAY- SEPTEMBER 2005)

E D A W P L C P L A N N I N G , D E S I G N A N D E C O N O M I C D E V E L O P M E N T W O R L D W I D E


STAGE 1: ISSUES AND OPPORTUNITIES

STAKEHOLDER WORKSHOPS

SUMMARY REPORT

JULY 2005


table of contents

=1 INTRODUCTION

2 STAKEHOLDER WORKSHOPS

3 NEXT STEPS

APPENDICES

=A1: KEY STAKEHOLDER WORKSHOP INVITEES

A2: KEY STAKEHOLDER WORKSHOP ATTENDEES A3: PUBLIC FOCUS STAKEHOLDER WORKSHOP INVITEES A4: PUBLIC FOCUS STAKEHOLDER WORKSHOP ATTENDEES A5: STAKEHOLDER WORKSHOPS CONSULTANT TEAM ATTENDEES =

B R O M L E Y T O W N C E N T R E A R E A A C T I O N P L A N | 1


Acknowledgement

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1. Introduction

BACKGROUND

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2. Stage 1 Workshops OVERVIEW

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CONSULTANT PRESENTATION

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• qÜÉ=éêáåÅáéäÉë=íÜ~í=ÅçìäÇ=éêçîáÇÉ=íÜÉ=Ä~ëáë=Ñçê=íÜÉ=éêÉé~ê~íáçå=çÑ=~=îáëáçå=Ñçê=_êçãäÉóX=

• fÇÉåíáÑáÅ~íáçå=çÑ=éçëëáÄäÉ=~äíÉêå~íáîÉ=äçÅ~íáçåë=Ñçê=ÑìíìêÉ=ÇÉîÉäçéãÉåí=çÑ=ã~áå=íçïå=ÅÉåíêÉ=ìëÉëX=~åÇ==

• `ä~êáÑáÅ~íáçå=çÑ=íÜÉ=åÉñí=ëí~ÖÉë=áå=íÜÉ=^^m=éêçÅÉëëK==aìêáåÖ=~åÇ=ÑçääçïáåÖ=íÜÉ=Åçåëìäí~åí=éêÉëÉåí~íáçå=é~êíáÅáé~åíë=ïÉêÉ=ÉåÅçìê~ÖÉÇ=íç=ÉåÖ~ÖÉ=áå=ÇáëÅìëëáçåë=~åÇ=íç=ëÜ~êÉ=íÜÉáê=îáÉïë=ïáíÜ=çíÜÉê=é~êíáÅáé~åíëäK=qÜÉ=ÑçääçïáåÖ=ëÉÅíáçåë=ëìãã~êáëÉë=íÜÉ=çìíéìíë=çÑ=íÜÉëÉ=ÇáëÅìëëáçåëK==



KEY STAKEHOLDER WORKSHOP (26 MAY (DAYTIME))

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Mix of uses

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• kÉÉÇ=íç=~ÇÇêÉëë=íê~ÑÑáÅ=~åÇ=éêçÄäÉãë=çÑ=~ÅÅÉëëX=

• qÜÉêÉ=áë=~=åÉÉÇ=Ñçê=ÄÉííÉê=áåíÉÖê~íáçå=ÄÉíïÉÉå=ÇÉîÉäçéãÉåí=~åÇ=íê~åëéçêí=Ñ~ÅáäáíáÉë=~åÇ=ëÜ~êÉÇ=ìëÉ=çÑ=é~êâáåÖX=

• fãéçêí~åÅÉ=çÑ=áãéêçîÉÇ=~ÅÅÉëë=êçìíÉë=íç=ÇÉëíáå~íáçåë=ïÜáÅÜ=~êÉ=éäÉ~ëìê~ÄäÉI=Éåàçó~ÄäÉ=~åÇ=áåíÉêÉëíáåÖ=íç=êÉÇìÅÉ=íÜÉ=éÉêÅÉéíáçåë=çÑ=Çáëí~åÅÉ=ÄÉíïÉÉå=åçêíÜ=~åÇ=ëçìíÜ=_êçãäÉóX=

• oÉãçî~ä=çÑ=ÅÉåíê~ä=Ä~êêáÉê=áå=eáÖÜ=ëíêÉÉí=ïáää=áãéêçîÉ=~ÅÅÉëëáÄáäáíó=~åÇ=áåíÉÖê~íáçåX=

• kÉÉÇ=áãéêçîÉãÉåíë=íç=éìÄäáÅ=íê~åëéçêí=êçìíáåÖ=~åÇ=~ÅÅÉëëW=

• `çååÉÅíáåÖ=kçêíÜ=~åÇ=pçìíÜ=_êçãäÉó=ëí~íáçåX=~åÇ==

• pçìíÜ=_êçãäÉó=ëí~íáçå=áå~ÇÉèì~íÉ=~ë=áãéçêí~åí=Ö~íÉï~óK=



• kÉÉÇ=íç=~ÇÇêÉëë=áëëìÉë=çÑ=~ÅÅÉëë=~åÇ=ë~ÑÉíó=

• mçíÉåíá~ä=Ñçê=ÉñíÉåëáçå=çÑ=éÉÇÉëíê~áåáëÉÇ=~êÉ~=áå=kçêíÜ=_êçãäÉó=íç=~ííê~Åí=ãçêÉ=ÅçããÉêÅá~ä=çìíäÉíëK=

• mçíÉåíá~ä=Ñçê=áãéêçîÉÇ=íê~åëéçêí=äáåâë=Ñçêã=_êçãäÉó=kçêíÜJ=ÅçååÉÅíáçåë=íç=kÉï=`êçëë=~åÇ=aio\=

=Culture and Leisure

• kÉÉÇ=íç=ÇÉîÉäçé=~=ëíêçåÖÉê=~åÇ=ãçêÉ=ÇáîÉêëÉ=äÉáëìêÉ=çÑÑÉêX=

• kÉÉÇ=íç=áãéêçîÉ=èì~äáíó=çÑ=ÉñéÉêáÉåÅÉ=íç=~ííê~Åí=ãçêÉ=éÉçéäÉX=

• ^êíë=éêçîáëáçå=Ü~ë=Ñ~áäÉÇ=áå=_êçãäÉóJ=éçëëáÄáäáíó=Ñçê=~å=~êíë=ÅÉåíêÉ=çê=ãÉÇáìã=ëáòÉÇ=ÅçåÅÉêí=Ü~ää=çê=çíÜÉê=~ííê~Åíáçå=ëÜçìäÇ=ÄÉ=ÉñéäçêÉÇX=

• `ÜìêÅÜáää=qÜÉ~íêÉ=áë=~=âÉó=ÑÉ~íìêÉ=Ñçê=íÜÉ=íçïå=ÅÉåíêÉ=~åÇ=Å~í~äóëí=Ñçê=ÅÜ~åÖÉJ=ëÜçìäÇ=ÄÉ=~=ÑçÅìë=Ñçê=êÉÖÉåÉê~íáçåW=åÉÉÇ=íç=ÅçåëáÇÉê=éçíÉåíá~ä=Ñçê=ëíêçåÖÉê=äÉáëìêÉLÅìäíìê~ä=ÑçÅìëI=áãéêçîÉÇ=ìëÉ=çÑ=ÄìáäÇáåÖë=~åÇ=ÅêÉ~íáçå=çÑ=éìÄäáÅ=ëé~ÅÉLäáåâ=íç=m~êâX=

• kÉÉÇ=Ñçê=Å~êÉÑìä=ÅçåëáÇÉê~íáçå=çÑ=äçÅ~íáçå=çÑ=äÉáëìêÉLÅáåÉã~=Ñ~ÅáäáíáÉë=~ë=íÜÉó=ïáää=ÄÉÅçãÉ=~=ÑçÅìë=áå=íÜÉ=íçïå=ÅÉåíêÉX===

• bîÉåáåÖ=ÉÅçåçãó=äáãáíÉÇ=~åÇ=ÅçìäÇ=ÄÉ=áãéêçîÉÇ=Äó=çéÉåáåÖ=ìé=íÜÉ=éÉÇÉëíêá~å=ëÉÅíçê=çÑ=íÜÉ=eáÖÜ=píêÉÉí=~ÑíÉê=Üçìêë=íç=ÅêÉ~íÉ=~ÅíáîáíóX=

• kÉÉÇ=íç=~ÇÇêÉëë=éêçÄäÉãë=çÑ=ÉîÉåáåÖ=ÉÅçåçãó=Äó=áåíêçÇìÅíáçå=çÑ=åÉï=Ñ~ÅáäáíáÉë=ïÜáÅÜ=ïáää=~ééÉ~ä=íç=~=ïáÇÉê=ã~êâÉíL~ÖÉ=ÖêçìéëXÄ=

• iáÄê~êó=~å=áãéçêí~åí=Ñ~Åáäáíó=Ñçê=äçÅ~ä=éÉçéäÉJ=åÉÉÇ=íç=ÉñéäçêÉ=çééçêíìåáíáÉë=Ñçê=ÉåÜ~åÅÉÇ=~åÇ=ÉñíÉåÇÉÇ=êçäÉ=áå=qçïå=`ÉåíêÉ=ÉÖW=ÖêçìåÇ=Ñäççê=éêÉëÉåÅÉI=ÉîÉåáåÖ=~ÅíáîáíáÉëI=Å~Ñ¨=~êÉ~K=

=Heritage and Design

• kÉÉÇ=Ñçê=áåÅêÉ~ëÉÇ=ÉãéÜ~ëáë=çå=íÜÉ=ÚÜÉêáí~ÖÉÛ=ÉäÉãÉåí=~åÇ=ÅÜ~ê~ÅíÉêáëíáÅë=çÑ=íÜÉ=~êÉ~=çå=íÜÉ=ÇÉëáÖå=~åÇ=ÇÉîÉäçéãÉåí=çÑ=_êçãäÉóK=rëÉ=ÜÉêáí~ÖÉ=~ë=~=âÉó=ÇêáîÉê=Ñçê=éêçãçíáåÖ=êÉÖÉåÉê~íáçå=Eä~êÖÉ=é~êí=çÑ=íçïå=ÅÉåíêÉ=áë=~=ÅçåëÉêî~íáçå=~êÉ~FX=

• kÉÉÇ=íç=éêçíÉÅí=~åÇ=éêÉëÉêîÉ=íÜÉ=ÄÉëí=~ëéÉÅíë=çÑ=_êçãäÉóX=

• _êçãäÉó=kçêíÜ=êÉí~áåë=ëÅ~äÉ=çÑ=ã~êâÉí=íçïå=ïÜáÅÜ=ëÜçìäÇ=ÄÉ=éêçíÉÅíÉÇJ=éçíÉåíá~ä=Ñçê=ãçêÉ=áåíÉåëáîÉ=ÇÉîÉäçéãÉåí=áå=_êçãäÉó=pçìíÜ=

• båîáêçåãÉåíLÜÉêáí~ÖÉ=áë=~=Ä~ëáÅ=ÉäÉãÉåí=çÑ=íÜÉ=íçïå=ÅÉåíêÉX=

• _êçãäÉó=áë=åçí=_äìÉï~íÉê=çÑ=`êçóÇçåX=

• kÉÉÇ=íç=ÅêÉ~íÉ=~å=Ú~ííê~ÅíáîÉÛ=~íãçëéÜÉêÉ=áå=çêÇÉê=íç=ã~âÉ=éÉçéäÉ=ÅçãÉ=íç=_êçãäÉóX=

• fåÅçêéçê~íÉ=~=ïÉ~íÜÉê=éêçíÉÅíÉÇ=ëÜçééáåÖ=ëíêÉÉíX==

• kÉÉÇ=Ñçê=íáÖÜíÉê=ÖìáÇ~åÅÉ=çå=ÇÉëáÖå=~åÇ=ÇÉîÉäçéãÉåí=áå=çêÇÉê=íç=ÉåëìêÉ=ÜáÖÜ=èì~äáíóK=

=General issues

• aÉîÉäçéãÉåí=çÑ=íçïå=ÅÉåíêÉ=áë=Åçåëíê~áåÉÇ=Äó=áíë=äáåÉ~ê=ÑçêãI=íçéçÖê~éÜó=~åÇ=íáÖÜí=êÉëáÇÉåíá~ä=êáåÖX==

• kÉÉÇ=íç=ÇêáîÉ=ÜáÖÜ=èì~äáíó=ÅÜ~åÖÉJ=ÇÉÅäáåÉ=áë=îÉêó=ÉîáÇÉåíX=



• bñáëíáåÖ=dm=Ñ~ÅáäáíáÉë=ïáää=åÉÉÇ=íç=ÄÉ=áãéêçîÉÇ=íç=ÅçéÉ=ïáíÜ=íÜÉ=éêçéçëÉÇ=êÉëáÇÉåíá~ä=ÇÉîÉäçéãÉåíëK=kÉÉÇ=íç=~ëëÉëë=éçëëáÄáäáíó=çÑ=ÉñíÉåÇáåÖ=éêçîáëáçå=áåíç=íçïå=ÅÉåíêÉX=

• qÜÉêÉ=áë=~=êÉèìáêÉãÉåí=Ñçê=ÜáÖÜ=èì~äáíó=ãçÇÉêå=çÑÑáÅÉ=Ñäççê=ëé~ÅÉ=Ñçê=Éëí~ÄäáëÜÉÇ=ÄìëáåÉëëÉë=íç=ãçîÉ=áåíçX=

• qÜÉêÉ=áë=~=åÉÉÇ=Ñçê=ä~êÖÉê=~åÇ=ãçêÉ=ÇáîÉêëÉ=~ééêç~ÅÜ=íç=ÄìëáåÉëë=éêçîáëáçåX=

• qÜÉêÉ=áë=ÅìêêÉåíäó=~=äçí=çÑ=ìåÇÉê=ìíáäáëÉÇ=çÑÑáÅÉ=~ÅÅçããçÇ~íáçåX=

• kÉÉÇ=íç=ÉñéäçêÉ=ÖêçïáåÖ=éçíÉåíá~ä=çÑ=_êçãäÉó=~ë=íçìêáëí=ÇÉëíáå~íáçå=Eäáåâ=íç=ÜÉêáí~ÖÉ=~åÇ=çéÉå=ÅçìåíêóëáÇÉFX=

• kÉÉÇ=Ñçê=~=èì~äáíó=ÜçíÉä=éêçîáëáçå=íç=Å~íÉê=Ñçê=íÜÉ=ÄìëáåÉëë=ã~êâÉí=~åÇ=îáëáíçêëX=

• få=~ëëÉëëáåÖ=Üçï=ãìÅÜ=ÅÜ~åÖÉ=_êçãäÉó=Å~å=~ÅÅçããçÇ~íÉI=åÉÉÇ=íç=äççâ=~í=Å~é~Åáíó=çÑ=ëáíÉë=~åÇ=ÄìáäÇáåÖëX==

• kÉÉÇ=íç=ã~âÉ=`áîáÅ=`ÉåíêÉ=ãçêÉ=ÉÑÑáÅáÉåí=~åÇ=ãçêÉ=~ÅÅÉëëáÄäÉK=

PUBLIC FOCUS WORKSHOP (26 May 2005 (evening))

qÜÉ=mìÄäáÅ=cçÅìë=tçêâëÜçé=ï~ë=~ííÉåÇÉÇ=Äó=NM=êÉéêÉëÉåí~íáîÉë=Ñêçã=äçÅ~ä=áåíÉêÉëí=I=êÉëáÇÉåí=~åÇ=~ãÉåáíó=ÖêçìéëK====qÜÉ=âÉó=áëëìÉë=ê~áëÉÇ=ÇìêáåÖ=íÜÉ=mìÄäáÅ=cçÅìë=tçêâëÜçé=~êÉ=ëìãã~êáëÉÇ=ÄÉäçï=ìåÇÉê=íÜÉ=ÑçääçïáåÖ=íÜÉãÉëW=ãáñ=çÑ=ìëÉëI=íê~åëéçêíI=ÅìäíìêÉ=~åÇ=äÉáëìêÉI=ÇÉëáÖå=~åÇ=ÖÉåÉê~ä=áëëìÉëK==Mix of uses

• kÉÉÇ=íç=ÅêÉ~íÉ=~=Ä~ä~åÅÉ=íç=ÅìêêÉåí=êÉí~áä=ìëÉë=ïáíÜ=áåÅêÉ~ëÉÇ=ÅçããÉêÅá~äI=êÉëáÇÉåíá~ä=~åÇ=äÉáëìêÉ=ìëÉëX=

• aÉîÉäçéãÉåí=çÑ=ÅçããÉêÅá~ä=ëÉÅíçê=ïáää=ëìééçêí=îá~Äáäáíó=çÑ=êÉí~áä=ëÉÅíçêX=

• mìÄäáÅ=ÉñéÉÅí~íáçå=çÑ=ÖççÇ=èì~äáíó=ëÜçééáåÖ=çÑÑÉêI=áåÅäìÇáåÖW=

• mêÉëÉêîáåÖ=Úëã~ää=ÄçìíáèìÉÛ=íóéÉ=ëÜçéëX=

• eáÖÜ=èì~äáíó=ÇÉé~êíãÉåí=ëíçêÉëJ=éêÉÑÉêÉåÅÉ=Ñçê=ãçêÉ=íÜ~å=N=åÉï=ëíçêÉX=~åÇ=

• oÉíìêå=çÑ=âÉó=êÉí~áäÉêë=EëìÅÜ=~ë=eçìëÉ=çÑ=cê~ëÉêI=FK=

• kÉÉÇ=Ñçê=Ä~ä~åÅÉ=ÄÉíïÉÉå=íÜÉ=Ñ~ÅáäáíáÉë=áå=kçêíÜ=~åÇ=pçìíÜ=_êçãäÉóJ=éçíÉåíá~ä=íç=íê~åëÑÉê=ëçãÉ=ìëÉë=íç=ëçìíÜX=

• oÉí~áä=ãáñ=ïáää=ÄÉ=ã~áå=Çê~ï=ÑçääçïÉÇ=Äó=äÉáëìêÉK=kÉÉÇ=Ñçê=ãìäíáéäÉñ=ÅáåÉã~=íç=ÑÉÉÇ=ÉîÉåáåÖ=ÉÅçåçãóX=

• kÉÉÇ=íç=~ííê~Åí=~=èì~äáíó=ÇÉé~êíãÉåí=ëíçêÉ=áããÉÇá~íÉäóI=ïáíÜ=~=ëÉÅçåÇ=íç=ÅçãÉ=áå=íÜÉ=ãÉÇáìã=íÉêãK=oÉí~áä=ãáñ=~åÇ=çÑÑÉê=~êÉ=~=ã~àçê=Çê~ï=Ñçê=_êçãäÉóX=ÅäçëÉäó=ÑçääçïÉÇ=Äó=äÉáëìêÉ=Ñ~ÅáäáíáÉëX=

• mçíÉåíá~ä=Ñçê=ÅêÉ~íáçå=çÑ=~=Å~Ñ¨=ÅìäíìêÉ=çå=íÜÉ=eáÖÜ=píêÉÉíX=~åÇ=

• kÉÉÇ=íç=ÄêáåÖ=êÉëáÇÉåíë=Ä~Åâ=áåíç=íçïå=ÅÉåíêÉK=



Transport

• j~àçê=áëëìÉ=çÑ=íê~åëéçêí=~åÇ=é~êâáåÖ=ãìëí=ÄÉ=~ÇÇêÉëëÉÇX=

• kÉÉÇ=íç=ÉåëìêÉ=íÜ~í=êÉèìáêÉãÉåíë=Ñçê=é~êâáåÖ=EëÜçééÉêëI=ïçêâÉêë=~åÇ=êÉëáÇÉåíëF~êÉ=~ÇÇêÉëëÉÇ=~åÇ=íÜ~í=åÉï=ÇÉîÉäçéãÉåí=ÇçÉë=åçí=áåÅêÉ~ëÉ=éêÉëëìêÉë=çå=ëìêêçìåÇáåÖ=êÉëáÇÉåíá~ä=ëíêÉÉíëX=

• qê~åëéçêí=~åÇ=é~êâáåÖ=áëëìÉë=åÉÉÇ=íç=Å~íÉê=Ñçê=íÜÉ=ÑçääçïáåÖW=

• mÉçéäÉ=ÅçãáåÖ=áå=íç=ëÜçé=~åÇ=ïçêâX=

• mÉçéäÉ=ÇçáåÖ=áåíÉêÅÜ~åÖÉ=~åÇ=ÅçããìíÉêëX=~åÇ=

• mÉçéäÉ=äáîáåÖ=áå=íçïå=ÅÉåíêÉ=EêÉëáÇÉåíá~ä=é~êâáåÖFK=

• kÉÉÇ=áãéêçîÉãÉåíë=íç=éìÄäáÅ=íê~åëéçêí=êçìíáåÖI=~ÅÅÉëë=~åÇ=äÉÖáÄáäáíó=íç=ÅçååÉÅí=kçêíÜ=~åÇ=pçìíÜ=_êçãäÉó=ëí~íáçåëX=

• lééçêíìåáíó=Ñçê=Äìë=áåíÉêÅÜ~åÖÉ=~í=_êçãäÉó=pçìíÜ=pí~íáçå=~åÇ=áãéêçîÉÇ=Ñ~ÅáäáíáÉë=~í=_êçãäÉó=pçìíÜX=

• _êçãäÉó=pçìíÜ=éêçîáÇÉë=~å=áå~ÇÉèì~íÉ=Ö~íÉï~ó=íç=qçïå=`ÉåíêÉX==

• kÉÉÇ=íç=ÅçåëáÇÉê=çééçêíìåáíó=çÑ=çéÉåáåÖ=ìé=eáÖÜ=píêÉÉí=áå=ÉîÉåáåÖë=íç=áãéêçîÉ=~ÅÅÉëëáÄáäáíóLáåÅêÉ~ëÉ=~ÅíáîáíóX=

• kÉÉÇ=íç=ÅçåëáÇÉê=éçíÉåíá~ä=Ñçê=m~êâ=C=oáÇÉK=

Culture and Leisure

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• kÉÉÇ=áåÅêÉ~ëÉÇ=ÉãéÜ~ëáë=çå=ÅìäíìêÉ=~åÇ=äÉ~êåáåÖJ=ëÜçìäÇ=ÄÉ=ëÜçïÅ~ëÉÇ=~åÇ=ãçêÉ=~ÅÅÉëëáÄäÉX==

• `ìêêÉåíäó=äáãáíÉÇ=ÉîÉåáåÖ=ÉÅçåçãóJ==íÜáë=ÅçìäÇ=ÄÉ=áãéêçîÉÇ=Äó=çéÉåáåÖ=ìé=éÉÇÉëíêá~åáëÉÇ=ëÉÅíçê=çÑ=íÜÉ=eáÖÜ=píêÉÉí=~ÑíÉê=Üçìêë=EáåÅêÉ~ëáåÖ=~åáã~íáçå=~åÇ=~ÅÅÉëëáÄáäáíóFX=

• pìééçêí=Ñçê=ÅáåÉã~X=

• j~êâÉíë=~êÉ=~=ïÉäÅçãÉ=~ÅíáîáíóI=Äìí=èì~äáíó=ÅçìäÇ=ÄÉ=áãéêçîÉÇK=mçíÉåíá~ä=íç=ãçîÉ=ëíêÉÉí=ã~êâÉíë=ëìÅÜ=~ë=`Ü~êíÉê=j~êâÉí=áåíç=íÜÉ=íçïå=ÅÉåíêÉX=

• mçíÉåíá~ä=çÑ=pçìíÜ=_êçãäÉó=~ë=~=åÉï=ÑçÅìë=Ñçê=äÉáëìêÉ=~Åíáîáíó=ëÜçìäÇ=ÄÉ=ÉñéäçêÉÇX=

• kÉÉÇ=Ñçê=~=ÜçíÉä=áå=íçïå=ÅÉåíêÉX=

• kÉÉÇ=Ñçê=Å~Ñ¨LÅìäíìê~ä=ÑçÅìë=çå=eáÖÜ=píêÉÉíJ=ïçìäÇ=çÑÑÉê=ãçêÉ=ÇáîÉêëáíóK=mçíÉåíá~ä=Ñçê=Å~Ñ¨=âáçëâëLé~îáäáçåë=áå=eáÖÜ=píêÉÉíX==

• kÉÉÇ=íç=~ÇÇêÉëë=éêçÄäÉãë=~ëëçÅá~íÉÇ=ïáíÜ=ÉîÉåáåÖ=ÉÅçåçãóJ=Ççãáå~íÉÇ=Äó=ä~êÖÉ=ÅÜ~áå=éìÄë=~åÇ=ÚÇêáåâáåÖ=ÅìäíìêÉÛK=kÉÉÇ=íç=çÑÑÉê=ÖêÉ~íÉê=ÇáîÉêëáíó=ïáíÜáå=íÜÉ=íçïåX=

• fåíÉÖê~íÉ=ÜÉ~äíÜ=ïáíÜ=äÉáëìêÉJ=ÅçåÅÉéí=çÑ=ÚÜÉ~äíÜó=äáîáåÖÛK=

Design

• råáèìÉåÉëë=çÑ=_êçãäÉó=ÇÉêáîÉë=Ñêçã=áíë=ÅÜ~ê~ÅíÉêLÜÉêáí~ÖÉJ=íÜáë=ëÜçìäÇ=ÄÉ=Äìáäí=çåX=

• =

• aáÑÑÉêÉåí=~ééêç~ÅÜ=íç=ëÅ~äÉLÇÉëáÖå=ã~ó=ÄÉ=~ééêçéêá~íÉ=áå=ÇáÑÑÉêÉåí=~êÉ~ë=ÇÉéÉåÇáåÖ=çå=ÅÜ~ê~ÅíÉêX=

• kÉÉÇ=íç=êÉáåÑçêÅÉ=ÇáëíáåÅíáîÉ=ÚÅçìåíó=íçïåÛ=ÑÉÉä=~åÇ=éêçíÉÅí=ÜÉêáí~ÖÉK=eÉêáí~ÖÉ=ïáää=ÄÉ=~=Å~í~äóëí=Ñçê=ÑìíìêÉX=



• kÉÉÇ=íç=~ÇÇêÉëë=ÅìêêÉåí=éÉêÅÉéíáçå=çÑ=_êçãäÉó=~ë=~å=ìåë~ÑÉ=ÉåîáêçåãÉåíJ=ÇÉÅäáåáåÖ=êÉí~áä=Ñ~ÅáäáíáÉëX=

• jçÇÉêå=ÜáÖÜ=èì~äáíó=~êÅÜáíÉÅíìêÉ=ÅçìäÇ=ÅêÉ~íÉ=~=ÚÜìÄÛ=çÑ=~Åíáîáíó=áå=_êçãäÉó=Äìí=ãìëí=ÄÉ=~ééêçéêá~íÉäó=~åÇ=êÉëéÉÅí=ÜÉêáí~ÖÉLÉñáëíáåÖ=ÅÜ~ê~ÅíÉêX=

• eáÖÜ=êáëÉ=ÇÉîÉäçéãÉåí=áå~ééêçéêá~íÉJ=ÜáÖÜÉê=ÄìáäÇáåÖë=åÉÉÇ=íç=êÉëéÉÅí=íÜÉ=äçÅ~äáëÉÇ=ëÅ~äÉ=~åÇ=ÅÜ~ê~ÅíÉê=çÑ=íÜÉ=ÅçåíÉñíX=

• _~ëÉ=ÇÉëáÖå=çå=íÜÉ=éêÉÅÉÇÉåí=çÑ=Ú_êáÖÜíçåÛI=áåÅäìÇáåÖW=

• oÉíÉåíáçå=çÑ=íÜÉ=ä~åÉë=áå=kçêíÜ=_êçãäÉóX=

• mêçîáÇÉ=åÉï=ëÜçééáåÖ=Ñ~ÅáäáíáÉëX=

• `êÉ~íÉ=ÅçåÑÉêÉåÅÉ=Ñ~ÅáäáíóX=~åÇ=

• fãéêçîÉ=äáÄê~êóK=

General issues

• `çåÅÉêå=íÜ~í=éä~ååáåÖ=éçäáÅó=ïáää=ÄÉ=~ÄäÉ=íç=ÇÉäáîÉê=ÅÜ~åÖÉ=ëìáí~ÄäÉ=íç=_êçãäÉó=ÅçåíÉñíX=

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• `êÉ~íáçå=çÑ=~=åÉíïçêâ=çÑ=éìÄäáÅ=ëé~ÅÉë=Ó=áåíÉÖê~íáåÖ=_êçãäÉóÛë=~ëëÉíëX=

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• _êçãäÉó=pçìíÜ=ÅìêêÉåíäó=Ü~ë=åç=êÉ~ä=ÅÜ~ê~ÅíÉê=çê=ÚëÉåëÉ=çÑ=éä~ÅÉÛ=íç=Çê~ï=áå=ìëÉêë=~åÇ=êÉëáÇÉåíëX=

• kçêíÜ=~åÇ=ëçìíÜ=çÑ=íçïå=ÅÉåíêÉ=~êÉ=ÇáëàçáåíÉÇ=~åÇ=åÉÉÇ=íç=ÄÉ=ÄÉííÉê=áåíÉÖê~íÉÇX=

• kÉÉÇ=íç=äççâ=~í=éêÉÅÉÇÉåíë=ÉÖW=_êáÖÜíçåJ=ãáñ=çÑ=ÜÉêáí~ÖÉI=ãçÇÉêå=ëÜçééáåÖI=åÉï=äáÄê~êóI=ÅçåÑÉêÉåÅÉ=Ñ~ÅáäáíáÉë=ÉíÅX=

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• hÉó=êÉí~áä=ìëÉëJ=åÉÉÇ=íç=ÄÉ=ÄêçìÖÜí=Ä~ÅâJ=ÉëéÉÅá~ääó=aÉé~êíãÉåí=píçêÉ=EåÉÉÇ=Ñçê=Ü~êÇï~êÉLïÜáíÉ=ÖççÇë=çìíäÉíFK=`çåÅÉêå=~Äçìí=qçïå=`ÉåíêÉ=ÄÉáåÖ=íçí~ääó=í~âÉå=çîÉê=Äó=Ñ~ëÜáçåLÅ~Ñ¨=çìíäÉíëX=

• båîáêçåãÉåí=ÑÉÉäë=ìåë~ÑÉJ=ÇìÉ=áå=é~êí=íç=ä~Åâ=çÑ=ÉîÉåáåÖ=~ÅíáîáíóX=

B R O M L E Y T O W N C E N T R E A R E A A C T I O N P L A N | 1 0


• sá~ÄáäáíóJ=éêçéçë~äë=ãìëí=ÄÉ=Å~é~ÄäÉ=çÑ=ÇÉäáîÉêóX=

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• qáãÉí~ÄäÉ=ëÜçìäÇ=ÄÉ=~ãÄáíáçìëK=

=KEY ISSUES AND OPPORTUNITIES FOR CONSIDERATION

qÜÉ=âÉó=áëëìÉë=~åÇ=çééçêíìåáíáÉë=ê~áëÉÇ=~í=íÜÉ=tçêâëÜçéë=ã~ó=ÄÉ=ëìãã~êáëÉÇ=~ë=ÑçääçïëW=

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• mêçíÉÅí=~åÇ=ÉåÜ~åÅÉ=íÜÉ=ÜÉêáí~ÖÉ=çÑ=_êçãäÉóX=

• fãéêçîÉ=_êçãäÉó=pçìíÜ=~åÇ=kçêíÜ=pí~íáçåë=~ë=íê~åëéçêí=áåíÉêÅÜ~åÖÉë=~åÇ=Ö~íÉï~óëX=

• mçíÉåíá~ä=Ñçê=áåíÉåëáÑáÅ~íáçå=çÑ=~Åíáîáíó=~í=_êçãäÉó=pçìíÜX=

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• kÉÉÇ=Ñçê=~ééêçéêá~íÉ=Ä~ä~åÅÉ=ÄÉíïÉÉå=íçïå=ÅÉåíêÉ=ìëÉëX=

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• o~íáçå~äáëÉ=é~êâáåÖ=~åÇ=ã~ñáãáëÉ=çééçêíìåáíáÉë=Ñçê=ëÜ~êÉÇ=ìëÉX=

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• kÉÉÇ=íç=áãéêçîÉ=éìÄäáÅ=íê~åëéçêí=~ÅÅÉëëáÄáäáíó=~åÇ=Ñ~ÅáäáíáÉëX=

• kÉÉÇ=íç=~ÇÇêÉëë=éêçÄäÉãë=çÑ=ÉîÉåáåÖ=ÉÅçåçãóK=

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3. next steps ^í=íÜÉ=ÅäçëÉ=çÑ=íÜÉ=tçêâëÜçéëI=íÜÉ=íÉÅÜåáÅ~ä=íÉ~ã=áÇÉåíáÑáÉÇ=íÜÉ=åÉñí=ëíÉéë=Ñçê=ÑìêíÜÉê=~ééê~áë~ä=~åÇ=íÜÉ=ëìÄëÉèìÉåí=ëí~ÖÉë=çÑ=íÜÉ=ëíìÇóK=qÜÉëÉ=áåÅäìÇÉW=

• oÉîáÉï=~åÇ=~å~äóëáë=çÑ=êÉëéçåëÉëX=

• `çåëáÇÉê~íáçå=~åÇ=íÉëíáåÖ=çÑ=ÉãÉêÖáåÖ=ÇÉîÉäçéãÉåí=çéíáçåë=~åÇ=íÉÅÜåáÅ~ä=áëëìÉëX=

• ^ÇÇáíáçå~ä=íÉÅÜåáÅ~ä=íÉëíáåÖX=~åÇ=

• cìêíÜÉê=ãÉÉíáåÖë=ïáíÜ=ëí~âÉÜçäÇÉêë=~åÇ=íÉÅÜåáÅ~ä=~ÇîáëçêëK==m~êíáÅáé~åíë=ïáää=Ü~îÉ=~å=çééçêíìåáíó=íç=ÅçåíêáÄìíÉ=íç=íÜÉ=ÑìêíÜÉê=ÇÉîÉäçéãÉåí=çÑ=íÜÉ=^^mK=qÜêÉÉ=ÑìêíÜÉê=ëí~ÖÉë=çÑ=Åçåëìäí~íáçå=ïáää=í~âÉ=éä~ÅÉ=ïáíÜ=âÉó=ëí~âÉÜçäÇÉêë=ÇìêáåÖ=íÜÉ=éêÉé~ê~íáçå=çÑ=íÜÉ=^^mW===pí~ÖÉ=OW=qÜÉ=îáëáçåáåÖ=ëí~ÖÉ=Egìäó=OMMRF=ïáää=áåÅäìÇÉ=~=ëÉÅçåÇ=âÉó=ëí~âÉÜçäÇÉê=ïçêâëÜçé=~åÇ=~=éìÄäáÅ=ÑçÅìë=ïçêâëÜçéK==qÜáë=ïáää=ÑçÅìë=çå=íÜÉ=ÑçääçïáåÖW=

• bëí~ÄäáëÜáåÖ=~==îáëáçå=Ñçê=_êçãäÉóX=

• fÇÉåíáÑóáåÖ=íÜÉ=éêáåÅáéäÉë=~åÇ=é~ê~ãÉíÉêë=Ñçê=íÜÉ=éêÉé~ê~íáçå=çÑ==ÇÉîÉäçéãÉåí==çéíáçåëX=

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• fÇÉåíáÑóáåÖ=áëëìÉë=Ñçê=ÑìêíÜÉê=íÉëíáåÖK==pí~ÖÉ=PW=aÉîÉäçéáåÖ=íÜÉ=léíáçåë=EpÉéíÉãÄÉê=OMMRF=ïáää=áåÅäìÇÉ=~=íÜáêÇ=ëÉêáÉë=çÑ==ëí~âÉÜçäÇÉê=ïçêâëÜçéë=~ë=é~êí=çÑ=íÜÉ=~ééê~áë~ä=çÑ=ÇÉîÉäçéãÉåí=çéíáçåë==pí~ÖÉ=QW=mêÉÑÉêêÉÇ=léíáçåë=Eg~åì~êó=OMMSF=ïáää=áåÅäìÇÉ=~=ÑìêíÜÉê=ëÉêáÉë=çÑ=ïçêâëÜçéë=~åÇ=~=éìÄäáÅ=ÉñÜáÄáíáçå=éêáçê=íç=éêÉé~ê~íáçå=çÑ=íÜÉ=Çê~Ñí=^^mK==qÜÉ=éìÄäáÅ=~åÇ=âÉó=ëí~âÉÜçäÇÉêë=ïáää=Ü~îÉ=~å=çééçêíìåáíó=íç=êÉîáÉï=~åÇ=ÅçããÉåí=çå=íÜÉ=éêçéçë~äë=áå=ãçêÉ=ÇÉí~áä=ÇìêáåÖ=íÜÉ=ÑìêíÜÉê=ëí~ÖÉë=çÑ=Åçåëìäí~íáçåK=====



appendix A1

ISSUES AND OPPORTUNITIES KEY STAKEHOLDER WORKSHOP INVITEES

qÜÉ=ÑçääçïáåÖ=áåÇáîáÇì~äë=~åÇ=çêÖ~åáë~íáçåë=ïÉêÉ=áåîáíÉÇ=íç=íÜÉ=hÉó=pí~âÉÜçäÇÉê=tçêâëÜçéW====

fåÇáîáÇì~ä= lêÖ~åáë~íáçå=j~íí=_Éää= jbq=mçäáÅÉJ=`çããìåáíó=m~êíåÉêëÜáéë=gáää=tÉÄÄ= _êçãäÉó=mêáã~êó=`~êÉ=qêìëí=qÜÉ=bñÉÅìíáîÉ=^Çãáåáëíê~íçê= içåÇçå=^ãÄìä~åÅÉ=pÉêîáÅÉë=pìéÉêáåíÉåÇÉåí=`Ü~êäÉë=dêáÖÖë= jbq=mçäáÅÉ==jê=`Ü~êäÉë=eçêíçå== pçìíÜÉêå=dç=~ÜÉ~Ç= j~íí=_~ää== pçìíÜÉêå=dç=~ÜÉ~Ç=

m`=jáÅÜ~Éä=i~åÉ=jbq=mçäáÅÉJ=`êáãÉ=mêÉîÉåíáçå=aÉëáÖå=^Çîáëçê=

_êá~å=háêÄó= kÉíïçêâ=o~áä=jê=o=j~ëëÉíí= iáÅÉåëÉÇ=q~ñá=aêáîÉêë=^ëëçÅá~íáçå=iíÇjê=a~îÉ=pãáíÜ= i``=`óÅäáåÖ=qÜÉ=pÉÅêÉí~êó= cêÉáÖÜí=qê~åëéçêí=^ëëçÅá~íáçå=iíÇ=jê=s=píçéë= içåÇçå=qê~åëéçêí=rëÉêë=`çããáííÉÉ=`ÜáÉÑ=fåëéÉÅíçê=jáâÉ=pã~ääã~å= jbq=mçäáÅÉ=Ópb=qê~ÑÑáÅ=aáîáëáçå==

jë=h~êÉå=dççÅÜ=içåÇçå=cáêÉ=C=`áîáä=aÉÑÉåÅÉ=^ìíÜçêáíó=EpçìíÜÉêå=`çãã~åÇF=

jê=d~êó=tççÇ= jÉíêçÄìë=jê=aáÅâ=e~ääÉ= içåÇçå=_ìëÉë=jê=_Éå=mäçïÇÉå= qê~åëéçêí=Ñçê=içåÇçå=jë=`~íÜÉêáåÉ=mÜáääéçííë= qÜÉ=_êáíáëÜ=jçíçêÅóÅäáëíë=cÉÇÉê~íáçå=jê=o~ó=t~íëçå= cêáÉåÇë=çÑ=íÜÉ=b~êíÜ=jê=m~ìä=eçééÉå= båîáêçåãÉåí=^ÖÉåÅó=jê=^=_óêåÉ= båÖäáëÜ=eÉêáí~ÖÉ=jê=`=jáíÅÜáëçå= `çåÑÉÇÉê~íáçå=çÑ=_êáíáëÜ=fåÇìëíêó=a~îáÇ=cçêíó= _ìëáåÉëëJcçÅìë=m~ìä=`ê~óÑçêÇ= _~åâ=çÑ=^ãÉêáÅ~=píÉîÉ=`Ü~åÇäÉê= dä~ÇÉë=pÜçééáåÖ=`ÉåíêÉ=hÉêêó=gçÜåëçå= `ÜìêÅÜáää=fåëìê~åÅÉ=

jêë=gìäáÉ=jáääÉê= oçó~ä=_~åâ=çÑ=pÅçíä~åÇ=



fåÇáîáÇì~ä= lêÖ~åáë~íáçå=`~êãÉä=lDkáÉää= j~êâë=~åÇ=péÉåÅÉêÛë=

= mêáã~êâ=

m~íêáÅâ=t~ää= _êçãäÉó=`çìêí=eçíÉä=E_Éëí=tÉëíÉêåF=

aÉêÉâ=káÅÜçääë= `ÜìêÅÜáää=qÜÉ~íêÉ=jê=d=v=v~íÉë= _êçãäÉó=qê~ÇÉë=råáçå=`çìåÅáä=jê=j=_~ä~~ãê= içåÇçå=qçìêáëí=_ç~êÇ=dáää=e~óåÉë= k~íáçå~ä=`ÜáäÇãáåÇáåÖ=^ëëçÅá~íáçå=jê=a~îáÇ=j~áå= pçìíÜ=içåÇçå=_ìëáåÉëë=

=



appendix A2

ISSUES AND OPPORTUNITIES KEY STAKEHOLDER WORKSHOP ATTENDEES

qÜÉ=ÑçääçïáåÖ=áåÇáîáÇì~äë=~åÇ=çêÖ~åáë~íáçåë=~ííÉåÇÉÇ=íÜÉ=hÉó=pí~âÉÜçäÇÉê=tçêâëÜçéW====aÉêÉâ=mçïÉää= i_=_êçãäÉó=oÉëáÇÉåíëÛ=cÉÇÉê~íáçå=m~íêáÅâ=t~ää= _êçãäÉó=`çìêí=eçíÉä=

^Äáçä~=fãçìâÜìÉÇÉ= =

`Ü~êäçííÉ=_ÉÇÇçÉ= _êçãäÉó=^Çìäí=bÇìÅ~íáçå=`çääÉÖÉ=píÉîÉ=`Ü~åÇäÉê= qÜÉ=dä~ÇÉë=a~îáÇ=j~áå= pçìíÜ=içåÇçå=_ìëáåÉëë=

_êá~å=`ççâÉ= içåÇçå=qê~åëéçêí=rëÉêë=`çããáííÉÉ=iÉÉ=e~êîÉó= cáêÉ=pí~íáçå=káÅâ=`çääáåë= båÖäáëÜ=eÉêáí~ÖÉ=

j~êÅ=qáãäáã= i__J=eÉêáí~ÖÉ=~åÇ=rêÄ~å=aÉëáÖå==^åÇêÉï=eáäÉó= qciJ==i~åÇ=rëÉ=mä~ååáåÖ=`~êçäóå=iÉïáë= _êçãäÉó=mq`=_~êÉåÇ=sÉääÉã~å= k`j^=`~êçäáåÉ=q~íÅÜÉää= k`j^=^êÅÜáÉ=^îÉêó= içåÇçå=_ìëÉë=



appendix A3

ISSUES AND OPPORTUNITIES PUBLIC FOCUS STAKEHOLDER WORKSHOP INVITEES

qÜÉ=ÑçääçïáåÖ=áåÇáîáÇì~äë=~åÇ=çêÖ~åáë~íáçåë=ïÉêÉ=áåîáíÉÇ=íç=íÜÉ=hÉó=pí~âÉÜçäÇÉê=tçêâëÜçéW==

Individual Organisation

jê=hÉå=pãáíÜ= mÉÇÉëíêá~åë=^ëëçÅá~íáçå=

= mÉÇÉëíêá~å=^ëëçÅá~íáçå=

jê=cêÉÇ=táäâáåëçå= _êçãäÉó=C=_áÖÖáå=eáää=^êÉ~=

jê=o=i~ïëçå= qÜÉ=_êçãäÉó=oç~Ç=^Åíáçå=dêçìé=

jê=t=pÉ~êÄó= cÉÇÉê~íáçå=çÑ=oÉëáÇÉåíë=^ëëçÅá~íáçå=

jê=t=o=tççÇ= i_=_êçãäÉó=oÉëáÇÉåíëÛ=cÉÇÉê~íáçå=

jê=q=_êçïå= mÉçéäÉ=táíÜ=aáë~ÄáäáíáÉë=jë=d=^=pÜáéäÉó= oÉëáÇÉåíëÛ=^ëëçÅá~íáçå=

jê=q=_~åÑáÉäÇ= eÉ~êí=çÑ=_êçãäÉó=

jê=f~å=_êçÇáÉ= _êçãäÉó=pçìíÜ=^Åíáçå=dêçìé=

jë=e=`Ü~ãÄÉêë= ^ÅÅÉëë=dêçìé=

jê=g=jÅdáää= _êçãäÉó=qçïå=`ÜìêÅÜ=

jê=j=^òÉÉò= jáåçêáíó=bíÜåáÅ=cçêìã=

jáÅÜ~Éä=gçåÉë== _êçãäÉó=`Üêáëíá~å=`ÉåíêÉ=

j~àçê=f~å=m~óåÉ= qçïå=`Ü~éä~áå==

gìÇó=cìääÉê= `çããìåáíó=iáåâ=

j~ìêÉÉå=c~ääçå= ^ÖÉ=`çåÅÉêå=

jê=a=g=tççÇ= dêçìé=C=`áîáÅ=pçÅáÉíó=

páãçå=^åëíêÉó= _êçãäÉó=kçêíÜ=oÉëáÇÉåíë=^ëëçÅá~íáçå====



appendix A4

ISSUES AND OPPORTUNITIES PUBLIC FOCUS STAKEHOLDER WORKSHOP ATTENDEES

qÜÉ=ÑçääçïáåÖ=áåÇáîáÇì~äë=~åÇ=çêÖ~åáë~íáçåë=~ííÉåÇÉÇ=íÜÉ=hÉó=pí~âÉÜçäÇÉê=tçêâëÜçéW==f~å=_êçÇáÉ= _êçãäÉó=pçìíÜ=^Åíáçå=dêçìé=gçå~íÜ~å=jÅdáää== _êçãäÉó=qçïå=`ÜìêÅÜ=páãçå=^åëíêÉó== _êçãäÉó=kçêíÜ=oÉëáÇÉåíë=^ëëçÅá~íáçå=a~îáÇ=tççÇ== dêçìé=C=`áîáÅ=pçÅáÉíó=oçÖÉê=i~ïëçå= qÜÉ=_êçãäÉó=oç~Ç=^Åíáçå=dêçìé=gÉÑÑ=oçóÅÉ= =qçåó=_~åÑáÉäÇ= eÉ~êí=çÑ=_êçãäÉó=jáÅÜ~Éä=píÉîÉåë= _êçãäÉó=`Üêáëíá~å=`ÉåíêÉ=_êìÅÉ=^åÇÉêëçå= _êçãäÉó=`Üêáëíá~å=`ÉåíêÉ=



appendix A5

ISSUES AND OPPORTUNITIES STAKEHOLDER WORKSHOPS CONSULTANT TEAM ATTENDEES

=gç~åå~=`Ü~ãÄÉêë= ba^t=jáÅâ=qáãéëçå= ba^t=s~ìÖÜ~å=^åÇÉêëçå== ba^t=dêÉÖ=`~ää~ÖÜ~å== mÉíÉê=_êÉíí=^ëëçÅá~íÉë=^åÇêÉï=tÉÉÇçå= mÉíÉê=_êÉíí=^ëëçÅá~íÉë== ==ISSUES AND OPPORTUNITIES STAKEHOLDER WORKSHOPS

LB BROMLEY ATTENDEES

=cê~åâ=tÜáíáåÖ= qçïå=`ÉåíêÉ=mêçàÉÅí=aáêÉÅíçê=oáí~=tÉëíäçíçêå= eÉ~Ç=çÑ=mä~ååáåÖ=mêçàÉÅí=j~å~ÖÉãÉåí== ===



STAGE 2: ‘Creating the vision for Bromley’


SUMMARY REPORT

September 2005


table of contents

=1 INTRODUCTION


3 SUMMARY

4 NEXT STEPS

APPENDICES

=A1: KEY STAKEHOLDER WORKSHOP INVITEES

A2: PUBLIC FOCUS STAKEHOLDER WORKSHOP INVITEES =



Acknowledgement

qÜÉ=içåÇçå=_çêçìÖÜ=çÑ=_êçãäÉó=~åÇ=íÜÉ=Åçåëìäí~åí=íÉ~ã=~êÉ=Öê~íÉÑìä=Ñçê=íÜÉ=íáãÉ=~åÇ=áåéìí=çÑ=~ää=íÉÅÜåáÅ~ä=~ÇîáëçêëI=ëí~âÉÜçäÇÉêëI=äçÅ~ä=çêÖ~åáë~íáçåë=~åÇ=äçÅ~ä=áåíÉêÉëí=Öêçìéë=ïÜç=~ííÉåÇÉÇ=íÜÉ=Ú`êÉ~íáåÖ=íÜÉ=sáëáçå=Ñçê=_êçãäÉóÛ=pí~âÉÜçäÇÉê=tçêâëÜçéë=çå=íÜÉ=NUíÜ=~åÇ=OSíÜ=çÑ=gìäó=OMMRK=qÜÉ=ëí~âÉÜçäÇÉê=ïçêâëÜçéë=Ñçêã=é~êí=çÑ=íÜÉ=Åçää~Äçê~íáîÉ=ÇÉëáÖå=éêçÅÉëë=~åÇ=ïÉêÉ=ÇÉëáÖåÉÇ=íç=ÉåëìêÉ=íÜ~í=íÜÉ=îáÉïë=çÑ=ëí~âÉÜçäÇÉêë=~åÇ=äçÅ~ä=áåíÉêÉëí=Öêçìéë=áåÑçêã=íÜÉ=É~êäó=ëí~ÖÉë=çÑ=íÜÉ=^Åíáçå=^êÉ~=mä~å=éêçÅÉëëK=táíÜçìí=íÜÉ=ÇÉÇáÅ~íÉÇ=ÉÑÑçêíë=çÑ=~ää=é~êíáÅáé~åíëI=íÜÉ=ïçêâëÜçéë=ïçìäÇ=åçí=Ü~îÉ=ÄÉÉå=éçëëáÄäÉK=



1. introduction

1.1 BACKGROUND

^ë=é~êí=çÑ=íÜÉ=råáí~êó=aÉîÉäçéãÉåí=mä~å=êÉîáÉïI=íÜÉ=içåÇçå=_çêçìÖÜ=çÑ=_êçãäÉó=áë=ÅìêêÉåíäó=éêÉé~êáåÖ=~=DåÉïJëíóäÉD=^êÉ~=^Åíáçå=mä~å=E^^mF=Ñçê=_êçãäÉó=qçïå=`ÉåíêÉ=íç=Éëí~ÄäáëÜ=íÜÉ=éçäáÅó=Ñê~ãÉïçêâ=~åÇ=ÖìáÇÉ=ÑìíìêÉ=ÇÉîÉäçéãÉåí=áå=íÜÉ=ÅÉåíêÉK==b~êäáÉê=íÜáë=óÉ~ê=íÜÉ=`çìåÅáä=ÅçããáëëáçåÉÇ=~=ãìäíáJÇáëÅáéäáå~êó=íÉ~ã=äÉÇ=Äó=êÉÖÉåÉê~íáçå=~åÇ=ã~ëíÉêéä~ååáåÖ=Åçåëìäí~åíë=ba^tI=íç=Å~êêó=çìí=êÉëÉ~êÅÜ=~åÇ=íç=ïçêâ=ïáíÜ=íÜÉ=`çìåÅáä=áå=íÜÉ=éêÉé~ê~íáçå=çÑ=íÜÉ=^^mK=tÜÉå=ÅçãéäÉíÉÇI=íÜÉ=^^m=ïáää=Ñçêã=é~êí=çÑ=íÜÉ=`çìåÅáäÛë=içÅ~ä=aÉîÉäçéãÉåí=cê~ãÉïçêâ=EiacFI=ïÜáÅÜ=ïáää=ÉîÉåíì~ääó=êÉéä~ÅÉ=íÜÉ=~ÇçéíÉÇ=råáí~êó=aÉîÉäçéãÉåí=mä~åK==qÜÉ=_êçãäÉó=qçïå=`ÉåíêÉ=^^m=ïáää=~äëç=~Åí=~ë=~å=áåîÉëíãÉåí=Ñê~ãÉïçêâ=~åÇ=ÖìáÇÉ=íç=ÇÉîÉäçéÉêëI=íÜÉ=äçÅ~ä=éä~ååáåÖ=~ìíÜçêáíó=~åÇ=çíÜÉê=éìÄäáÅ=~ÖÉåÅáÉëK==qÜÉ=Åçåëìäí~åí=íÉ~ã=áë=ïçêâáåÖ=ÅäçëÉäó=ïáíÜ=íÜÉ=`çìåÅáä=~åÇ=ëí~âÉÜçäÇÉêë=áå=íÜÉ=éêçÇìÅíáçå=çÑ=~=îáëáçå=Ñçê=íÜÉ=íçïå=ÅÉåíêÉI=íÜÉ=Éëí~ÄäáëÜãÉåí=çÑ=ÇÉîÉäçéãÉåí=~åÇ=ÇÉëáÖå=éêáåÅáéäÉë=~åÇ=íÜÉ=éêÉé~ê~íáçå=çÑ=ÇÉí~áäÉÇ=éä~ååáåÖ=éçäáÅáÉë=Ñçê=íÜÉ=íçïå=ÅÉåíêÉK==qÜÉ=`çìåÅáä=áë=êÉèìáêÉÇ=íç=ìåÇÉêí~âÉ=Åçåëìäí~íáçå=~í=É~ÅÜ=ëí~ÖÉ=çÑ=éêÉé~ê~íáçå=çÑ=íÜÉ=^^mK=qÜÉ=éêçÖê~ããÉ=çÑ=Åçåëìäí~íáçå=áåÅäìÇÉë=~=åìãÄÉê=çÑ=ÑçÅìëÉÇ=ÉîÉåíë=~í=É~ÅÜ=ëí~ÖÉ=çÑ=íÜÉ=^^m=éêçÅÉëëK=qÜÉ=ëí~ÖÉë=ÅçãéêáëÉW==

• pí~ÖÉ=NW=fëëìÉë=~åÇ=lééçêíìåáíáÉë=oÉîáÉïX=

• pí~ÖÉ=OW=`êÉ~íáåÖ=~=sáëáçå=Ñçê=_êçãäÉóX=

• pí~ÖÉ=PW=aÉîÉäçéáåÖ=íÜÉ=léíáçåëX=~åÇ=

• pí~ÖÉ=QW=mêÉÑÉêêÉÇ=léíáçåëK===qÜáë=Åçää~Äçê~íáîÉ=~ééêç~ÅÜ=íç=éä~å=ã~âáåÖ=áë=Ñìääó=ëìééçêíÉÇ=~åÇ=ÉåÅçìê~ÖÉÇ=Äó=dçîÉêåãÉåí=~åÇ=~áãë=íç=ãáíáÖ~íÉ=éçíÉåíá~ä=ÅçåÑäáÅí=íÜêçìÖÜ=ÇáëÅìëëáçåK==fí=ëÉÉâë=íç=Éëí~ÄäáëÜ=ÚÄìóJáåÛ=Äó=íÜÉ=î~êáçìë=ëí~âÉÜçäÇÉêëK==^í=íÜÉ=ë~ãÉ=íáãÉI=íÜÉ=éêçÅÉëë=áë=ÇêáîÉå=Äó=íÜÉ=çÄàÉÅíáîÉ=çÑ=ìåÇÉêëí~åÇáåÖ=íÜÉ=åÉÉÇë=çÑ=íÜÉ=Åçããìåáíó=áå=íÜÉ=fëëìÉë=~åÇ=lééçêíìåáíáÉë=ëí~ÖÉ=~åÇ=~ÇÇêÉëëáåÖ=íÜÉëÉ=áå=íÜÉ=ÇÉîÉäçéãÉåí=çÑ=~=îáëáçå=~åÇ=éêÉé~ê~íáçå=çÑ=íÜÉ=ÇÉîÉäçéãÉåí=çéíáçåë=Ñçê=íÜÉ=íçïå=ÅÉåíêÉK==qÜÉ=çìíéìíë=çÑ=íÜÉ=Ñáêëí=íÜêÉÉ=ëí~ÖÉë=çÑ=Åçåëìäí~íáçå=ïáää=áåÑçêã=íÜÉ=éêÉé~ê~íáçå=çÑ=íÜÉ=ÇÉîÉäçéãÉåí=çéíáçåë=~åÇ=êÉÑáåÉãÉåí=çÑ=íÜÉ=éêÉÑÉêêÉÇ=ÇÉîÉäçéãÉåí=çéíáçåë=áåíç=íÜÉ=Çê~Ñí=^^mK=====



1.2 CONSULTATION PROCESS

qÜÉ=Åçää~Äçê~íáîÉ=ïçêâëÜçé=éêçÅÉëë=~ääçïë=éçíÉåíá~ä=Åçåëíê~áåíëI=çééçêíìåáíáÉë=~åÇ=~ëéáê~íáçåë=íç=ÄÉ=íÜçêçìÖÜäó=Éñ~ãáåÉÇ=Äó=áåíÉêÉëíÉÇ=é~êíáÉëK==fí=ÉåÅçìê~ÖÉë=áååçî~íáîÉ=ëçäìíáçåë=íç=áëëìÉë=ëìÅÜ=~ë=íê~åëéçêíI=ãáñ=çÑ=ìëÉë=~åÇ=ÇÉëáÖåK==_ó=~ÇçéíáåÖ=~=Åçää~Äçê~íáîÉ=~ééêç~ÅÜI=íÜÉ=ÉãéÜ~ëáë=áë=çå=ÇÉîÉäçéáåÖ=ÅêÉ~íáîÉ=ëçäìíáçåë=Ñçê=çééçêíìåáíáÉë=~åÇ=áëëìÉë=ëéÉÅáÑáÅ=íç=íÜÉ=íçïå=ÅÉåíêÉK==^ë=é~êí=çÑ=íÜÉ=Ñáêëí=ëí~ÖÉ=çÑ=ëí~âÉÜçäÇÉê=Åçåëìäí~íáçåI=íÜÉ=Åçåëìäí~åí=íÉ~ã=Ñ~Åáäáí~íÉÇ=~=ëÉêáÉë=çÑ=ëí~âÉÜçäÇÉê=ïçêâëÜçéë=çå=ÄÉÜ~äÑ=çÑ=íÜÉ=`çìåÅáä=áå=j~ó=OMMR=íç=ÉñéäçêÉ=íÜÉ=áëëìÉë=~åÇ=çééçêíìåáíáÉë=Ñ~ÅáåÖ=_êçãäÉó=qçïå=`ÉåíêÉK=qÜáë=áåÅäìÇÉÇ=íÜÉ=ÑçääçïáåÖ=ÉîÉåíëW==



=qÜÉ=çÄàÉÅíáîÉ=çÑ=íÜÉ=tçêâëÜçéë=ï~ë=íç=Çê~ï=çå=íÜÉ=îáÉïëI=~ëéáê~íáçåë=~åÇ=ÉñéÉêáÉåÅÉ=çÑ=~=ïáÇÉ=ê~åÖÉ=çÑ=áåíÉêÉëíÉÇ=é~êíáÉë=~åÇ=íç=Éëí~ÄäáëÜ=íÜÉ=âÉó=áëëìÉë=~åÇ=çééçêíìåáíáÉë=íç=ÄÉ=~ÇÇêÉëëÉÇ=áå=éêÉé~ê~íáçå=çÑ=íÜÉ=^^mK=====qÜÉ=áëëìÉë=~åÇ=çééçêíìåáíáÉë=ïçêâëÜçéë=êÉéêÉëÉåíÉÇ=íÜÉ=Ñáêëí=ã~àçê=ëíÉé=áå=éêÉé~êáåÖ=íÜÉ=^^mK==qÜÉ=ÅçããÉåíë=êÉÅÉáîÉÇ=ïÉêÉ=~å~äóëÉÇ=~åÇ=êÉéçêíÉÇ=Ä~Åâ=~í=íÜÉ=sáëáçåáåÖ=tçêâëÜçéë=ÜÉäÇ=áå=ÇìêáåÖ=gìäó=OMMRK==^ë=é~êí=çÑ=íÜÉ=ëÉÅçåÇ=ëí~ÖÉ=çÑ=ëí~âÉÜçäÇÉê=Åçåëìäí~íáçåI=íÜÉ=Åçåëìäí~åí=íÉ~ã=~Ö~áå=Ñ~Åáäáí~íÉÇ=~=ëÉêáÉë=çÑ=ëí~âÉÜçäÇÉê=ïçêâëÜçéë=çå=ÄÉÜ~äÑ=çÑ=íÜÉ=`çìåÅáä=ÇìêáåÖ=gìäó=OMMR=íç=ÇáëÅìëë=~åÇ=ÄÉÖáå=íç=ÇÉîÉäçé=~=îáëáçå=Ñçê=_êçãäÉó=qçïå=`ÉåíêÉK=qÜáë=áåÅäìÇÉÇ=íÜÉ=ÑçääçïáåÖ=ÉîÉåíëW==

NK hÉó=pí~âÉÜçäÇÉêë=tçêâëÜçé=J=NUíÜ=gìäó=OMMRX=~åÇ==

OK mìÄäáÅ=cçÅìë=pí~âÉÜçäÇÉêë=tçêâëÜçé=J=OSíÜ=gìäó=OMMR=

=qÜÉ=çÄàÉÅíáîÉ=çÑ=íÜÉ=îáëáçåáåÖ=ïçêâëÜçéë=ï~ë=íç=Çê~ï=çå=íÜÉ=îáÉïëI=~ëéáê~íáçåë=~åÇ=ÉñéÉêáÉåÅÉ=çÑ=~=ïáÇÉ=ê~åÖÉ=çÑ=áåíÉêÉëíÉÇ=é~êíáÉëI=íç=Éëí~ÄäáëÜ=~=îáëáçå=~åÇ=íç=áåîÉëíáÖ~íÉ=íÜÉ=ëé~íá~ä=éêáåÅáéäÉë=~åÇ=é~ê~ãÉíÉêë=çÑ=íÜÉ=ÉãÉêÖáåÖ=ÇÉîÉäçéãÉåí=çéíáçåë=Ñçê=_êçãäÉó=íÜ~í=ëÜçìäÇ=ÄÉ=~ÇÇêÉëëÉÇ=ïáíÜáå=íÜÉ=^^mK==qÜÉ=tçêâëÜçéë=ÄêçìÖÜí=íçÖÉíÜÉê=âÉó=ëí~âÉÜçäÇÉêëJ=íÉÅÜåáÅ~ä=~ÇîáëçêëI=âÉó=_êçãäÉó=`çìåÅáä=çÑÑáÅÉêëI=ëí~íìíçêó=~ÖÉåÅáÉëI=äçÅ~ä=ÄìëáåÉëëÉëI=ä~åÇ=çïåÉêë==~åÇ=êÉéêÉëÉåí~íáîÉë=çÑ=äçÅ~ä=áåíÉêÉëí=~åÇ=êÉëáÇÉåíë=Öêçìéë=íç=àçáåíäó=áåîÉëíáÖ~íÉ=éçëëáÄáäáíáÉë=Ñçê=íÜÉ=ÑìíìêÉ=çÑ=íÜÉ=qçïå=`ÉåíêÉI=íÜêçìÖÜ=~=ëÉêáÉë=çÑ=ïçêâëÜçéëK==^=Ñìää=äáëí=çÑ=íÜÉ=Öêçìéë=~åÇ=çêÖ~åáë~íáçåë=áåîáíÉÇ=íç=íÜÉ=sáëáçåáåÖ=ïçêâëÜçéë=áë=áåÅäìÇÉÇ=áå=^ééÉåÇáñ=^N=~åÇ=ÔK==qÜáë=êÉéçêíI=éêÉé~êÉÇ=Äó=íÜÉ=Åçåëìäí~åí=íÉ~ãI=éêçîáÇÉë=~å=~ÅÅçìåí=çÑ=íÜÉ=éêçÅÉÉÇáåÖë=~åÇ=ëìãã~êáëÉë=íÜÉ=çìíéìíë=çÑ=íÜÉ=pí~ÖÉ=O=sáëáçåáåÖ=tçêâëÜçéëK===



2. Stage 2 Workshops 2.1 OVERVIEW

qÜÉ=áåíÉåíáçå=çÑ=íÜÉ=pí~ÖÉ=O=pí~âÉÜçäÇÉêëÛ=tçêâëÜçéë=ï~ë=íç=áåÑçêã=âÉó=ëí~âÉÜçäÇÉêë=çÑ=íÜÉ=^^m=éêçÅÉëëI=ÇáëÅìëë=~åÇ=ÄÉÖáå=íç=ÇÉîÉäçé=~=îáëáçå=Ñçê=_êçãäÉó=~åÇ=íç=Éñ~ãáåÉ=âÉó=éêáåÅáéäÉë=~åÇ=é~ê~ãÉíÉêë=Ñçê=íÜÉ=^^mK= 2.2 INTRODUCTORY COMMENTS

_çíÜ=íÜÉ=hÉó=pí~âÉÜçäÇÉê=~åÇ=mìÄäáÅ=cçÅìë=tçêâëÜçéë=ÅçããÉåÅÉÇ=ïáíÜ=áåíêçÇìÅíçêó=ÅçããÉåíë=Ñêçã=cê~åâ=tÜáíáåÖI=qçïå=`ÉåíêÉ=mêçàÉÅí=aáêÉÅíçê=~í=íÜÉ=içåÇçå=_çêçìÖÜ=çÑ=_êçãäÉóK=eÉ=ïÉäÅçãÉÇ=é~êíáÅáé~åíëI=Éñéä~áåÉÇ=íÜÉ=ÖÉåÉê~ä=éêçÅÉÉÇáåÖë=Ñçê=íÜÉ=ÉîÉåíë=~åÇ=áåíêçÇìÅÉÇ=íÜÉ=Åçåëìäí~åí=íÉ~ãK=qÜáë=ï~ë=ÑçääçïÉÇ=Äó=~=éêÉëÉåí~íáçå=Ñêçã=íÜÉ=éêçàÉÅí=íÉ~ã=~åÇ=çåÉ=íÜÉãÉÇ=ÇáëÅìëëáçå=ëÉëëáçå=~åÇ=~=ëé~íá~ä=ÉñÉêÅáëÉK=_çíÜ=ïçêâëÜçéë=ïÉêÉ=ÜÉäÇ=áå=`çããìåáíó=eçìëÉI=pçìíÜ=píêÉÉíI=_êçãäÉóK=

2.3 CONSULTANT PRESENTATION




• mêçàÉÅí=éêçÖê~ããÉX==

• cÉÉÇÄ~Åâ=Ñêçã=íÜÉ=fëëìÉë=~åÇ=lééçêíìåáíó=tçêâëÜçéëX=

• `çåëáÇÉê~íáçå=~åÇ=Éñ~ãéäÉë=çÑ=ÉäÉãÉåíë=íÜ~í=ã~âÉ=~=íçïå=ÅÉåíêÉ=ëìÅÅÉëëÑìä=Åçãé~êÉÇ=ïáíÜ=íÜÉ=ÉñáëíáåÖ=ëáíì~íáçå=áå=_êçãäÉóX=

• fÇÉåíáÑáÅ~íáçå=çÑ=íÜÉ=ÇÉîÉäçéãÉåí=éêáåÅáéäÉëX=

• fÇÉåíáÑáÅ~íáçå=çÑ=íÜÉ=ÇÉîÉäçéãÉåí=Ñê~ãÉïçêâ=áåÅäìÇáåÖ=íÜÉ=ÜáëíçêáÅ=ÇÉîÉäçéãÉåí=çÑ=íÜÉ=íçïå=ÅÉåíêÉI=ram=ëáíÉëI=íÜÉ=ÅçåëÉêî~íáçå=~êÉ~=~åÇ=âÉó=çééçêíìåáíó=~êÉ~ëX=

• bñéä~å~íáçå=çÑ=íÜÉ=áëëìÉë=íç=ÄÉ=~ÇÇêÉëëÉÇ=áå=íÜÉ=ïçêâëÜçé=ÄêÉ~âçìí=ëÉëëáçåëX=

• fÇÉåíáÑáÅ~íáçå=çÑ=íÜÉ=êÉèìáêÉÇ=ÇÉîÉäçéãÉåí=ãáñ=áå=_êçãäÉóX=

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• ^ÇÇáíáçå=çÑ=ãÉÇáìã=ÇÉåëáíó=êÉëáÇÉåíá~ä=ÇÉîÉäçéãÉåí=~ÄçîÉ=íÜÉ=ÉñáëíáåÖ=p~áåëÄìêóX=

• `êÉ~íáçå=çÑ=~=åÉï=éìÄäáÅ=çéÉå=ëé~ÅÉ=çå=`çääÉÖÉ=dêÉÉåX=



• aÉîÉäçéãÉåí=çÑ=Ä~êë=~åÇ=êÉëí~ìê~åíë=~êçìåÇ=íÜÉ=éÉêáãÉíÉê=çÑ=nìÉÉåë=d~êÇÉåëX=

• `êÉ~íáçå=çÑ=~=åÉï=ÇÉé~êíãÉåí=ëíçêÉ=çå=íÜÉ=ëáíÉ=çÑ=íÜÉ=m~îáäáçåX=

• `êÉ~íáçå=çÑ=~=åÉï=ä~åÇëÅ~éÉÇ=ÖêÉÉå=ÄêáÇÖÉ=Ñêçã=nìÉÉåë=d~êÇÉåë=çîÉê=hÉåíáëÜ=t~ó=íç=~=êÉäçÅ~íÉÇ=äÉáëìêÉ=ÅÉåíêÉ=çå=íÜÉ=`áîáÅ=`ÉåíêÉ=ëáíÉX=

• `êÉ~íáçå=çÑ=~=åÉï=äçï=ÇÉåëáíó=êÉëáÇÉåíá~ä=~êÉ~=íç=íÜÉ=ïÉëí=~åÇ=åçêíÜ=çÑ=íÜÉ=`áîáÅ=`ÉåíêÉ=ëáíÉX=

• oÉÑìêÄáëÜãÉåí=çÑ=íÜÉ=m~ä~ÅÉ=~ë=~=ÜçíÉä=~åÇ=ÅçåÑÉêÉåÅÉ=ÅÉåíêÉX==

• `êÉ~íáçå=çÑ=~=åÉï=íçïå=ëèì~êÉ=ëìêêçìåÇÉÇ=Äó=íÜÉ=`ÜìêÅÜáää=qÜÉ~íêÉI=Ä~êë=~åÇ=êÉëí~ìê~åíëI=~=åÉï=äáÄê~êó=~åÇ=Åçããìåáíó=Ñ~ÅáäáíáÉëX=

• `êÉ~íáçå=çÑ=~=åÉï=ÇÉé~êíãÉåí=ëíçêÉI=ãÉÇáìã=ÇÉåëáíó=êÉëáÇÉåíá~ä=~åÇ=êÉí~áä=ìåáíë=íç=íÜÉ=ïÉëí=çÑ=íÜÉ=eáÖÜ=píêÉÉíX=

• oÉÇÉîÉäçéãÉåí=çÑ=tÉëíãçêÉä~åÇ=`~ê=m~êâ=~ë=~=ãáñÉÇ=ìëÉ=ÇÉîÉäçéãÉåí=ÅçãéêáëáåÖ=çÑ=çÑÑáÅÉë=~åÇ=ÜáÖÜ=ÇÉåëáíó=êÉëáÇÉåíá~äX=~åÇ=

• oÉÇÉîÉäçé=pçìíÜ=_êçãäÉó=pí~íáçå=~ë=~=ÅçãéêÉÜÉåëáîÉ=ãáñÉÇ=ìëÉ=ÇÉîÉäçéãÉåí=ÅçãéêáëáåÖ=ÜáÖÜ=ÇÉåëáíó=êÉëáÇÉåíá~äI=êÉí~áä=ìåáíëI=~=ÜçíÉä=~åÇ=~=íê~åëéçêí=áåíÉêÅÜ~åÖÉX==

• `êÉ~íáçå=çÑ=~=åÉï=çéÉå=ëé~ÅÉ=áåÑêçåí=çÑ=pçìíÜ=_êçãäÉó=pí~íáçåX=~åÇ=

• oÉÇÉîÉäçé=t~áíêçëÉ=Ñçê=~=ä~êÖÉ=ÑççÇëíçêÉ=ïáíÜ=~=åÉï=ä~åÇëÅ~éÉÇ=Ö~íÉï~óK==



2.7 PUBLIC FOCUS WORKSHOP (26 JULY 2005)

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^ë=áÇÉåíáÑáÉÇ=éêÉîáçìëäóI=ÇìêáåÖ=íÜÉ=Ñáêëí=áåíÉê~ÅíáîÉ=ëÉëëáçå=íÜÉ=ÇÉîÉäçéãÉåí=éêáåÅáéäÉë=äáëíÉÇ=ÄÉäçï=ïÉêÉ=ÇáëÅìëëÉÇW=








• ^=ÅÉåíêÉ=ïÜáÅÜ=ÄìáäÇë=çå=áíë=ÜÉêáí~ÖÉK==qÜÉ=é~êíáÅáé~åíë=ïÉêÉ=ÖÉåÉê~ääó=áå=~ÖêÉÉãÉåí=íÜ~í=íÜÉ=~ÄçîÉ=éêáåÅáéäÉë=ëÜçìäÇ=ÄÉÅçãÉ=íÜÉ=Ä~ëáë=çÑ=~=sáëáçå=Ñçê=_êçãäÉóK=líÜÉê=âÉó=áëëìÉë=~åÇ=ÅçããÉåíë=ê~áëÉÇ=ÇìêáåÖ=íÜÉ=ÇáëÅìëëáçå=áåÅäìÇÉÇW=

• fãéçêí~åí=íç=ÅêÉ~íÉ=ÇáëíáåÅíáîÉ=~êÉ~ë=~äçåÖ=íÜÉ=eáÖÜ=píêÉÉíX=

• qÜÉêÉ=áë=äáãáíÉÇ=é~êâáåÖ=Ñ~ÅáäáíáÉë=ÅäçëÉ=íç=íÜÉ=`ÜìêÅÜáää=qÜÉ~íêÉX==

• qÜÉêÉ=áë=~=åÉÉÇ=íç=áåÅêÉ~ëÉ=íÜÉ=äÉáëìêÉ=çÑÑÉê=ïáíÜáå=íÜÉ=íçïå=ÅÉåíêÉ=Ñçê=~ää=~ÖÉ=ÖêçìéëX=

• qÜÉêÉ=áë=~=ä~Åâ=çÑ=éÉêÑçêã~åÅÉ=~åÇ=~ÅíáîáíáÉë=ëé~ÅÉX=

• qÜÉêÉ=áë=~=åÉÉÇ=íç=áãéêçîÉ=íÜÉ=ÚÅìäíìê~ä=ÉñéÉêáÉåÅÉÛ=áå=_êçãäÉóX=

• qÜÉ=ä~êÖÉëí=Çê~ï=íç=íÜÉ=íçïå=ÅÉåíêÉ=áë=êÉí~áäÉêëX=

• qÜÉ=ëÜçééáåÖ=ÉñéÉêáÉåÅÉ=áå=_êçãäÉó=áë=ÄÉÅçãáåÖ=Ää~åÇ=~åÇ=ìåáåíÉêÉëíáåÖX=

• eçï=ÇçÉë=_êçãäÉó=Åçãé~êÉ=íç=iÉïáëÜ~ã=~åÇ=_êáÖÜíçå\X=

• qÜÉêÉ=áë=~=ä~Åâ=çÑ=~ééêçéêá~íÉ=ëáíÉë=Ñçê=ÇÉîÉäçéãÉåíX=

• qÜÉêÉ=áë=~=åÉÉÇ=íç=éêçîáÇÉ=Ñ~ÅáäáíáÉë=Ñçê=óçìåÖ=éÉçéäÉ=Eëâ~íÉ=é~êâFX=

• kÉÉÇ=íç=ÑáåÇ=~=äçÅ~íáçå=Ñçê=~=`çåÅÉêí=e~ää=EäççâÉÇ=Ñçê=~=ëáíÉ=áå=íÜÉ=é~ëíFX=

• `~å=éä~ååáåÖ=Ö~áå=ÄÉ=ìëÉÇ=~ë=~=ãÉ~åë=çÑ=ÑìåÇáåÖ=Åìäíìê~ä=~ÅíáîáíáÉëX=

• m~îáäáçå=ëÜçìäÇ=ÄÉ=êÉí~áåÉÇ=~ë=áí=áë=~å=áãéçêí~åí=Åçããìåáíó=Ñ~ÅáäáíóX=

• píêÉÉí=äÉîÉä=ëÜçéÑêçåíë=~êÉ=çÑ=~=éççê=èì~äáíó=EÄä~åÇFK=qÜÉ=Ñáêëí=Ñäççê=~åÇ=~ÄçîÉ=~êÉ=çÑ=~=ÜáÖÜÉê=èì~äáíóX==

• båÜ~åÅÉ=íÜÉ=ÜáëíçêáÅ=ÉåîáêçåãÉåí=~êçìåÇ=íÜÉ=läÇ=qçïå=e~ää=ã~êâÉí=ëèì~êÉ=~êÉ~X=

• fë=íÜÉêÉ=ÇÉã~åÇLåÉÉÇ=Ñçê=~ÇÇáíáçå~ä=aÉé~êíãÉåí=píçêÉë\X=

• e~êÇ=íç=éìêÅÜ~ëÉ=~åóíÜáåÖ=çíÜÉê=íÜ~å=ÅäçíÜÉë=~åÇ=ëÜçÉë=çå=íÜÉ=eáÖÜ=píêÉÉíX=~åÇ=

• qÜÉ=ÉåîáêçåãÉåí=áå=_êçãäÉó=åÉÉÇë=íç=ÄÉ=çÑ=~=ÜáÖÜÉê=èì~äáíó=íç=~ííê~Åí=~=ÇÉé~êíãÉåí=ëíçêÉK=



OUTCOMES FROM THE SECOND INTERACTIVE SESSION: SPATIAL EXERCISE

^ë=é~êí=çÑ=íÜÉ=ëÉÅçåÇ=áåíÉê~ÅíáîÉ=ëÉëëáçåI=é~êíáÅáé~åíë=ïÉêÉ=~ëâÉÇ=íç=ÅçåëáÇÉê=íÜÉ=ÇáëíêáÄìíáçå=çÑ=ä~åÇ=ìëÉë=íÜêçìÖÜçìí=íÜÉ=íçïå=ÅÉåíêÉK=aìêáåÖ=íÜÉ=ëÉëëáçå=é~êíáÅáé~åíë=Å~êêáÉÇ=çìí=íÜÉ=ëé~íá~ä=ÉñÉêÅáëÉ=íç=ÉñéäçêÉ=íÜÉáê=áåáíá~ä=áÇÉ~ë=çå=íÜÉ=éçëëáÄäÉ=éêáåÅáéäÉë=~åÇ=é~ê~ãÉíÉêë=Ñçê=íÜÉ=ÇÉîÉäçéãÉåí=ëáíÉK===qÜÉ=çìíÅçãÉë=Ñêçã=íÜÉ=ëé~íá~ä=ÉñÉêÅáëÉ=~êÉ=ëìãã~êáëÉÇ=ÄÉäçïK========================================qÜÉ=ëé~íá~ä=çìíÅçãÉ=Ñçê=léíáçå=N=Å~å=ÄÉ=ëìãã~êáëÉÇ=~ë=ÑçääçïëW=

• `êÉ~íáçå=çÑ=~=åÉï=~Åíáîáíó=ÜìÄ=ÑçÅìëÉÇ=~êçìåÇ=kçêíÜ=_êçãäÉó=pí~íáçå=ÅçåëáëíáåÖ=çÑ=~=åÉï=éìÄäáÅ=ëé~ÅÉI=çÑÑáÅÉëI=~=ÑççÇëíçêÉI=Ä~êë=~åÇ=êÉëí~ìê~åíëI=Å~ê=é~êâáåÖ=~åÇ=ãÉÇáìã=ÇÉåëáíó=êÉëáÇÉåíá~äX=

• aÉîÉäçé=~ÇÇáíáçå~ä=Ä~êë=~åÇ=êÉëí~ìê~åíë=~äçåÖ=b~ëí=píêÉÉíX==



• oÉÇÉîÉäçéãÉåí=çÑ=íÜÉ=p~áåëÄìêó=ëáíÉ=íç=áåÅäìÇÉ=ãÉÇáìã=ÇÉåëáíó=êÉëáÇÉåíá~ä=ÇÉîÉäçéãÉåíI=ëã~ää=êÉí~áä=ìåáíëI=Ä~êë=~åÇ=êÉëí~ìê~åíë=~åÇ=áãéêçîÉÇ=äáåâë=íç=íÜÉ=eáÖÜ=píêÉÉíX=

• `êÉ~íáçå=çÑ=~=ÅçãéêÉÜÉåëáîÉ=ãáñ=ìëÉ=~êÉ~=~í=íÜÉ=eáää=`~êâ=m~êâ=~êÉ~=ÅçãéêáëáåÖ=çÑ=~=åÉï=ÑççÇëíçêÉI=ãÉÇáìã=ÇÉåëáíó=êÉëáÇÉåíá~äI=~=åÉï=äáÄê~êó=~åÇ=~ëëçÅá~íÉÇ=Åçããìåáíó=Ñ~ÅáäáíáÉëI=~=åÉï=çéÉå=ëé~ÅÉ=~åÇ=Ä~êë=~åÇ=êÉëí~ìê~åíëX=

• aÉîÉäçéãÉåí=çÑ=äçï=ÇÉåëáíó=êÉëáÇÉåíá~ä=~ÅÅçããçÇ~íáçå=~åÇ=åÉï=çéÉå=ëé~ÅÉ=çå=íÜÉ=ÅçêåÉê=çÑ=qïÉÉÇó=oç~Ç=~åÇ=içåÇçå=oç~ÇX=

• `êÉ~íáçå=çÑ=~=åÉï=íçïå=ëèì~êÉ=çå=íÜÉ=eáÖÜ=píêÉÉíX=• fåíêçÇìÅíáçå=çÑ=Ä~êë=~åÇ=êÉëí~ìê~åíë=çå=íÜÉ=eáÖÜ=píêÉÉíX=

• `êÉ~íáçå=çÑ=~=åÉï=ÇÉé~êíãÉåí=~åÇ=ÑççÇ=ëíçêÉ=çå=íÜÉ=ëáíÉ=çÑ=íÜÉ=m~îáäáçåX=

• `êÉ~íáçå=çÑ=~=åÉï=ÄêáÇÖÉ=Ñêçã=dä~ÇÉë=çîÉê=hÉåíáëÜ=t~ó=íç=íÜÉ=`áîáÅ=`ÉåíêÉ=ëáíÉX=

• `çãéêÉÜÉåëáîÉ=êÉÇÉîÉäçéãÉåí=çÑ=íÜÉ=`áîáÅ=`ÉåíêÉ=ëáíÉ=íç=áåÅäìÇÉ=~=åÉï=äçï=ÇÉåëáíó=êÉëáÇÉåíá~ä=~êÉ~=íç=íÜÉ=ïÉëíI=~=åÉï=äÉáëìêÉ=ÅÉåíêÉ=íç=íÜÉ=åçêíÜ=~åÇ=ÅçåëçäáÇ~íÉÇ=`áîáÅ=lÑÑáÅÉêë=íç=íÜÉX=

• `êÉ~íáçå=çÑ=~=åÉï=çéÉå=ëé~ÅÉ=ëìêêçìåÇÉÇ=Äó=íÜÉ=`ÜìêÅÜáää=qÜÉ~íêÉI=Åçããìåáíó=Ñ~ÅáäáíáÉë=~åÇ=åÉï=êÉí~áä=éêÉãáëÉëX=

• `êÉ~íáçå=çÑ=~=åÉï=ÇÉé~êíãÉåí=ëíçêÉI=äçï=ÇÉåëáíó=êÉëáÇÉåíá~ä=~åÇ=êÉí~áä=ìåáíë=íç=íÜÉ=ïÉëí=çÑ=íÜÉ=eáÖÜ=píêÉÉíX=

• oÉÇÉîÉäçéãÉåí=tÉëíãçêÉä~åÇ=`~ê=m~êâ=~ë=~=ãáñÉÇ=ìëÉ=ÇÉîÉäçéãÉåí=ÅçãéêáëáåÖ=çÑ=Å~ê=é~êâáåÖ=~åÇ=~=ãìäíáéäÉñ=ÅáåÉã~X=~åÇ=

• oÉÇÉîÉäçéãÉåí=çÑ=pçìíÜ=_êçãäÉó=pí~íáçå=~ë=~=ÅçãéêÉÜÉåëáîÉ=ãáñÉÇ=ìëÉ=ÇÉîÉäçéãÉåí=ÅçãéêáëáåÖ=ÜáÖÜ=ÇÉåëáíó=êÉëáÇÉåíá~äI=~=ÜçíÉä=~åÇ=êÉëí~ìê~åíë=~åÇ=Ä~êëX=~åÇ==

• `êÉ~íáçå=çÑ=~=åÉï=íê~åëéçêí=áåíÉêÅÜ~åÖÉ=çééçëáíÉ=pçìíÜ=_êçãäÉó=pí~íáçåK=



3. Summary táíÜáå=ÄçíÜ=íÜÉ=hÉó=pí~âÉÜçäÇÉê=~åÇ=mìÄäáÅ=cçÅìë=pí~âÉÜçäÇÉê=sáëáçåáåÖ=tçêâëÜçéë=íÜÉ=ÑçääçïáåÖ=~êÉ~ë=çÑ=~ÖêÉÉãÉåí=ïÉêÉ=áÇÉåíáÑáÉÇW=

• båÜ~åÅÉÇ=êçäÉ=~åÇ=ÑìåÅíáçåX==

• píêçåÖÉê=òçåÉë=çÑ=~ÅíáîáíóJ=äÉáëìêÉI=ÅìäíìêÉX=

• oÉëéÉÅí=ÜÉêáí~ÖÉ=~åÇ=ÅÜ~ê~ÅíÉêX==

• dÉåÉê~ä=ëìééçêí=Ñçê=ëáÖåáÑáÅ~åí=ÅÜ~åÖÉ=~åÇ=ÇÉîÉäçéãÉåíX==

• pìééçêí=Ñçê=êÉÖÉåÉê~íáçå=çÑ=eáÖÜ=píêÉÉíX=

• pìééçêí=Ñçê=ÅçåëçäáÇ~íáçå=çÑ=`áîáÅ=`ÉåíêÉX=

• bñíÉåëáçå=çÑ=dä~ÇÉëLêÉäçÅ~íáçå=çÑ=äÉáëìêÉX=

• _~ä~åÅÉÇ=ãáñ=çÑ=ìëÉë=áåÅäìÇáåÖ=ëáÖåáÑáÅ~åí=åÉï=ÜçìëáåÖX=

• fãéêçîÉÇ=éìÄäáÅ=íê~åëéçêí=~åÇ=êçäÉ=çÑ=áåíÉêÅÜ~åÖÉëX=~åÇ=

• mêçãçíÉ=ÇáëíáåÅíáîÉ=~êÅÜáíÉÅíìêÉ=~åÇ=í~ää=ÄìáäÇáåÖë=áå=~ééêçéêá~íÉ=äçÅ~íáçåëK==

cçääçïáåÖ=íÜÉ=ïçêâëÜçéë=íÜÉ=íÉÅÜåáÅ~ä=íÉ~ã=Ü~îÉ=áÇÉåíáÑáÉÇ=íÜÉ=ÑçääçïáåÖ=ÇÉîÉäçéãÉåí=çéíáçåë=íÜ~í=êÉèìáêÉ=ÑìêíÜÉê=Éñéäçê~íáçå=~åÇ=íÉÅÜåáÅ~ä=íÉëíáåÖ=~ë=é~êí=çÑ=íÜÉ=åÉñí=ëí~ÖÉë=çÑ=íÜÉ=^^m=éêçÅÉëëI=íÜáë=áåÅäìÇÉëW==

• içÅ~íáçå=çÑ=íÜÉ=iáÄê~êóLäÉáëìêÉ=Ñ~ÅáäáíáÉëX=

• cìíìêÉ=çÑ=`áîáÅ=`ÉåíêÉLäçÅ~íáçå=çÑ=ÅáîáÅ=ÑìåÅíáçåëX=

• pÅ~äÉ=~åÇ=Ñçêã=çÑ=åÉï=ÇÉîÉäçéãÉåíJ=éáÉÅÉãÉ~äLÅçãéêÉÜÉåëáîÉ\X=

• cìíìêÉ=ìëÉ=çÑ=âÉó=ëíê~íÉÖáÅ=ëáíÉëX=

• cìíìêÉ=çÑ=íÜÉ=m~îáäáçåX=

• içÅ~íáçåLëÅ~äÉ=çÑ=åÉï=êÉí~áä=ÇÉîÉäçéãÉåíX=

• bñíÉåíLã~å~ÖÉãÉåí=çÑ=éÉÇÉëíêá~åáëÉÇ=~êÉ~ëX=~åÇ=

• qê~åëéçêí=áåíÉêÅÜ~åÖÉ=Ñ~ÅáäáíáÉëK==



4. Next Steps ^í=íÜÉ=ÅäçëÉ=çÑ=íÜÉ=tçêâëÜçéëI=íÜÉ=íÉÅÜåáÅ~ä=íÉ~ã=áÇÉåíáÑáÉÇ=íÜÉ=åÉñí=ëíÉéë=Ñçê=ÑìêíÜÉê=~ééê~áë~ä=~åÇ=íÜÉ=ëìÄëÉèìÉåí=ëí~ÖÉë=çÑ=íÜÉ=ëíìÇóK=qÜÉëÉ=áåÅäìÇÉW=


• `çåëáÇÉê~íáçå=~åÇ=ÑìêíÜÉê=íÉëíáåÖ=çÑ=ÉãÉêÖáåÖ=ÇÉîÉäçéãÉåí=çéíáçåë=~åÇ=íÉÅÜåáÅ~ä=áëëìÉëX=~åÇ=

• cìêíÜÉê=ãÉÉíáåÖë=ïáíÜ=ëí~âÉÜçäÇÉêë=~åÇ=íÉÅÜåáÅ~ä=~ÇîáëçêëK==m~êíáÅáé~åíë=ïáää=Ü~îÉ=~å=çééçêíìåáíó=íç=ÅçåíêáÄìíÉ=íç=íÜÉ=ÑìêíÜÉê=ÇÉîÉäçéãÉåí=çÑ=íÜÉ=^^mK=qïç=ÑìêíÜÉê=ëí~ÖÉë=çÑ=Åçåëìäí~íáçå=ïáää=í~âÉ=éä~ÅÉ=ïáíÜ=âÉó=ëí~âÉÜçäÇÉêë=ÇìêáåÖ=íÜÉ=éêÉé~ê~íáçå=çÑ=íÜÉ=^^mW===

• pí~ÖÉ=PW=aÉîÉäçéáåÖ=íÜÉ=léíáçåë=EpÉéíÉãÄÉê=OMMRF=ïáää=áåÅäìÇÉ=~=íÜáêÇ=ëÉêáÉë=çÑ=ëí~âÉÜçäÇÉê=ïçêâëÜçéë=~ë=é~êí=çÑ=íÜÉ=~ééê~áë~ä=çÑ=ÇÉîÉäçéãÉåí=çéíáçåëX=~åÇ=

• pí~ÖÉ=QW=mêÉÑÉêêÉÇ=léíáçåë=Eg~åì~êó=OMMSF=ïáää=áåÅäìÇÉ=~=ÑìêíÜÉê=ëÉêáÉë=çÑ=ïçêâëÜçéë=~åÇ=~=éìÄäáÅ=ÉñÜáÄáíáçå=éêáçê=íç=éêÉé~ê~íáçå=çÑ=íÜÉ=Çê~Ñí=^^mK=

=qÜÉ=éìÄäáÅ=~åÇ=âÉó=ëí~âÉÜçäÇÉêë=ïáää=Ü~îÉ=~å=çééçêíìåáíó=íç=êÉîáÉï=~åÇ=ÅçããÉåí=çå=íÜÉ=éêçéçë~äë=áå=ãçêÉ=ÇÉí~áä=ÇìêáåÖ=íÜÉ=ÑìêíÜÉê=ëí~ÖÉë=çÑ=Åçåëìäí~íáçåK==qÜÉ=pí~ÖÉ=P=ïçêâëÜçéë=ïáää=áåÑçêã=~åÇ=ÅçåíêáÄìíÉ=íç=íÜÉ=Ñçêãìä~íáçå=çÑ=íÜÉ=éêÉÑÉêêÉÇ=ÇÉîÉäçéãÉåí=çéíáçåë=Ñçê=_êçãäÉó=qçïå=`ÉåíêÉK=qÜÉëÉ=ÇÉîÉäçéãÉåí=çéíáçåë=ïáää=ÄÉ=éêÉëÉåíÉÇ=íç=íÜÉ=`çìåÅáäÛë=aÉîÉäçéãÉåí=`çåíêçä=`çããáííÉÉ=áå=lÅíçÄÉê=OMMR=~åÇ=ÑçääçïáåÖ=~åó=êÉÑáåÉãÉåíI=íÜÉ=éêÉÑÉêêÉÇ=çéíáçå=ïáää=ÄÉ=ëìÄàÉÅí=íç=~=éÉêáçÇ=çÑ=éìÄäáÅ=Åçåëìäí~íáçå=Epí~ÖÉ=QF=áå=É~êäó=OMMSK====



appendix A1

VISIONING KEY STAKEHOLDER WORKSHOP INVITEES


fåÇáîáÇì~ä= lêÖ~åáë~íáçå=

j~íí=_Éää= _êçãäÉó=mçäáÅÉ=pí~íáçå==

gáää=tÉÄÄ= _~ëëÉííë=eçìëÉ=

qÜÉ=bñÉÅìíáîÉ=^Çãáåáëíê~íçê= içåÇçå=^ãÄìä~åÅÉ=pÉêîáÅÉë=

pìéÉêáåíÉåÇÉåí=`Ü~êäÉë=dêáÖÖë= _êçãäÉó=mçäáÅÉ=pí~íáçå==

jê=`Ü~êäÉë=eçêíçå== pçìíÜÉêå=dç=~ÜÉ~Ç=eçìëÉ j~íí=_~ää== pçìíÜÉêå=dç=~ÜÉ~Ç=eçìëÉ=


_êá~å=háêÄó= kÉíïçêâ=o~áä=Ó=qÜÉ=mçÇáìã=

jê=o=j~ëëÉíí= iáÅÉåëÉÇ=q~ñá=aêáîÉêë=^ëëçÅá~íáçå=iíÇ

jê=a~îÉ=pãáíÜ= i``=`óÅäáåÖ=

qÜÉ=pÉÅêÉí~êó= cêÉáÖÜí=qê~åëéçêí=^ëëçÅá~íáçå=iíÇ=

jê=s=píçéë= içåÇçå=qê~åëéçêí=rëÉêë=`çããáííÉÉ=

_êá~å=`ççâÉ= içåÇçå=qê~åëéçêí=rëÉêë=`çããáííÉÉ=

`ÜáÉÑ=fåëéÉÅíçê=jáâÉ=pã~ääã~å= jbq=mçäáÅÉ=Ópb=qê~ÑÑáÅ=aáîáëáçå==

jë=h~êÉå=dççÅÜ=içåÇçå=cáêÉ=C=`áîáä=aÉÑÉåÅÉ=^ìíÜçêáíó=EpçìíÜÉêå=`çãã~åÇF=

jê=d~êó=tççÇ= jÉíêçÄìë=

jê=aáÅâ=e~ääÉ= içåÇçå=_ìëÉë=

^Äáçä~=fãçìâÜìÉÇÉ= içåÇçå=_ìëÉë=

jê=_Éå=mäçïÇÉå=qê~åëéçêí= Ñçê= içåÇçå= Ó= i~åÇ= rëÉ=mä~ååáåÖ=

jë=`~íÜÉêáåÉ=mÜáääéçííë= qÜÉ=_êáíáëÜ=jçíçêÅóÅäáëíë=cÉÇÉê~íáçå=

jê=m~ìä=eçééÉå= båîáêçåãÉåí=^ÖÉåÅó=

jê=^=_óêåÉ= båÖäáëÜ=eÉêáí~ÖÉ=

jê=`=jáíÅÜáëçå= `çåÑÉÇÉê~íáçå=çÑ=_êáíáëÜ=fåÇìëíêó=

a~îáÇ=cçêíó= _ìëáåÉëëJcçÅìë=

m~ìä=`ê~óÑçêÇ= _~åâ=çÑ=^ãÉêáÅ~=

píÉîÉ=`Ü~åÇäÉê= dä~ÇÉë=pÜçééáåÖ=`ÉåíêÉ=

hÉêêó=gçÜåëçå= `ÜìêÅÜáää=fåëìê~åÅÉ=

jê=o=g=eçéâáåë= `ÜìêÅÜáää=Ñáå~åÅá~ä=pÉêîáÅÉë=iíÇ=

jêë=gìäáÉ=jáääÉê= oçó~ä=_~åâ=çÑ=pÅçíä~åÇ=




`~êãÉä=lDkáÉää= j~êâë=~åÇ=péÉåÅÉê=mäÅ=

jê=j~êâ=lÛ`çååçê= j~êâë=~åÇ=péÉåÅÉê=mäÅ=


jê=`Üêáë=däçîÉê= `ÜìêÅÜáää=qÜÉ~íêÉ=

jê=d=v=v~íÉë= _êçãäÉó=qê~ÇÉë=råáçå=`çìåÅáä=

jê=j=_~ä~~ãê= içåÇçå=qçìêáëí=_ç~êÇ=

jê=a~îáÇ=j~áå= pçìíÜ=içåÇçå=_ìëáåÉëë=

jáÅÜ~Éä=tÜÉÉäÉê= _êçãäÉó=^Çìäí=bÇìÅ~íáçå=`ÉåíêÉ=

`Ü~êäçííÉ=_ÉÇÇçÉ= _êçãäÉó=^Çìäí=bÇìÅ~íáçå=`ÉåíêÉ=

aÉêáÅâ=mçïÉää= i_=_êçãäÉó=oÉëáÇåíëÛ=cÉÇÉê~íáçå=

jáëë=p~ê~Ü=_ê~ÇäÉó= ^îêç=mäÅ=

jê=^Çêá~å=eçää~åÇë=_~âÉê=qáääó=_al=píçó=e~óï~êÇ=

jë=`=pÉñíçå= _ep=iíÇ=

jêë=d=_áëÜçé= `~ãÄÉêÑçêÇ=i~ï=mäÅ=

jê=o=aáãáåáÉìñ= `ä~êâë=pÜçÉë=iíÇ=

jê=mÉíÉê=_êçïå= `çëãçë=`ç~ÅÜ=qçìêë=iíÇ=

jê=q=_=táääá~ãëçå= `çëãçë~áê=mäÅ=

jêë=o=_~êåÉë= `óëíáÅ=cáÄêçëáë=qêìëí=

jê=káÖÉä=mçìäíçå= aÉÄÉåÜ~ãë=

jê=a~îáÇ=qÜçêéÉ= cáêëí=qáíäÉ=pÉêîáÅÉë=iíÇ=

jê=d=m~é~ÖÉçêÖáçì= dÉçiçÖáëíáÅë=iíÇ=

jê=gçÜå=q~óäçê= e~ëïÉää=`çåëìäíáåÖ=båÖáåÉÉêë=

jë=jÉêÅÉÇÉë=v~ëêìÇÇáå= gìÇÖÉ=~åÇ=mêáÉëíäó=

jê=g~ëçå=c~Üó= iáÄÉê~í~=

jê=qáã=açìÖä~ë= jÅaçå~äÇÛë=oÉëí~ìê~åíë=iíÇ=

jê=hÉîáå=_áÄÄ= jÅaçå~äÇÛë=oÉëí~ìê~åíë=iíÇ=

jê=^åÇêÉï=wáÉäáåëâá= jp_=fåíÉêå~íáçå~ä=mäÅ=

jê=^åÇêÉï=`~êíÉê= kÉñí=oÉí~áä=mäÅ=

jë=g~Åâó=iÉçå~êÇ= m~îáäáçå=iÉáëìêÉ=`ÉåíêÉ=

jêë=`=pÉÇÖïáÅâ= mÉääáåÖë=

jê=t=pìääáî~å= mêáã~êâ=

jê=o=j=^ìîê~ó= mêçëéÉÅíë=pÉêîáÅÉë=iíÇ=

jê=qçåó=háåÖ= oçó~ä=j~áä=

jê=oçÖÉê=_êçãäÉó= oìëëÉää=~åÇ=_êçãäÉó=iíÇ=

jë=_~êåÉë= p~áåëÄìêó=pìéÉêã~êâÉíë=iíÇ=

jê=e=m=açïåÉê= pÉäÉÅíáçå=pÉêîáÅÉë=iíÇ=

jê=gçÜå=_~êâÉê= pÉí=~åÇ=píêáâÉ=iíÇ=

jêë=pÜ~êçå=tççÇë= qÜ~Åâê~ó=táääá~ãë=

jê=m=j=iìåå= qÜ~ãÉë=`êÉÇáí=iíÇ=

jêë=káÅçäÉ=q~óäçê= qÜÉ=tÉëíãÉêá~=kìêëáåÖ=`ÉåíêÉ=

jê=píÉîÉ=qÜçãëçå= qÜçãëçå=fåíÉêãÉÇá~=mäÅ=

jê=f~å=dáäãçìê= s~å=^ãÉóÇÉ=~åÇ=t~ääáë=iíÇ=

jê=m=ráåÖë= tççäïçêíÜë=

jÉäîóå=a~îáë= táääá~ã=^åÇêÉïë=C=`ç=

jê=^åÇêÉï=eáíÅÜ= qÜÉ=dä~ÇÉë=jÉêÅÜ~åíë=^ëëçÅá~íáçå=

jêë=`~êçäóå=iÉïáë= _êçãäÉó=mq`=



jê=_~êÉåÇ=sÉääÉã~å= k`j^=

jë=`~êçäáåÉ=q~íÅÜÉää= k`j^=

jê=^êÅÜáÉ=^îÉêó= =

jê=píÉîÉ=mêáÅÉ= _êçãäÉó=jóíáãÉ=

jê=hÉáíÜ=bñÑçêÇ= ^ÑÑáåáíó=



appendix A2

VISIONING PUBLIC FOCUS STAKEHOLDER WORKSHOP INVITEES



jê=hÉå=pãáíÜ= mÉÇÉëíêá~åë=^ëëçÅá~íáçå=

jê=cêÉÇ=táäâáåëçå= _êçãäÉó=C=_áÖÖáå=eáää=^êÉ~=

jê=o=i~ïëçå= qÜÉ=_êçãäÉó=oç~Ç=^Åíáçå=dêçìé=


jê=q=_êçïå= mÉçéäÉ=táíÜ=aáë~ÄáäáíáÉë=

jê=d=pÜáéäÉó= oÉëáÇÉåíëÛ=^ëëçÅá~íáçå=

jë=o=pÜáéäÉó= oÉëáÇÉåíëÛ=^ëëçÅá~íáçå=


jê=f~å=_êçÇáÉ= _êçãäÉó=pçìíÜ=^Åíáçå=dêçìé=






gìÇó=cìääÉê= `çããìåáíó=iáåâ=


jê=a=g=tççÇ= dêçìé=C=`áîáÅ=pçÅáÉíó=

páãçå=^åëíêÉó= _êçãäÉó=kçêíÜ=oÉëáÇÉåíë=^ëëçÅá~íáçå=

gÉÑÑ=oçóÅÉ= =

jáÅÜ~Éä=píÉîÉåë= _êçãäÉó=`Üêáëíá~å=`ÉåíêÉ=

_êìÅÉ=^åÇÉêëçå= =

jê=o~ó=t~íëçå= cêáÉåÇë=çÑ=íÜÉ=b~êíÜ=

aÉêÉâ=mçïÉää= i__oc====



STAGE 3: ‘Options for Bromley’


SUMMARY REPORT

October 2005


table of contents

=1 INTRODUCTION


3 SUMMARY

4 NEXT STEPS

APPENDICES

=APPENDIX 1: OPTIONS KEY STAKEHOLDER WORKSHOP INVITEES

APPENDIX 2: OPTIONS KEY STAKEHOLDER WORKSHOP ATTENDEES

APPENDIX 3: OPTIONS PUBLIC FOCUS STAKEHOLDER WORKSHOP INVITEES

APPENDIX 4: OPTIONS PUBLIC FOCUS STAKEHOLDER WORKSHOP ATTENDEES

=



Acknowledgement

qÜÉ=içåÇçå=_çêçìÖÜ=çÑ=_êçãäÉó=~åÇ=íÜÉ=Åçåëìäí~åí=íÉ~ã=~êÉ=Öê~íÉÑìä=Ñçê=íÜÉ=íáãÉ=~åÇ=áåéìí=çÑ=~ää=íÉÅÜåáÅ~ä=~ÇîáëçêëI=ëí~âÉÜçäÇÉêëI=äçÅ~ä=çêÖ~åáë~íáçåë=~åÇ=äçÅ~ä=áåíÉêÉëí=Öêçìéë=ïÜç=~ííÉåÇÉÇ=íÜÉ=ÚqÜÉ=léíáçåë=tçêâëÜçéëÛ=ÜÉäÇ=çå=íÜÉ=NVíÜ=pÉéíÉãÄÉê=OMMRK=qÜÉ=ëí~âÉÜçäÇÉê=ïçêâëÜçéë=Ñçêã=é~êí=çÑ=íÜÉ=Åçää~Äçê~íáîÉ=ÇÉëáÖå=éêçÅÉëë=~åÇ=ïÉêÉ=ÇÉëáÖåÉÇ=íç=ÉåëìêÉ=íÜ~í=íÜÉ=îáÉïë=çÑ=ëí~âÉÜçäÇÉêë=~åÇ=äçÅ~ä=áåíÉêÉëí=Öêçìéë=áåÑçêã=íÜÉ=^Åíáçå=^êÉ~=mä~å=éêçÅÉëëK=táíÜçìí=íÜÉ=ÇÉÇáÅ~íÉÇ=ÉÑÑçêíë=çÑ=~ää=é~êíáÅáé~åíëI=íÜÉ=ïçêâëÜçéë=ïçìäÇ=åçí=Ü~îÉ=ÄÉÉå=éçëëáÄäÉK=



1. introduction

1.1 BACKGROUND

qÜÉ=içåÇçå=_çêçìÖÜ=çÑ=_êçãäÉó=áë=ÅìêêÉåíäó=éêÉé~êáåÖ=~=DåÉïJëíóäÉD=^êÉ~=^Åíáçå=mä~å=E^^mF=Ñçê=_êçãäÉó=qçïå=`ÉåíêÉ=íç=Éëí~ÄäáëÜ=íÜÉ=éçäáÅó=Ñê~ãÉïçêâ=~åÇ=ÖìáÇÉ=ÑìíìêÉ=ÇÉîÉäçéãÉåí=áå=íÜÉ=ÅÉåíêÉK==b~êäó=áå=OMMR=íÜÉ=`çìåÅáä=ÅçããáëëáçåÉÇ=~=ãìäíáJÇáëÅáéäáå~êó=íÉ~ã=äÉÇ=Äó=êÉÖÉåÉê~íáçå=~åÇ=ã~ëíÉêéä~ååáåÖ=Åçåëìäí~åíë=ba^tI=íç=Å~êêó=çìí=êÉëÉ~êÅÜ=~åÇ=íç=ïçêâ=ïáíÜ=íÜÉ=`çìåÅáä=áå=íÜÉ=éêÉé~ê~íáçå=çÑ=íÜÉ=^^mK=tÜÉå=ÅçãéäÉíÉÇI=íÜÉ=^^m=ïáää=Ñçêã=é~êí=çÑ=íÜÉ=`çìåÅáäÛë=içÅ~ä=aÉîÉäçéãÉåí=cê~ãÉïçêâ=EiacFI=ïÜáÅÜ=ïáää=ÉîÉåíì~ääó=êÉéä~ÅÉ=íÜÉ=~ÇçéíÉÇ=råáí~êó=aÉîÉäçéãÉåí=mä~åK==qÜÉ=_êçãäÉó=qçïå=`ÉåíêÉ=^^m=ïáää=~äëç=~Åí=~ë=~å=áåîÉëíãÉåí=Ñê~ãÉïçêâ=~åÇ=ÖìáÇÉ=íç=ÇÉîÉäçéÉêëI=íÜÉ=äçÅ~ä=éä~ååáåÖ=~ìíÜçêáíó=~åÇ=çíÜÉê=éìÄäáÅ=~ÖÉåÅáÉëK==qÜÉ=Åçåëìäí~åí=íÉ~ã=áë=ïçêâáåÖ=ÅäçëÉäó=ïáíÜ=íÜÉ=`çìåÅáä=~åÇ=ëí~âÉÜçäÇÉêë=áå=íÜÉ=éêçÇìÅíáçå=çÑ=~=îáëáçå=Ñçê=íÜÉ=íçïå=ÅÉåíêÉI=íÜÉ=Éëí~ÄäáëÜãÉåí=çÑ=ÇÉîÉäçéãÉåí=~åÇ=ÇÉëáÖå=éêáåÅáéäÉë=~åÇ=íÜÉ=éêÉé~ê~íáçå=çÑ=ÇÉí~áäÉÇ=éä~ååáåÖ=éçäáÅáÉë=Ñçê=íÜÉ=íçïå=ÅÉåíêÉK==qÜÉ=`çìåÅáä=áë=êÉèìáêÉÇ=íç=ìåÇÉêí~âÉ=Åçåëìäí~íáçå=~í=É~ÅÜ=ëí~ÖÉ=çÑ=éêÉé~ê~íáçå=çÑ=íÜÉ=^^mK=qÜÉ=éêçÖê~ããÉ=çÑ=Åçåëìäí~íáçå=áåÅäìÇÉë=~=åìãÄÉê=çÑ=ÑçÅìëÉÇ=ÉîÉåíë=~í=É~ÅÜ=ëí~ÖÉ=çÑ=íÜÉ=^^m=éêçÅÉëëK=qÜÉ=ëí~ÖÉë=ÅçãéêáëÉW==• pí~ÖÉ=NW=fëëìÉë=~åÇ=lééçêíìåáíáÉë=oÉîáÉï=Ej~ó=OMMRFX=

• pí~ÖÉ=OW=`êÉ~íáåÖ=~=sáëáçå=Ñçê=_êçãäÉó=Egìäó=OMMRFX=

• pí~ÖÉ=PW=aÉîÉäçéáåÖ=íÜÉ=léíáçåë=EpÉéíÉãÄÉê=OMMRFX=~åÇ=

• pí~ÖÉ=QW=mêÉÑÉêêÉÇ=léíáçåë=Eg~åì~êóLcÉÄêì~êó=OMMSFK==

=qÜáë=Åçää~Äçê~íáîÉ=~ééêç~ÅÜ=íç=éä~å=ã~âáåÖ=áë=Ñìääó=ëìééçêíÉÇ=~åÇ=ÉåÅçìê~ÖÉÇ=Äó=dçîÉêåãÉåí=~åÇ=~áãë=íç=ãáíáÖ~íÉ=éçíÉåíá~ä=ÅçåÑäáÅí=íÜêçìÖÜ=ÇáëÅìëëáçåK==fí=ëÉÉâë=íç=Éëí~ÄäáëÜ=ÚÄìóJáåÛ=Äó=íÜÉ=î~êáçìë=ëí~âÉÜçäÇÉêëK==^í=íÜÉ=ë~ãÉ=íáãÉI=íÜÉ=éêçÅÉëë=áë=ÇêáîÉå=Äó=íÜÉ=çÄàÉÅíáîÉ=çÑ=ìåÇÉêëí~åÇáåÖ=íÜÉ=åÉÉÇë=çÑ=íÜÉ=Åçããìåáíó=áå=íÜÉ=fëëìÉë=~åÇ=lééçêíìåáíáÉë=ëí~ÖÉ=~åÇ=~ÇÇêÉëëáåÖ=íÜÉëÉ=áå=íÜÉ=ÇÉîÉäçéãÉåí=çÑ=~=îáëáçå=~åÇ=éêÉé~ê~íáçå=çÑ=íÜÉ=ÇÉîÉäçéãÉåí=çéíáçåë=Ñçê=íÜÉ=íçïå=ÅÉåíêÉK==qÜÉ=çìíéìíë=çÑ=íÜÉ=Ñáêëí=íÜêÉÉ=ëí~ÖÉë=çÑ=Åçåëìäí~íáçå=ïáää=áåÑçêã=íÜÉ=éêÉé~ê~íáçå=çÑ=íÜÉ=ÇÉîÉäçéãÉåí=çéíáçåë=~åÇ=êÉÑáåÉãÉåí=çÑ=íÜÉ=éêÉÑÉêêÉÇ=ÇÉîÉäçéãÉåí=çéíáçåëK====qÜáë=êÉéçêíI=éêçîáÇÉë=~å=~ÅÅçìåí=çÑ=íÜÉ=éêçÅÉÉÇáåÖë=~åÇ=ëìãã~êáëÉë=íÜÉ=çìíéìíë=çÑ=íÜÉ=pí~ÖÉ=P=ïçêâëÜçéëK===



1.2 CONSULTATION PROCESS

qÜÉ=Åçää~Äçê~íáîÉ=ïçêâëÜçé=éêçÅÉëë=~ääçïë=éçíÉåíá~ä=Åçåëíê~áåíëI=çééçêíìåáíáÉë=~åÇ=~ëéáê~íáçåë=íç=ÄÉ=íÜçêçìÖÜäó=Éñ~ãáåÉÇ=Äó=áåíÉêÉëíÉÇ=é~êíáÉëK==fí=ÉåÅçìê~ÖÉë=áååçî~íáîÉ=ëçäìíáçåë=íç=áëëìÉë=ëìÅÜ=~ë=íê~åëéçêíI=ãáñ=çÑ=ìëÉë=~åÇ=ÇÉëáÖåK==_ó=~ÇçéíáåÖ=~=Åçää~Äçê~íáîÉ=~ééêç~ÅÜI=íÜÉ=ÉãéÜ~ëáë=áë=çå=ÇÉîÉäçéáåÖ=ÅêÉ~íáîÉ=ëçäìíáçåë=ïÜáÅÜ=êÉëéçåÇ=íç=çééçêíìåáíáÉë=~åÇ=áëëìÉë=ëéÉÅáÑáÅ=íç=íÜÉ=íçïå=ÅÉåíêÉK==pí~ÖÉ=NW=fëëìÉë=~åÇ=lééçêíìåáíáÉë=oÉîáÉï=^ë=é~êí=çÑ=íÜÉ=Ñáêëí=ëí~ÖÉ=çÑ=ëí~âÉÜçäÇÉê=Åçåëìäí~íáçåI=íÜÉ=Åçåëìäí~åí=íÉ~ã=Ñ~Åáäáí~íÉÇ=~=ëÉêáÉë=çÑ=ëí~âÉÜçäÇÉê=ïçêâëÜçéë=çå=ÄÉÜ~äÑ=çÑ=íÜÉ=`çìåÅáä=áå=j~ó=OMMRI=íç=ÉñéäçêÉ=íÜÉ=áëëìÉë=~åÇ=çééçêíìåáíáÉë=Ñ~ÅáåÖ=_êçãäÉó=qçïå=`ÉåíêÉK=qÜáë=áåÅäìÇÉÇ=íÜÉ=ÑçääçïáåÖ=ÉîÉåíëW=



=qÜÉ=çÄàÉÅíáîÉ=çÑ=íÜÉ=tçêâëÜçéë=ï~ë=íç=Çê~ï=çå=íÜÉ=îáÉïëI=~ëéáê~íáçåë=~åÇ=ÉñéÉêáÉåÅÉ=çÑ=~=ïáÇÉ=ê~åÖÉ=çÑ=áåíÉêÉëíÉÇ=é~êíáÉë=~åÇ=íç=Éëí~ÄäáëÜ=íÜÉ=âÉó=áëëìÉë=~åÇ=çééçêíìåáíáÉë=íç=ÄÉ=~ÇÇêÉëëÉÇ=áå=éêÉé~ê~íáçå=çÑ=íÜÉ=^^mK=====qÜÉ=áëëìÉë=~åÇ=çééçêíìåáíáÉë=ïçêâëÜçéë=êÉéêÉëÉåíÉÇ=íÜÉ=Ñáêëí=ã~àçê=ëíÉé=áå=éêÉé~êáåÖ=íÜÉ=^^mK==qÜÉ=ÅçããÉåíë=êÉÅÉáîÉÇ=ïÉêÉ=~å~äóëÉÇ=~åÇ=êÉéçêíÉÇ=Ä~Åâ=~í=íÜÉ=sáëáçåáåÖ=tçêâëÜçéë=ÜÉäÇ=áå=ÇìêáåÖ=gìäó=OMMRK=qÜÉëÉ=çìíéìíë=~êÉ=ëìãã~êáëÉÇ=áå=íÜÉ=pí~ÖÉ=N=pí~âÉÜçäÇÉê=tçêâëÜçé=pìãã~êó=oÉéçêíK==pí~ÖÉ=OW=`êÉ~íáåÖ=~=sáëáçå=Ñçê=_êçãäÉó=^ë=é~êí=çÑ=íÜÉ=ëÉÅçåÇ=ëí~ÖÉ=çÑ=ëí~âÉÜçäÇÉê=Åçåëìäí~íáçåI=íÜÉ=Åçåëìäí~åí=íÉ~ã=Ñ~Åáäáí~íÉÇ=~=ÑìêíÜÉê=ëÉêáÉë=çÑ=ëí~âÉÜçäÇÉê=ïçêâëÜçéë=çå=ÄÉÜ~äÑ=çÑ=íÜÉ=`çìåÅáä=ÇìêáåÖ=gìäó=OMMRI=íç=ÇáëÅìëë=~åÇ=ÄÉÖáå=íç=ÇÉîÉäçé=~=îáëáçå=Ñçê=_êçãäÉó=qçïå=`ÉåíêÉK=qÜáë=áåÅäìÇÉÇ=íÜÉ=ÑçääçïáåÖ=ÉîÉåíëW=

NK hÉó=pí~âÉÜçäÇÉêë=tçêâëÜçé=J=NUíÜ=gìäó=OMMRX=~åÇ==

OK mìÄäáÅ=cçÅìë=pí~âÉÜçäÇÉêë=tçêâëÜçé=J=OSíÜ=gìäó=OMMR=

=qÜÉ=çÄàÉÅíáîÉ=çÑ=íÜÉ=îáëáçåáåÖ=ïçêâëÜçéë=ï~ë=íç=Çê~ï=çå=íÜÉ=îáÉïëI=~ëéáê~íáçåë=~åÇ=ÉñéÉêáÉåÅÉ=çÑ=~=ïáÇÉ=ê~åÖÉ=çÑ=áåíÉêÉëíÉÇ=é~êíáÉëI=íç=Éëí~ÄäáëÜ=~=îáëáçå=~åÇ=íç=áåîÉëíáÖ~íÉ=íÜÉ=ëé~íá~ä=éêáåÅáéäÉë=~åÇ=é~ê~ãÉíÉêë=çÑ=íÜÉ=ÉãÉêÖáåÖ=ÇÉîÉäçéãÉåí=çéíáçåë=Ñçê=_êçãäÉó=íÜ~í=ëÜçìäÇ=ÄÉ=~ÇÇêÉëëÉÇ=ïáíÜáå=íÜÉ=^^mK=qÜÉëÉ=çìíéìíë=~êÉ=ëìãã~êáëÉÇ=áå=íÜÉ=pí~ÖÉ=O=pí~âÉÜçäÇÉê=tçêâëÜçé=pìãã~êó=oÉéçêíK==pí~ÖÉ=PW=aÉîÉäçéáåÖ=íÜÉ=léíáçåë=qÜÉ=íÜáêÇ=ëí~ÖÉ=çÑ=ëí~âÉÜçäÇÉê=Åçåëìäí~íáçå=ÅçåëáëíÉÇ=çÑ=íÜÉ=Åçåëìäí~åí=íÉ~ã=Ñ~Åáäáí~íáåÖ=~=Ñáå~ä=ëÉêáÉë=çÑ=ëí~âÉÜçäÇÉê=ïçêâëÜçéë=áå=pÉéíÉãÄÉê=OMMRI=íç=ÇáëÅìëë=~åÇ=Éî~äì~íÉ=íÜÉ=ÉãÉêÖáåÖ=ÇÉîÉäçéãÉåí=çéíáçåë=Ñçê=_êçãäÉó=qçïå=`ÉåíêÉK=qÜáë=áåÅäìÇÉÇ=íÜÉ=ÑçääçïáåÖ=ÉîÉåíëW=

NK hÉó=pí~âÉÜçäÇÉêë=tçêâëÜçé=J=NVíÜ=pÉéíÉãÄÉê=OMMR=EÇ~óíáãÉFX=~åÇ==

OK mìÄäáÅ=cçÅìë=pí~âÉÜçäÇÉêë=tçêâëÜçé=J=NVíÜ=pÉéíÉãÄÉê=OMMR=EÉîÉåáåÖFK=

=qÜÉ=çÄàÉÅíáîÉ=çÑ=íÜÉ=çéíáçåë=ïçêâëÜçéë=ï~ë=~Ö~áå=íç=Çê~ï=çå=íÜÉ=îáÉïëI=~ëéáê~íáçåë=~åÇ=ÉñéÉêáÉåÅÉ=çÑ=~=ïáÇÉ=ê~åÖÉ=çÑ=áåíÉêÉëíÉÇ=é~êíáÉëI=íç=Éëí~ÄäáëÜ=~åÇ=Éî~äì~íÉÇ=íÜÉ=ÉãÉêÖáåÖ=ÇÉîÉäçéãÉåí=ëÅÉå~êáçë=~åÇ=ëé~íá~ä=ëíê~íÉÖó=Ñçê=_êçãäÉó=qçïå=`ÉåíêÉK=qÜÉ=çìíéìíë=çÑ=íÜÉëÉ=ïçêâëÜçéë=~êÉ=ëìãã~êáëÉÇ=áå=íÜáë=êÉéçêíK=



qÜÉ=ïçêâëÜçéë=ÜÉäÇ=ÇìêáåÖ=pí~ÖÉë=NJP=ïÉêÉ=~ííÉåÇÉÇ=Äó=~=ä~êÖÉ=åìãÄÉê=çÑ=ëí~âÉÜçäÇÉêëI=áåÅäìÇáåÖ=êÉéêÉëÉåí~íáîÉë=Ñêçã=íÜÉ=ÑçääçïáåÖ=çêÖ~åáë~íáçåëW=• içÅ~ä=Åçããìåáíó=ÖêçìéëW=i_=_êçãäÉó=oÉëáÇÉåíëÛ=cÉÇÉê~íáçåI=eÉ~êí=çÑ=

_êçãäÉóI=_êçãäÉó=pçìíÜ=^Åíáçå=dêçìéI=_êçãäÉó=kçêíÜ=oÉëáÇÉåíë=^ëëçÅá~íáçåI=`çããìåáíó=iáåâëI=^ÖÉ=`çåÅÉêåI=_êçãäÉó=`Üêáëíá~å=`ÉåíêÉI=cêáÉåÇë=çÑ=íÜÉ=b~êíÜ=~åÇ=_êçãäÉó=qçïå=`ÜìêÅÜX=

• bãÉêÖÉåÅó=ëÉêîáÅÉëW=içåÇçå=cáêÉ=_êáÖ~ÇÉI=içåÇçå=^ãÄìä~åÅÉ=pÉêîáÅÉë=~åÇ=jÉíêçéçäáí~å=mçäáÅÉ=pÉêîáÅÉX=

• pí~íìíçêó=lêÖ~åáë~íáçåëW=båÖäáëÜ=eÉêáí~ÖÉI=qê~åëéçêí=Ñçê=içåÇçå=~åÇ=iáÅÉåëÉÇ=q~ñá=aêáîÉêë=^ëëçÅá~íáçåX=

• içÅ~ä=çêÖ~åáë~íáçåë=~åÇ=ÄìëáåÉëëÉëW=`óëíáÅ=cáÄêçëáë=qêìëíI=_êçãäÉó=^Çìäí=bÇìÅ~íáçå=`çääÉÖÉI=`ÜìêÅÜáää=qÜÉ~íêÉI=_êçãäÉó=jóíáãÉI=_êçãäÉó=m`qI=pçìíÜ=içåÇçå=_ìëáåÉëëI=_êçãäÉó=`çìêí=eçíÉäI=tççäïçêíÜëI=mêçëéÉÅíëI=`~éáí~ä=pÜçééáåÖ=`ÉåíêÉë=~åÇ=mÉääáåÖëX=~åÇ==

• líÜÉê=áåíÉêÉëíÉÇ=é~êíáÉëW=ä~åÇçïåÉêëI=éêçéÉêíó=ÇÉîÉäçéÉêë=~åÇ=~ÖÉåíëK==

^=Ñìää=äáëí=çÑ=íÜÉ=Öêçìéë=~åÇ=çêÖ~åáë~íáçåë=áåîáíÉÇ=~åÇ=~ííÉåÇÉÉë=íç=íÜÉ=ïçêâëÜçéë=áë=áåÅäìÇÉÇ=ïáíÜáå=íÜÉ=^ééÉåÇáÅÉë=íÜ~í=Å~å=ÄÉ=ÑçìåÇ=~í=íÜÉ=êÉ~ê=çÑ=É~ÅÜ=çÑ=íÜÉ=pìãã~êó=oÉéçêíëK===



2. Stage 3 Workshops 2.1 OVERVIEW

qÜÉ=áåíÉåíáçå=çÑ=íÜÉ=pí~ÖÉ=P=pí~âÉÜçäÇÉêëÛ=tçêâëÜçéë=ï~ë=íç=éêçîáÇÉ=ÑÉÉÇÄ~Åâ=Ñêçã=éêÉîáçìë=ïçêâëÜçéë=~åÇ=íç=ÇáëÅìëë=~åÇ=Éî~äì~íÉ=íÜÉ=ÉãÉêÖáåÖ=çéíáçåë=Ñçê=_êçãäÉó=qçïå=`ÉåíêÉK= 2.2 INTRODUCTORY COMMENTS

_çíÜ=íÜÉ=hÉó=pí~âÉÜçäÇÉê=~åÇ=mìÄäáÅ=cçÅìë=tçêâëÜçéë=ÅçããÉåÅÉÇ=ïáíÜ=áåíêçÇìÅíçêó=ÅçããÉåíë=Ñêçã=cê~åâ=tÜáíáåÖI=qçïå=`ÉåíêÉ=mêçàÉÅí=aáêÉÅíçê=~í=íÜÉ=içåÇçå=_çêçìÖÜ=çÑ=_êçãäÉóK=eÉ=ïÉäÅçãÉÇ=é~êíáÅáé~åíëI=Éñéä~áåÉÇ=íÜÉ=ÖÉåÉê~ä=éêçÅÉÉÇáåÖë=Ñçê=íÜÉ=ÉîÉåíë=~åÇ=áåíêçÇìÅÉÇ=íÜÉ=Åçåëìäí~åí=íÉ~ãK=qÜáë=ï~ë=ÑçääçïÉÇ=Äó=~=éêÉëÉåí~íáçå=Ñêçã=íÜÉ=Åçåëìäí~åí=íÉ~ã=çå=íÜÉ=ÉãÉêÖáåÖ=çéíáçåë=~åÇ=~=Öêçìé=ÇáëÅìëëáçå=ëÉëëáçåK=qÜÉ=hÉó=pí~âÉÜçäÇÉêë=tçêâëÜçé=ï~ë=ÜÉäÇ=~í=íÜÉ=_êçãäÉó=`áîáÅ=`ÉåíêÉ=~åÇ=íÜÉ=mìÄäáÅ=cçÅìë=pí~âÉÜçäÇÉêë=tçêâëÜçé=ï~ë=ÜÉäÇ=~í=`çããìåáíó=eçìëÉI=pçìíÜ=píêÉÉíI=_êçãäÉóK=

2.3 CONSULTANT PRESENTATION




• mêçàÉÅí=éêçÖê~ããÉX==

• cÉÉÇÄ~Åâ=Ñêçã=íÜÉ=pí~ÖÉ=O=sáëáçåáåÖ=tçêâëÜçéëX=

• fÇÉåíáÑáÅ~íáçå=çÑ=âÉó=áëëìÉë=íç=ÄÉ=ÅçåëáÇÉêÉÇ=áå=ÇÉîÉäçéáåÖ=íÜÉ=çéíáçåë=Ñçê=_êçãäÉó=qçïå=`ÉåíêÉ=áåÅäìÇáåÖ=ÇÉîÉäçéãÉåí=ãáñI=âÉó=çééçêíìåáíó=~êÉ~ëI=Ñçêã=çÑ=ÇÉîÉäçéãÉåí=~åÇ=~ÅÅÉëë=~åÇ=ãçîÉãÉåí=áëëìÉëX=

• fÇÉåíáÑáÅ~íáçå=çÑ=íÜÉ=íÜêÉÉ=ÇÉîÉäçéãÉåí=ëÅÉå~êáçë=Ñçê=_êçãäÉó=ïÜáÅÜ=ÉãÉêÖÉÇ=Ñêçã=íÜÉ=éêÉîáçìë=ïçêâëÜçéëX=

• fÇÉåíáÑáÅ~íáçå=çÑ=íÜÉ=çéíáçåë=~åÇ=áëëìÉë=~êáëáåÖ=Ñêçã=É~ÅÜ=çÑ=íÜÉ=íÜêÉÉ=ëÅÉå~êáçëX==

• `çåëáÇÉê~íáçå=çÑ=íÜÉ=ÇÉîÉäçéãÉåí=éçíÉåíá~ä=ÅêÉ~íÉÇ=~ë=~=êÉëìäí=çÑ=íÜÉ=ëÅÉå~êáçëX=~åÇ=

• `ä~êáÑáÅ~íáçå=çÑ=íÜÉ=åÉñí=ëí~ÖÉë=áå=íÜÉ=^^m=éêçÅÉëëK==aìêáåÖ=~åÇ=ÑçääçïáåÖ=íÜÉ=Åçåëìäí~åí=éêÉëÉåí~íáçå=é~êíáÅáé~åíë=ïÉêÉ=ÉåÅçìê~ÖÉÇ=íç=ÉåÖ~ÖÉ=áå=Öêçìé=ÇáëÅìëëáçåë=~åÇ=íç=ëÜ~êÉ=íÜÉáê=îáÉïë=ïáíÜ=çíÜÉê=é~êíáÅáé~åíëK=qÜÉ=ÑçääçïáåÖ=ëÉÅíáçåë=ëìãã~êáëÉ=íÜÉ=çìíéìíë=çÑ=íÜÉëÉ=ÇáëÅìëëáçåëK==2.4 INTERACTIVE SESSION: EVALUATION OF THE OPTIONS

táíÜáå=íÜÉ=áåíÉê~ÅíáîÉ=ëÉëëáçå=íÜÉ=é~êíáÅáé~åíë=ëéäáí=áåíç=ëã~ää=Öêçìéë=íç=ÅçåëáÇÉê=íÜÉ=çîÉê~ää=ëé~íá~ä=ëíê~íÉÖó=~åÇ=ÇÉîÉäçéãÉåí=ëÅÉå~êáçë=Ñçê=íÜÉ=íçïå=ÅÉåíêÉK===DEVELOPMENT SENARIOS

qÜêÉÉ=ÇÉîÉäçéãÉåí=ëÅÉå~êáçë=ïÉêÉ=Éî~äì~íÉÇK=qÜÉëÉ=ëÉåÄ~êáçë=~êÉ=çìíäáåÉÇ=ÄÉäçï=~åÇ=ïÉêÉ=ÇÉêáîÉÇ=Ñêçã=ÑÉÉÇÄ~Åâ=êÉÅÉáîÉÇ=ÇìêáåÖ=íÜÉ=éêÉîáçìë=ëí~ÖÉë=çÑ=íÜÉ=Åçåëìäí~íáçå=éêçÅÉëë=~åÇ=íÜÉ=ÑìêíÜÉê=íÉÅÜåáÅ~ä=íÉëíáåÖ=ìåÇÉêí~âÉå=Äó=íÜÉ=éêçàÉÅí=íÉ~ãK==



SCENARIO 1:

SPATIAL STRATEGY DEVELOPMENT SENARIO

==============================qÜÉ=âÉó=ÉäÉãÉåíë=çÑ=pÅÉå~êáç=N=ÅçãéêáëÉÇW=

• `êÉ~íáçå=çÑ=~=åÉï=äÉáëìêÉ=~åÇ=ÉåíÉêí~áåãÉåí=ÑçÅìë=áå=kçêíÜ=sáää~ÖÉX=

• píêÉåÖíÜÉåáåÖ=kçêíÜ=sáää~ÖÉ=~ë=~=ëíêçåÖ=ÇÉëíáå~íáçåX=

• bñíÉåÇÉÇ=êÉí~áä=çÑÑÉê=çå=íÜÉ=m~îáäáçå=ëáíÉ=ïáíÜ=íÜÉ=êÉäçÅ~íáçå=çÑ=íÜÉ=äÉáëìêÉ=ÅÉåíêÉX=

• kÉï=ãáñÉÇ=ìëÉ=ÇÉîÉäçéãÉåí=ïáíÜ=áãéêçîÉãÉåíë=íç=éìÄäáÅ=íê~åëéçêí=Ñ~ÅáäáíáÉë=~í=ÄçíÜ=ëí~íáçåëX=

• `êÉ~íáçå=çÑ=~=åÉï=ÅáîáÅ=ëèì~êÉ=~í=`ÜìêÅÜáää=qÜÉ~íêÉX=~åÇ=

• dÉåÉê~ä=áãéêçîÉãÉåíë=íç=éìÄäáÅ=êÉ~äã=~åÇ=çéÉå=ëé~ÅÉëK=



=SCENARIO 2:


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• oÉÖÉåÉê~íáçå=çÑ=íÜÉ=ïÉëíÉêå=~åÇ=ëçìíÜÉêå=é~êí=çÑ=íÜÉ=eáÖÜ=píêÉÉíX=

• `êÉ~íáçå=çÑ=åÉï=êÉí~áä=ÑçÅìë=çå=íÜÉ=ïÉëíÉêå=ëáÇÉ=çÑ=íÜÉ=eáÖÜ=píêÉÉíX=

• kÉï=~åÇ=ÉñíÉåÇÉÇ=íçïå=ëèì~êÉ=íç=áãéêçîÉ=íÜÉ=ëÉííáåÖ=çÑ=qÜÉ~íêÉL=iáÄê~êóX=

• kÉï=ãáñÉÇ=ìëÉ=ÇÉîÉäçéãÉåí=ïáíÜ=áãéêçîÉãÉåíë=íç=éìÄäáÅ=íê~åëéçêí=Ñ~ÅáäáíáÉë=~í=ÄçíÜ=ëí~íáçåëX=

• `êÉ~íáçå=çÑ=åÉï=éìÄäáÅ=ëé~ÅÉ=çìíëáÇÉ=_êçãäÉó=pçìíÜ=pí~íáçåX=~åÇ=

• `çåëçäáÇ~íáçå=çÑ=ÉñáëíáåÖ=`áîáÅ=`ÉåíêÉ=ëáíÉK==



=SCENARIO 3:


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• kÉÉÇ=íç=äççâ=ÑìêíÜÉê=~í=çééçêíìåáíáÉë=Ñçê=åÉï=çÑÑáÅÉ=éêçîáëáçåX=

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2.6 PUBLIC FOCUS STAKEHOLDER WORKSHOP (19TH SEPTEMBER 2005) (EVENING)

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• oÉäçÅ~íáçå=çÑ=íÜÉ=äÉáëìêÉ=ÅÉåíêÉX=

• içÅ~íáçå=çÑ=íÜÉ=ÅáåÉã~X=~åÇ=

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• açÉë=åçí=~ÇÇêÉëë=íÜÉ=âÉó=áëëìÉë=Ñ~ÅáåÖ=_êçãäÉó=áå=é~êíáÅìä~ê=~ÅÅçããçÇ~íáçå=çÑ=åÉï=êÉí~áä=Ñäççêëé~ÅÉ=~åÇ=êÉÖÉåÉê~íáçå=çÑ=íÜÉ=ïÉëíÉêå=ëáÇÉ=çÑ=íÜÉ=eáÖÜ=píêÉÉíX=

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• kÉÉÇ=íç=ÉåëìêÉ=íÜ~í=çåÅÉ=íÜÉ=ÅáåÉã~=áë=êÉäçÅ~íÉÇ=íç=íÜÉ=ëçìíÜ=çÑ=íÜÉ=íçïå=íÜÉêÉ=áë=~ÇÉèì~íÉ=ìëÉë=íç=~ííê~Åí=~Åíáîáíó=íç=íÜÉ=åçêíÜ=~åÇ=ãáåáãáëÉ=íÜÉ=áãé~Åí=çÑ=íÜÉ=äçëë=çÑ=íÜÉ=ÅáåÉã~X=



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• kÉÉÇ=íç=éêçíÉÅí=`çääÉÖÉ=dêÉÉå=~åÇ=ÉåÜ~åÅÉ=íÜÉ=ëÉííáåÖ=çÑ=íÜÉ=äáëíÉÇ=ÄìáäÇáåÖX=

• qÜÉ=ÉñáëíáåÖ=lÇÉå=ÄìáäÇáåÖ=ÅçìäÇ=ÄÉ=~=ëìáí~ÄäÉ=äçÅ~íáçå=Ñçê=~=åÉï=äáÄê~êó=çê=Åçããìåáíó=ìëÉë=áÑ=íÜÉ=ÉñáëíáåÖ=äáÄê~êó=áë=íç=ÄÉ=êÉäçÅ~íÉÇX==

• qÜÉ=ÅçåîÉêëáçå=çÑ=íÜÉ=m~ä~ÅÉ=íç=~=ÜçíÉä=ïçìäÇ=ÄÉ=~=ÖççÇ=ìëÉ=çÑ=íÜÉ=ÄìáäÇáåÖI=~åÇ=ïçìäÇ=~äëç=êÉëéÉÅí=íÜÉ=ÜáëíçêáÅ=ëÉííáåÖX=

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• ^ÖêÉÉãÉåí=çå=íÜÉ=ÉñíÉåëáçå=çÑ=éÉÇëÉíêá~åáë~íáçåI=ÜçïÉîÉêI=åÉÉÇ=íç=ÅçåëáÇÉê=Å~ê=é~êâáåÖ=Ñ~ÅáäáíáÉë=áå=íÜÉ=ÉîÉåáåÖK=

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• fãéçêí~åÅÉ=çÑ=êÉáåÑçêÅáåÖ=áÇÉåíáíó=çÑ=kçêíÜ=sáää~ÖÉK=båÅçìê~ÖÉãÉåí=çÑ=áåÇÉéÉåÇÉåí=ëÜçéëI=Ñêçåí~ÖÉ=áãéêçîÉãÉåíë=~åÇ=Åçåíêçä=çÑ=~ÇîÉêíáëáåÖX=

• bîÉå=ïáíÜ=ã~àçê=êÉåçî~íáçåë=ëÅÉéíáÅáëã=Éñáëíë=~ë=íç=ïÜÉíÜÉê=_êçãäÉó=kçêíÜ=pí~íáçå=ïáää=~ííê~Åí=ã~åó=ìëÉêëX=

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• eÉ~äíÜ=ÅÉåíêÉëI=áåÅäìÇáåÖ=ãÉåí~ä=ÜÉ~äíÜ=Ñ~ÅáäáíáÉëI=ëÜçìäÇ=ÄÉ=ÇÉîÉäçéÉÇ=ïáíÜáå=íÜÉ=íçïå=ÅÉåíêÉI=éçëëáÄäó=äáåâÉÇ=ïáíÜ=äÉáëìêÉ=~åÇ=çíÜÉê=Åçããìåáíó=ìëÉëX=

• _~ëÉãÉåíë=çÑ=ÉñáëíáåÖ=ÄìáäÇáåÖë=~êÉ=ìåÇÉê=ìíáäáëÉÇ=~åÇ=ïçìäÇ=éêçîáÇÉ=éçëëáÄäÉ=äçÅ~íáçåë=Ñçê=Å~ê=é~êâáåÖ=Ñ~ÅáäáíáÉëX=

• fãéçêí~åÅÉ=çÑ=éêçíÉÅíáåÖ=ÜÉêáí~ÖÉ=~åÇ=êÉí~áåáåÖ=âÉó=Ñêçåí~ÖÉë=~äçåÖ=íÜÉ=eáÖÜ=píêÉÉíX=

• båëìêÉ=íÜÉ=éêçíÉÅíáçå=çÑ=íÜÉ=îáÉïë=çÑ=íÜÉ=hÉëíçå=oáÇÖÉX=

• kÉÉÇ=íç=áãéêçîÉ=íÜÉ=éÉÇÉëíêá~å=ÅêçëëáåÖ=Ñêçã=_êçãäÉó=kçêíÜ=pí~íáçå=~åÇ=çíÜÉê=ÅêçëëáåÖë=~äçåÖ=hÉåíáëÜ=t~óX==

• kÉÉÇ=íç=ÉåÅçìê~ÖÉ=êÉëáÇÉåíë=íç=ìëÉ=ëìëí~áå~ÄäÉ=Ñçêãë=çÑ=íê~åëéçêíX==

• pìééçêí=Ñçê=áãéêçîÉÇ=éÉÇÉëíêá~å=ÉåîáêçåãÉåí=Äìí=åÉÉÇ=íç=ÉåëìêÉ=~Åíáîáíó=íÜêçìÖÜçìí=íÜÉ=Ç~ó=~åÇ=ÉîÉåáåÖ=çå=ë~ÑÉíóLëÉÅìêáíó=ÖêçìåÇëK=mçíÉåíá~ä=íç=çéÉå=ìé=~êÉ~ë=Ñçê=é~êâáåÖ=áå=íÜÉ=ÉîÉåáåÖëX=~åÇ=

• `çåÅÉêå=~Äçìí=áãé~Åí=çÑ=êÉëáÇÉåíá~ä=êÉÇÉîÉäçéãÉåí=çå=íÜÉ=`áîáÅ=`ÉåíêÉ=ëáíÉ=~åÇ=åÉÉÇ=íç=éêçíÉÅí=ÅÜ~ê~ÅíÉê=çÑ=ëçìíÜÉêå=é~êí=çÑ=íÜÉ=ëáíÉK=



3. Summary qÜÉ=íÜêÉÉ=ëÅÉå~êáçë=êÉÑäÉÅí=ÇáÑÑÉêÉåí=~ééêç~ÅÜÉë=áå=êÉä~íáçå=íç=íÜÉ=ÑçääçïáåÖW=

• bñíÉåí=çÑ=ÅÜ~åÖÉ=~åÇ=ÇÉîÉäçéãÉåíX=

• jáñI=Ñçêã=~åÇ=äçÅ~íáçå=çÑ=ä~åÇìëÉëX=

• `Ü~åÖÉë=íç=íÜÉ=ÜáÖÜï~ó=åÉíïçêâL=íê~åëéçêí=Ñ~ÅáäáíáÉëX=~åÇ==

• `Ü~åÖÉë=íç=íÜÉ=éìÄäáÅ=êÉ~äã=áåÅäìÇáåÖ=íÜÉ=ÅêÉ~íáçå=çÑ=åÉï=éìÄäáÅ=ëé~ÅÉëL=äáåâ~ÖÉëK==

tçêâëÜçé=é~êíáÅáé~åíë=ïÉêÉ=ìå~åáãçìë=áå=íÜÉ=îáÉï=íÜ~í=pÅÉå~êáç=N=ïçìäÇ=åçí=~ÅÜáÉîÉ=íÜÉ=çÄàÉÅíáîÉë=Ñçê=êÉîáí~äáë~íáçå=çÑ=íÜÉ=eáÖÜ=píêÉÉí=~åÇ=íÜÉ=ÅêÉ~íáçå=çÑ=ëíêçåÖÉê=äáåâë=ÄÉíïÉÉå=_êçãäÉó=kçêíÜ=~åÇ=pçìíÜ=~åÇ=ÅçìäÇ=åçí=~ÅÅçããçÇ~íÉ=åÉÅÉëë~êó=ÅÜ~åÖÉ=~åÇ=ÇÉîÉäçéãÉåí=áå=íÜÉ=qçïå=`ÉåíêÉ=ïáíÜáå=íÜÉ=éä~å=éÉêáçÇK=pÅÉå~êáçë=O=~åÇ=P=ïÉêÉ=éêÉÑÉêêÉÇ=~ë=íÜÉ=Ä~ëáë=Ñçê=~ÅÜáÉîáåÖ=íÜÉ=îáëáçå=Ñçê=íÜÉ=qçïå=`ÉåíêÉI=áå=é~êíáÅìä~ê=íÜÉ=êÉÖÉåÉê~íáçå=çÑ=íÜÉ=eáÖÜ=píêÉÉí=~åÇ=äáåâ~ÖÉë=ÄÉíïÉÉå=_êçãäÉó=kçêíÜ=~åÇ=pçìíÜK=bäÉãÉåíë=çÑ=ÄçíÜ=léíáçåë=O=~åÇ=P=ïÉêÉ=Ñ~îçìêÉÇ=Äó=é~êíáÅáé~åíë=áåÅäìÇáåÖW=

• båÜ~åÅÉãÉåí=çÑ=íÜÉ=ÇáëíáåÅíáîÉåÉëë=çÑ=kçêíÜ=sáää~ÖÉX=

• `êÉ~íáçå=çÑ=~=åÉï=ÑçÅìë=çÑ=~Åíáîáíó=~í=_êçãäÉó=pçìíÜ=íç=Ä~ä~åÅÉ=íÜÉ=êÉí~áä=ÅçêÉ=~åÇ=kçêíÜ=sáää~ÖÉX=

• mçíÉåíá~ä=Ñçê=ê~íáçå~äáò~íáçå=çÑ=íÜÉ=`áîáÅ=`ÉåíêÉ=ëáíÉX=

• aÉîÉäçéãÉåí=íç=íÜÉ=ïÉëí=çÑ=íÜÉ=eáÖÜ=píêÉÉíX=

• `çåÅÉåíê~íáçå=çÑ=ÜáÖÜ=ÇÉåëáíó=ãáñÉÇ=ìëÉ=ÇÉîÉäçéãÉåí=~í=_êçãäÉó=pçìíÜ=~åÇ=kçêíÜ=pí~íáçåëX=

• `êÉ~íáçå=çÑ=~=åÉï=~åÇ=ÉñíÉåÇÉÇ=íçïå=ëèì~êÉ=~í=íÜÉ=ÑçêÉÅçìêí=çÑ=íÜÉ=qÜÉ~íêÉLiáÄê~êóX=

• fãéêçîÉÇ=éÉÇÉëíêá~å=~ÅÅÉëë=~åÇ=äáåâ~ÖÉë=íÜêçìÖÜçìí=íÜÉ=qçïå=`ÉåíêÉX=

• oÉÇÉîÉäçéãÉåí=~í=íÜÉ=eáää=`~ê=é~êâ=íç=ÉåÜ~åÅÉ=íÜÉ=ëÉííáåÖ=~åÇ=Ñ~ÅáäáíáÉë=áå=kçêíÜ=sáää~ÖÉX=

• fãéêçîÉÇ=~ÅÅÉëë=~åÇ=~ÅíáîÉ=Ñêçåí~ÖÉë=çåíç=é~êâë=~åÇ=Ö~êÇÉåëX=~åÇ=

• bñíÉåëáçå=çÑ=qÜÉ=dä~ÇÉë=~åÇ=êÉäçÅ~íáçå=çÑ=íÜÉ=äÉáëìêÉ=ÅÉåíêÉK=

qÜÉ=çìíéìíë=Ñêçã=íÜÉ=pí~ÖÉ=P=ïçêâëÜçéë=Ü~îÉ=ÄÉÉå=Ñìääó=~ëëÉëëÉÇ=~åÇ=Ü~îÉ=ÄÉÉå=êÉÑäÉÅíÉÇ=áå=íÜÉ=éêÉé~ê~íáçå=çÑ=íÜÉ=Çê~Ñí=pé~íá~ä=píê~íÉÖó=~åÇ=ÉãÉêÖáåÖ=mêÉÑÉêêÉÇ=léíáçåë=~åÇ=éêçéçë~äë=áå=pí~ÖÉ=Q=çÑ=íÜÉ=^^m=éêçÅÉëëK==



4. Next Steps ^í=íÜÉ=ÅäçëÉ=çÑ=íÜÉ=tçêâëÜçéëI=íÜÉ=íÉÅÜåáÅ~ä=íÉ~ã=áÇÉåíáÑáÉÇ=íÜÉ=åÉñí=ëíÉéë=Ñçê=ÑìêíÜÉê=~ééê~áë~ä=~åÇ=íÜÉ=ëìÄëÉèìÉåí=ëí~ÖÉë=çÑ=íÜÉ=ëíìÇóK=qÜÉëÉ=áåÅäìÇÉW=


• `çåëáÇÉê~íáçå=~åÇ=ÑìêíÜÉê=íÉëíáåÖ=çÑ=ÉãÉêÖáåÖ=ÇÉîÉäçéãÉåí=çéíáçåë=~åÇ=íÉÅÜåáÅ~ä=áëëìÉëX==

• cìêíÜÉê=ãÉÉíáåÖë=ïáíÜ=ëí~âÉÜçäÇÉêë=~åÇ=íÉÅÜåáÅ~ä=~ÇîáëçêëX=~åÇ=

• mêÉé~ê~íáçå=çÑ=íÜÉ=Çê~Ñí=^^mK==m~êíáÅáé~åíë=ïáää=Ü~îÉ=~å=çééçêíìåáíó=íç=ÅçåíêáÄìíÉ=íç=íÜÉ=ÑìêíÜÉê=ÇÉîÉäçéãÉåí=çÑ=íÜÉ=^^mK=låÉ=ÑìêíÜÉê=ëí~ÖÉ=çÑ=Åçåëìäí~íáçå=ïáää=í~âÉ=éä~ÅÉ=ïáíÜ=âÉó=ëí~âÉÜçäÇÉêë=~åÇ=íÜÉ=éìÄäáÅ=ÇìêáåÖ=íÜÉ=éêÉé~ê~íáçå=çÑ=íÜÉ=^^mK=qÜáë=ÅçãéêáëÉëW=

• pí~ÖÉ=QW=mêÉÑÉêêÉÇ=léíáçåë=Eg~åì~êó=OMMSF=ëÉêáÉë=çÑ=éìÄäáÅ=ÉñÜáÄáíáçåë=~åÇ=Åçåëìäí~íáçå=éêáçê=íç=éêÉé~ê~íáçå=çÑ=íÜÉ=Çê~Ñí=^^mK=

=qÜÉ=éìÄäáÅ=~åÇ=âÉó=ëí~âÉÜçäÇÉêë=ïáää=Ü~îÉ=~å=çééçêíìåáíó=íç=êÉîáÉï=~åÇ=ÅçããÉåí=çå=íÜÉ=éêçéçë~äë=áå=ãçêÉ=ÇÉí~áä=ÇìêáåÖ=íÜáë=Ñçêã~ä=ëí~ÖÉ=çÑ=Åçåëìäí~íáçåK==qÜÉ=pí~ÖÉ=P=ïçêâëÜçéë=Ü~îÉ=áåÑçêãÉÇ=~åÇ=ÅçåíêáÄìíÉ=íç=íÜÉ=Ñçêãìä~íáçå=çÑ=íÜÉ=éêÉÑÉêêÉÇ=ÇÉîÉäçéãÉåí=çéíáçåë=Ñçê=_êçãäÉó=qçïå=`ÉåíêÉK=qÜÉëÉ=ÇÉîÉäçéãÉåí=çéíáçåë=ïÉêÉ=éêÉëÉåíÉÇ=íç=íÜÉ=`çìåÅáäÛë=aÉîÉäçéãÉåí=`çåíêçä=`çããáííÉÉ=áå=lÅíçÄÉê=OMMR=~åÇ=ïÉêÉ=~ééêçîÉÇ=~åÇ=ÑçääçïáåÖ=~åó=êÉÑáåÉãÉåíI=íÜÉ=éêÉÑÉêêÉÇ=çéíáçå=ïáää=ÄÉ=ëìÄàÉÅí=íç=íÜÉ=~ÄçîÉ=ãÉåíáçåÉÇ=éÉêáçÇ=çÑ=éìÄäáÅ=Åçåëìäí~íáçå=Epí~ÖÉ=QF=áå=É~êäó=OMMSK==^ää=ÅçããÉåíë=êÉÅÉáîÉÇ=ïáää=ÄÉ=í~âÉå=Ñìääó=áåíç=~ÅÅçìåí=áå=éêÉé~êáåÖ=íÜÉ=Çê~Ñí=^^m=ïÜáÅÜ=ïáää=ÄÉ=ëìÄãáííÉÇ=íç=íÜÉ=lÑÑáÅÉ=çÑ=íÜÉ=aÉéìíó=mêáãÉ=jáåáëíÉê=ElamjF=áå=gìäó=OMMSK=qÜÉêÉ=ïáää=ÄÉ=~=ÑìêíÜÉê=éÉêáçÇ=çÑ=éìÄäáÅ=Åçåëìäí~íáçå=~í=íÜáë=ëí~ÖÉ=ïÜÉå=ÅçããÉåíë=ïáää=ÄÉ=áåîáíÉÇ=çå=íÜÉ=Çê~Ñí=^^mK==qÜÉ=Çê~Ñí=^^m=ïáää=ÄÉ=ãçÇáÑáÉÇ=~ë=~ééêçéêá~íÉI=ÄÉÑçêÉ=ÄÉáåÖ=ëìÄàÉÅí=íç=~=mìÄäáÅ=bñ~ãáå~íáçå=ÄÉÑçêÉ=~å=áåÇÉéÉåÇÉåí=áåëéÉÅíçê=íÜ~í=ïáää=ÄÉ=~ééçáåíÉÇ=Äó=íÜÉ=lamj=áå=É~êäó=OMMTK==^Ççéíáçå=çÑ=íÜÉ=^^m=áë=~åíáÅáé~íÉÇ=áå=ãáÇ=OMMTK==



appendix 1

OPTIONS KEY STAKEHOLDER WORKSHOP INVITEES

qÜÉ=ÑçääçïáåÖ=áåÇáîáÇì~äë=~åÇ=çêÖ~åáë~íáçåë=ïÉêÉ=áåîáíÉÇ=íç=~ííÉåÇ=íÜÉ=hÉó=pí~âÉÜçäÇÉê=tçêâëÜçéW==


j~íí=_Éää= _êçãäÉó=mçäáÅÉ=pí~íáçå==

gáää=tÉÄÄ= _~ëëÉííë=eçìëÉ=

qÜÉ=bñÉÅìíáîÉ=^Çãáåáëíê~íçê= içåÇçå=^ãÄìä~åÅÉ=pÉêîáÅÉë=

pìéÉêáåíÉåÇÉåí=`Ü~êäÉë=dêáÖÖë= _êçãäÉó=mçäáÅÉ=pí~íáçå==

`Ü~êäÉë=eçêíçå== pçìíÜÉêå=dç=~ÜÉ~Ç=eçìëÉ j~íí=_~ää== pçìíÜÉêå=dç=~ÜÉ~Ç=eçìëÉ=


_êá~å=háêÄó= kÉíïçêâ=o~áä=Ó=qÜÉ=mçÇáìã=

jê=o=j~ëëÉíí= iáÅÉåëÉÇ=q~ñá=aêáîÉêë=^ëëçÅá~íáçå=iíÇ

a~îÉ=pãáíÜ= i``=`óÅäáåÖ=

qÜÉ=pÉÅêÉí~êó= cêÉáÖÜí=qê~åëéçêí=^ëëçÅá~íáçå=iíÇ=

jê=s=píçéë= içåÇçå=qê~åëéçêí=rëÉêë=`çããáííÉÉ=

_êá~å=`ççâÉ= içåÇçå=qê~åëéçêí=rëÉêë=`çããáííÉÉ=

`ÜáÉÑ=fåëéÉÅíçê=jáâÉ=pã~ääã~å= jbq=mçäáÅÉ=Ópb=qê~ÑÑáÅ=aáîáëáçå==

h~êÉå=dççÅÜ=içåÇçå=cáêÉ=C=`áîáä=aÉÑÉåÅÉ=^ìíÜçêáíó=EpçìíÜÉêå=`çãã~åÇF=

d~êó=tççÇ= jÉíêçÄìë=

aáÅâ=e~ääÉ= içåÇçå=_ìëÉë=

^Äáçä~=fãçìâÜìÉÇÉ= içåÇçå=_ìëÉë=

_Éå=mäçïÇÉå=qê~åëéçêí= Ñçê= içåÇçå= Ó i~åÇ= rëÉ=mä~ååáåÖ=

`~íÜÉêáåÉ=mÜáääéçííë= qÜÉ=_êáíáëÜ=jçíçêÅóÅäáëíë=cÉÇÉê~íáçå=

m~ìä=eçééÉå= båîáêçåãÉåí=^ÖÉåÅó=

jê=^=_óêåÉ= båÖäáëÜ=eÉêáí~ÖÉ=

jê=`=jáíÅÜáëçå= `çåÑÉÇÉê~íáçå=çÑ=_êáíáëÜ=fåÇìëíêó=

a~îáÇ=cçêíó= _ìëáåÉëëJcçÅìë=

m~ìä=`ê~óÑçêÇ= _~åâ=çÑ=^ãÉêáÅ~=

píÉîÉ=`Ü~åÇäÉê= dä~ÇÉë=pÜçééáåÖ=`ÉåíêÉ=

hÉêêó=gçÜåëçå= `ÜìêÅÜáää=fåëìê~åÅÉ=

jê=o=g=eçéâáåë= `ÜìêÅÜáää=Ñáå~åÅá~ä=pÉêîáÅÉë=iíÇ=

gìäáÉ=jáääÉê= oçó~ä=_~åâ=çÑ=pÅçíä~åÇ=

`~êãÉä=lDkáÉää= j~êâë=~åÇ=péÉåÅÉê=mäÅ=

j~êâ=lÛ`çååçê= j~êâë=~åÇ=péÉåÅÉê=mäÅ=


`Üêáë=däçîÉê= `ÜìêÅÜáää=qÜÉ~íêÉ=




jê=d=v=v~íÉë= _êçãäÉó=qê~ÇÉë=råáçå=`çìåÅáä=

jê=j=_~ä~~ãê= içåÇçå=qçìêáëí=_ç~êÇ=

a~îáÇ=j~áå= pçìíÜ=içåÇçå=_ìëáåÉëë=

tÜÉÉäÉê= _êçãäÉó=^Çìäí=bÇìÅ~íáçå=`ÉåíêÉ=

`Ü~êäçííÉ=_ÉÇÇçÉ= _êçãäÉó=^Çìäí=bÇìÅ~íáçå=`ÉåíêÉ=

aÉêáÅâ=mçïÉää= i_=_êçãäÉó=oÉëáÇåíëÛ=cÉÇÉê~íáçå=

p~ê~Ü=_ê~ÇäÉó= ^îêç=mäÅ=

^Çêá~å=eçää~åÇë=_~âÉê=qáääó=_al=píçó=e~óï~êÇ=

jë=`=pÉñíçå= _ep=iíÇ=

jêë=d=_áëÜçé= `~ãÄÉêÑçêÇ=i~ï=mäÅ=

jê=o=aáãáåáÉìñ= `ä~êâë=pÜçÉë=iíÇ=

mÉíÉê=_êçïå= `çëãçë=`ç~ÅÜ=qçìêë=iíÇ=

jê=q=_=táääá~ãëçå= `çëãçë~áê=mäÅ=

jêë=o=_~êåÉë= `óëíáÅ=cáÄêçëáë=qêìëí=

káÖÉä=mçìäíçå= aÉÄÉåÜ~ãë=

a~îáÇ=qÜçêéÉ= cáêëí=qáíäÉ=pÉêîáÅÉë=iíÇ=

jê=d=m~é~ÖÉçêÖáçì= dÉçiçÖáëíáÅë=iíÇ=

gçÜå=q~óäçê= e~ëïÉää=`çåëìäíáåÖ=båÖáåÉÉêë=

jÉêÅÉÇÉë=v~ëêìÇÇáå= gìÇÖÉ=~åÇ=mêáÉëíäó=

g~ëçå=c~Üó= iáÄÉê~í~=

qáã=açìÖä~ë= jÅaçå~äÇÛë=oÉëí~ìê~åíë=iíÇ=

hÉîáå=_áÄÄ= jÅaçå~äÇÛë=oÉëí~ìê~åíë=iíÇ=

^åÇêÉï=wáÉäáåëâá= jp_=fåíÉêå~íáçå~ä=mäÅ=

^åÇêÉï=`~êíÉê= kÉñí=oÉí~áä=mäÅ=

g~Åâó=iÉçå~êÇ= m~îáäáçå=iÉáëìêÉ=`ÉåíêÉ=

jêë=`=pÉÇÖïáÅâ= mÉääáåÖë=

jê=t=pìääáî~å= mêáã~êâ=

jê=o=j=^ìîê~ó= mêçëéÉÅíë=pÉêîáÅÉë=iíÇ=

qçåó=háåÖ= oçó~ä=j~áä=

oçÖÉê=_êçãäÉó= oìëëÉää=~åÇ=_êçãäÉó=iíÇ=

jë=_~êåÉë= p~áåëÄìêó=pìéÉêã~êâÉíë=iíÇ=

jê=e=m=açïåÉê= pÉäÉÅíáçå=pÉêîáÅÉë=iíÇ=

gçÜå=_~êâÉê= pÉí=~åÇ=píêáâÉ=iíÇ=

pÜ~êçå=tççÇë= qÜ~Åâê~ó=táääá~ãë=

jê=m=j=iìåå= qÜ~ãÉë=`êÉÇáí=iíÇ=

káÅçäÉ=q~óäçê= qÜÉ=tÉëíãÉêá~=kìêëáåÖ=`ÉåíêÉ=

píÉîÉ=qÜçãëçå= qÜçãëçå=fåíÉêãÉÇá~=mäÅ=

f~å=dáäãçìê= s~å=^ãÉóÇÉ=~åÇ=t~ääáë=iíÇ=

jê=m=ráåÖë= tççäïçêíÜë=

jÉäîóå=a~îáë= táääá~ã=^åÇêÉïë=C=`ç=

^åÇêÉï=eáíÅÜ= qÜÉ=dä~ÇÉë=jÉêÅÜ~åíë=^ëëçÅá~íáçå=

`~êçäóå=iÉïáë= _êçãäÉó=mq`=

_~êÉåÇ=sÉääÉã~å= k`j^=

`~êçäáåÉ=q~íÅÜÉää= k`j^=

^êÅÜáÉ=^îÉêó= =

píÉîÉ=mêáÅÉ= _êçãäÉó=jóíáãÉ=

hÉáíÜ=bñÑçêÇ= ^ÑÑáåáíó=



appendix 2 OPTIONS KEY STAKEHOLDER WORKSHOP ATTENDEES

qÜÉ=ÑçääçïáåÖ=áåÇáîáÇì~äë=~åÇ=çêÖ~åáë~íáçåë=~ííÉåÇÉÇ=íÜÉ=hÉó=pí~âÉÜçäÇÉê=tçêâëÜçé=ÜÉäÇ=çå=íÜÉ=NVíÜ=çÑ=pÉéíÉãÄÉê=OMMRW==

cáêëí=k~ãÉ= lêÖ~åáë~íáçå=táää=bÇãìåÇë= k~íÜ~åáÉäI=iáíÅÜÑáÉäÇ=C=m~êíåÉêë=qáã=dççÇäáÑÑÉ= `çãéìíÉê=pÜçééáåÖ=`ÉåíêÉë=

`çäáå=_ìêåÉíí=_ìêåÉíí= mä~ååáåÖ= C= aÉîÉäçéãÉåí=iíÇ=

pÉÄ~ëíá~å=_~äÅçãÄÉ= qê~åëéçêí=Ñçê=içåÇçå=iÉÉ=e~êîÉó= içåÇçå=cáêÉ=_êáÖ~ÇÉ=E_êçãäÉóF=kÉáä=oçïäÉó= p~îáääë=EfkdF=oçó=`çää~Çç= `çää~Çç=`çääáåë=^êÅÜáíÉÅíë=_êá~å=q~áå= _êçãäÉó=jóíáãÉ=`Üêáë=däçîÉê= `ÜìêÅÜáää=qÜÉ~íêÉ=iáò=dÉåíêó= `ÜìêÅÜáää=qÜÉ~íêÉ=g~ãÉë=pÜ~êé= mÉääáåÖë=a~îáÇ=j~áå= pçìíÜ=içåÇçå=_ìëáåÉëë=mÜáäáé=ÇÉ=_êìóå= içåÇçå=^ãÄìä~åÅÉ=pÉêîáÅÉ=

j~íí=_Éää=jÉíêçéçäáí~å=mçäáÅÉ=pÉêîáÅÉ=J=_êçãäÉó=

jáÅâ=_çååÉê= tççäïçêíÜë=mÉíÉê=j~êíáå= i_=_êçãäÉó=`çäáå=oìÇÇäÉëÇÉå= i_=_êçãäÉó=j~êó=j~åìÉä= i_=_êçãäÉó=káÅâ=`çääáåë= båÖäáëÜ=eÉêáí~ÖÉ=g~Åâ=pÉÅë~êÇ= mêçàÉÅí=aáêÉÅíçê=o~åÖÉêë=oç~Ç=jáÅÜ~Éä=tÜÉÉäÉê= _êçãäÉó=^Çìäí=bÇìÅ~íáçå=`çääÉÖÉ=d~êó=pï~åå= _êçãäÉó=j~ó=qáãÉ=J=m~îáäáçå=i`=m~íêáÅâ=t~ää= _êçãäÉó=`çìêí=eçíÉä==



appendix 3

OPTIONS PUBLIC FOCUS STAKEHOLDER WORKSHOP INVITEES

qÜÉ=ÑçääçïáåÖ=áåÇáîáÇì~äë=~åÇ=çêÖ~åáë~íáçåë=ïÉêÉ=áåîáíÉÇ=íç=íÜÉ=mìÄäáÅ=cçÅìë=pí~âÉÜçäÇÉê=tçêâëÜçéW==


hÉå=pãáíÜ= mÉÇÉëíêá~åë=^ëëçÅá~íáçå=

cêÉÇ=táäâáåëçå= _êçãäÉó=C=_áÖÖáå=eáää=^êÉ~=

jê=o=i~ïëçå= __o^d=


jê=q=_êçïå= mÉçéäÉ=táíÜ=aáë~ÄáäáíáÉë=

jê=d=pÜáéäÉó=_êçãäÉó= kçêíÜ= oÉëáÇÉåíëÛ=^ëëçÅá~íáçå=

jë=o=pÜáéäÉó=_êçãäÉó= kçêíÜ= oÉëáÇÉåíëÛ=^ëëçÅá~íáçå=


f~å=_êçÇáÉ= _êçãäÉó=pçìíÜ=^Åíáçå=dêçìé=





gìÇó=cìääÉê= `çããìåáíó=iáåâë=


jê=a=g=tççÇ= ^m`^=

páãçå=^åëíêÉó=_êçãäÉó= kçêíÜ= oÉëáÇÉåíë=^ëëçÅá~íáçå=

gÉÑÑ=oçóÅÉ= =

jáÅÜ~Éä=píÉîÉåë= _êçãäÉó=`Üêáëíá~å=`ÉåíêÉ=


^ä~å=_~åÅÉ= _êçãäÉó=`Üêáëíá~å=`ÉåíêÉ=

_êìÅÉ=^åÇÉêëçå= =

o~ó=t~íëçå= cêáÉåÇë=çÑ=íÜÉ=b~êíÜ=

aÉêÉâ=mçïÉää= i__oc====



appendix 4

OPTIONS PUBLIC FOCUS STAKEHOLDER WORKSHOP ATTENDEES

qÜÉ=ÑçääçïáåÖ=áåÇáîáÇì~äë=~åÇ=çêÖ~åáë~íáçåë=ïÉêÉ=~ííÉåÇÉÇ=íÜÉ=mìÄäáÅ=cçÅìë=pí~âÉÜçäÇÉê=tçêâëÜçé=ÜÉäÇ=çå=íÜÉ=ÉîÉåáåÖ=çÑ=íÜÉ=NVíÜ=pÉéíÉãÄÉê=OMMRW==Individual Organisation oáÅÜ~êÇ=`çã~áëÜ= cêáÉåÇë=çÑ=íÜÉ=b~êíÜ=j~íÜÉï=tÜáíå~ää= _êçãäÉó=qçïå=`ÜìêÅÜ=m~ìä=dçìäÇÉå= ^ÖÉ=`çåÅÉêå=_êçãäÉó=däÉå=pÜáéäÉó= _êçãäÉó=kçêíÜ=oÉëáÇÉåíëÛ=^ëëçÅá~íáçå=oáí~=pÜáéäÉó= _êçãäÉó=kçêíÜ=oÉëáÇÉåíëÛ=^ëëçÅá~íáçå=a~îáÇ=tççÇ= ^m`^=oçÖÉê=i~ïëçå= __o^d=^äÑêÉÇç=jÉêÇÉë= içåÇçå=_çêçìÖÜ=çÑ=_êçãäÉó=qçåó=_çãÑáÉäÇ= eÉ~êí=çÑ=_êçãäÉó=


APPENDIX 3

AAP: PREFERRED OPTIONS (JANUARY-FEBRUARY 2006): SUMMARY OF CONSULTATION RESPONSES


Publ ic Consul tat ion Summary Preferred Opt ions January to February 2006 Responses received via: • leaflet completed questionnaire 1264• email completed questionnaire 74• letter 57• additional email responses 23• petitions 2 Leaf let Quest ion 1 Do you agree the town needs at least one new department store? Response Number % Agree 1112 90% Disagree 105 8% No View 24 2% Quest ion 2

Do you agree the town needs a better range of entertainment facilities, including a multi-screen cinema, to help make the town more attractive to visitors of all ages, especially in the evening?

Response Number % Agree 954 78% Disagree 189 15% No View 83 7%

Question 3 Do you agree it is important to protect the heritage of Bromley? Response Number % Agree 1174 95% Disagree 23 2% No View 43 3%

Question 4 Do you support residential development in the town centre?



Question 5 Do you support the redevelopment options for Bromley North and south railway stations, which could help

improve the current transport facilities?


Question 6 Do you think the town needs a hotel?


Question 7 Do you think it is important that the town retains a leisure centre?


Question 8 Would you use the public open spaces and gardens more if they were better signposted and more easily

accessible?



Question 9 Do you agree that redevelopment of the western side of the High Street would revitalise the town centre by

providing a better retail balance?



Question 10 Do you think the preferred options would improve the town centre?


Age monitoring Age Number % under 20 12 1% 20-34 145 12% 35-49 248 21% 50-64 376 31% 65 or over 426 35%


Question 11 Options not agreed with (concerns/objections/reasons)

General Comment Number of

comments made

% of those

comments

Ranked

Leisure centre : demolition and relocation 67 12% 1 Residential development 64 11% 2 Quantity of Cheap shops 47 8% 3 Anti-social behaviour 39 7% 4 Demolition of housing stock 39 7% 4 Glades extension (Site E) 36 6% 5 Extension of Licences and Licensing Hours 30 5% 6 Congestion 27 5% 6 Hotel 22 4% 7 Relocation of churches 22 4% 7 West of High Street development 21 4% 7 Demolition of The Hill car park (Site D) 16 3% 8 Cinema/theatre 13 2% 9 Queens garden café 12 2% 9 Civic Centre relocation (Site F) 11 2% 9 Extending pedestrianised area 10 2% 9 Further information of plans required 9 2% 9 Possible lack of parking opportunities (Site D) 9 2% 9 Better signposting 8 1% 10 Need for new Department stores 7 1% 10 Further retail development 7 1% 10 Bromley North redevelopment (Site A) 6 1% 10 Quantity of eating places 6 1% 10 Health/Education services – strain on 6 1% 10 Concerned about loss of Green space 5 1% 10 High rise development (Site N) - unsightly 5 1% 10 Redevelopment of Westmoreland Road car park (Site K) 4 1% 10 Loss of library facilities 2 0% 11 Aggressive security 2 0% 11 Concerned about vandalism/graffiti/litter 2 0% 11 Market researches nuisance 1 0% 11 Open spaces/parks cause anti social behaviour 1 0% 11 Concerned about road infrastructure 1 0% 11


Question 12 Other options to be considered:

Number of

comments made

% of those

comments

Ranked

Would like to see a new Department store/s 153 10% 1 Parking – cost/access/increased park and ride 112 7% 2 Recognition of Religious facilities 108 7% 3 More specialised shops 90 6% 4 Bromley South railway improved – access lifts/drop off 86 5% 5 leisure facilities to include ice/roller skating/bowling skate parks 71 4% 6 Young people provided for 71 4% 6 Policing/security increased 52 3% 7 Art gallery/cinema included 51 3% 8 Road/pavement infrastructure improved 47 3% 9 Leisure facilities improved – swimming pool 43 2% 10 Street lighting/cleaning improvements/pest control (pigeons) 34 2% 11 Green environment – create/keep/flower beds, st trees 31 2% 12 Churchill gardens regeneration, promote HG Wells 31 2% 12 Restaurants/quality pubs late entertainment 30 2% 13 Heritage – promote/retain 29 1% 14 Tramlink extension 27 1% 15 Market improvement/increased 25 1% 16 Concert hall required 23 1% 17 Train service improved 22 1% 18 Bus services – improved 21 1% 19 Bromley North Station/services improved 20 1% 20 Bromley South improvement 19 1% 21 Hostels/hotels included 18 1% 22 Leisure – out of town 18 1% 22 Parks facilities improved 17 1% 23 Disability access 17 1% 23 Pedestrian facilities 16 1% 24 Housing – affordable 16 1% 24 Cyclists signage/facilities 15 1% 25 Shopping facilities improved

13Less than

1% 26 Food courts 13

26 Seating 13 26 Business support 10 27 Library improvements/ground floor library 10 27 Toilets 10 27 Extend Glades up to join Theatre 8 28 West side improvements (G) 8 28 Supermarkets 8 28 Free Sunday parking 7 29 Market researchers reduce 7 29 Market Square – north redevelopment 5 30 Disability opportunities 4 31 East Street shops improved 4 31 Sustainable development 4 31 Charity centres – activity etc. 4 31 Orpington town centre refurbishment 4 31 Pedestrian crossings 3 32


Street furniture – less 3 32 Deli Stores multi culture 3 32 Minor injuries unit 3 32 Employment opportunities 2 33 Westmoreland car park(K) remove 2 33 Canal waterways improved 2 33 College Green improvements (B) 1 34 Post office required 1 34 Hospital bus links 1 34 Child shopping crèche free 1 34 Licensing hours reduced/less pubs 1 34


Postcode monitoring Postcode Number % BR1 483 40% BR2 305 26% BR3 114 10% BR4 54 5% BR5 42 4% BR6 45 4% BR7 37 3% BR8 2 Less than

1% BS15 1 CR0 7 CR2 3 CR3 1 DA14 3 DA15 3 DA2 1 DA3 1 ME14 1 ME16 1 ME19 2 NK45 1 RH1 1 RH8 2 RM14 1 SE12 9 SE13 2 SE19 4 SE20 16 1% SE23 1 Less than

1% SE26 1 SE6 6 SE9 13 SM6 1 SW15 1 SW16 1 SW1V 1 TN11 2 TN13 4 TN14 2 TN15 1 TN16 16 1% TN17 1 Less than

1%


Summary of Written Representations C01 Turleys on behalf of

Sainsbury’s • wish site to be identified for re-development • any retailing in Bromley South would merely

redistribute shopping rather than trying to retain lost expenditure

C02 Salvation Army • important for them to stay within the town

centres and increase capacity • excited about the plans and wish to become

key partners in any development opportunity

C03 Bromley Town Chaplaincy - covers 15 churches in and around town

• see the AAP as a positive initiative agree some form of re-development is essential

• believe the town needs more community cohesion

• wish to see more emphasis on the religious needs of the town centre, their beneficial social/ community/youth activities

• wish to see more diversity in shop frontages/less retail focus

• wish to see improvements to Bromley South Station and to attract commuters into the town

• support residential • would like the town to have improved

permeability • town needs a better balanced evening

economy

C04 Thames Water • All sites – waste water flows – suggest para to be included in plan

• sites – C,D,L,M and N no concerns re clean water supply but have concerns regarding water supply capability to all other sites. Suggest inclusion of wording for plan.

• upgrading waste water facilities can take up to 3 years.

C05 Tandridge District

Council • No comment but please keep informed


C06 Mytime • support the regeneration of town • Pavilion not keeping pace with changing

leisure demand and pool expensive to run. Sports hall etc. underused

• Pavilion could be re-figured but possibly not economic to do so

• concerned about loss of facilities whilst being re-developed

• sports facilities should be in town centre • additional housing would create new

customers

C07 Bromley Friends of the Earth

• AAP needs more thought about improving public transport

• more retail will mean more congestion • Suggest moving LBB (Civic Centre) out of

town • improve leisure facilities • would like eco-friendly development

C08 The Theatres Trust • pleased with commitment towards culture and support new town square at theatre/library

C09 Broomleigh • support initiative, especially new residential

• consider growth of internet when considering new, extended retailing

• railway stations require improved access • Should retain a leisure centre in the town to

provide variety of activities • Should protect green spaces

C10 Bromley Green Party • Suggest possible traffic congestion in town if re-developed

• Sustainability Appraisal issues; wish to see eco-friendly development

• Should keep leisure in town • Should encourage small, independent shops

C11 Her Majesty’s Court Service

• Town need improved transport links • court users use Hill car park so any re-

development could impinge on them

C12 English Partnerships • no comment

C13 Tinklin Springall • have concerns about current traffic congestion around Elmfield Road and town generally

• have concerns about current unsocial behaviour


C14 Parish Church of St Mark

• strongly support the broad vision • town needs high quality residential • AAP should mention churches/faith

communities – significant stakeholders • upgrade public transport • improve pedestrian facilities • expand farmers market

C15 CgMs (consultants for Metropolitan Police) and attached document ‘ Planning for Future Police Estate Development” guidance for LA’s

• additional development will have a direct impact on the need for additional community facilities and services

• important that ‘Secure by Design’ principles are achieved policy should reflect this

• AAP should include.... “community safety and policing initiatives”.

C16 Michael Rodgers • should re-site bus gate

• shuttle from Bromley North into town • Town needs hotel

C17 Network Rail • stress the need for better access to and around Bromley South station

• viable development is key to funding new infrastructure

• support the board development options in table 5.1 but wish to have a stand-alone retail element including at Bromley North

• concerned about any future transit system and wish to discuss how this might limit other interchange enhancements

C18 Savills

responding on behalf of ING

• concerns regarding statement in paragraphs 4.3 and 4.6 regarding entertainment/leisure forms at Bromley South.

• Suggest re-wording development .opportunities for Site J.

• suggest rewording para. 4.7 • suggest rewording para 4.11 regarding

relocation of bus gate • suggest rewording of Table 5.1 to reflect

comments made on paragraphs 4.3 and 4.6. • Town Centre retail frontages should be

defined in AAP taking account of the importance of Bromley South station.


C19 GOL • the Sustainability Appraisal needs to show clearly how the process to identify options was arrived at

• the Sustainability Appraisal should consider short, medium and long-term effects

• monitoring should be addressed • Sustainability Appraisal needs to show

compliance with SEA Directive • range of uses for a number of sites too

varied, or whether use would warrant tall buildings on sites indicated

• DPD needs to relate to UDP • residential should reflect wider housing needs

and appropriate mix of retail units. Details policies may be required to ensure outcomes are achieved

• it may be appropriate to bring issues of licensing/anti-social behaviour etc within the scope of the AAP

• need to promote the efficient use of existing buildings

• address phasing of development • address how to deal with sites not allocated

to deal with sites not allocated in AAP • give protection to and enhancement of

historic elements • identify frontages

C20 Bromley PCT • GP/Dental & Social Services needs should be taken into account within the AAP new residential development should provide the resources to meet the impact of additional residents

• sites for such services should be identified in AAP

C21 Nathaniel Lichfield and

Partners • concerns about current ranking of BTC • support new retail floorspace requirements

especially those on Site E due to limited opportunities to provide the scale of new retail required elsewhere in the town

• high quality design is crucial • any planning gain requirements should reflect

government guidance


C22 Burnett Planning & Development representing Legal and General

• suggest town centre under-performing • L&G support a principle of a phased

approach to development rather than the emphasis on a comprehensive approach

• proposals for site G are vague and unrealistic and need the level of detail set out in PPS12 otherwise will not meet test of soundness

• timescales for development should be clarified

• concerned about the AAP being able to prove a proper environmental assessment in accordance with SEA and regulations – more detailed information required

• questions why Ringers Road site is included in site G

• L&G support residential development in the town and this should be recognised in AAP

• Ringers Road site should be identified solely as a high density residential location

C23 Star Planning and

Development on behalf of Taylor Woodrow Developments

• the objectives need to be quantified, they are too broad and generalised

• the AAP should encourage the two stations to be ‘destinations’ with different attritubes along a traffic free pedestrian corridor

• poor quality buildings in southern end of High Street and an absence of mix of uses which reflects lack of vibrancy within the town during day and evening

• Kentish Way divorces the Civic Centre (site F) from the town and the road frontage needs enhancement to integrate civic centre into the town

• AAP should encourage flexible general policies that provide mixed uses ie. active ground floors with residential or offices above

• support landmark buildings on key sites


C24 Social Services and Housing Department

• the number of residential units identified are needed and desirable

• the affordable housing provision likely to come forward will help to ensure there is an adequate workforce supply in the future for the town and the borough as a whole

• support improvements to transport links • new commercial development will help

promote social inclusion and improve quality of life

• support provision of new entertainment and leisure facilities which will help to balance social mix in the evening

• accommodation for the elderly/disabled should be addressed as well as those for families

• support reduced parking provision for social rented housing

• health and educational requirement should be addressed

C25 Highways Agency • support development locations for retailing

• consideration should be given to reducing the need to travel and reliance on the car

• development options should be deliverable • traffic modelling should be used to address

impacts of development • Park and Ride facility is supported in principle

which they work expect to be able to reduce the level of parking available in the town

C26 P.P.S

on behalf of Land Securities Trillium

• welcome inclusion of site L within the emerging AAP, but suggest changes to boundary of site to exclude St Mark’s School and churches and restricted to Crown Buildings only, suggest deleting reference to retention and refurbishment of school building

• they believe the school and church buildings do not make a positive contribution to the redevelopment of the site for town centre uses and produce a constraint as to future re-development opportunities

• Crown Building relate to town centre and could incorporate a 5/6 storey development tapering downwards towards existing residential

• office uses also may not be viable • potential for a hotel, being close to transport

and business sectors with an element of residential should be identified.


C27 The Countryside Agency

• support the objectives • the Action Plan could help alleviate or

address lack of animation/solution of the public realm/open space in the town

• consider policies to improve sustainable transport

• consider inclusion of live/work units in new development within the town.

C28 Friends of Bromley

Town Parks & Gardens and Heart of Bromley Residents Association

• dispute BTC’s decline • site E, so close to Debenhams, could not

support another department store • concerned that a new multi-plex cinema

would destroy existing Odeon and cinema in Beckenham

• support other leisure provision ie. skate boarding facilities, restoration of River Ravensbourne

• unhappy with approach to historic buildings and heritage sites and against sale of such properties merely to raise revenue

• concerned about blight and possible Compulsory Purchase Orders

• Site B should be withdrawn • Site C: Council should reoccupy • Site D: blight to existing homes - loss of Odeon cinema - against taller buildings as within a conservation area - welcome inclusion of more homes it existing not demolished • Site E – leisure centre should not be

relocated • Site F – should be returned to open parkland

and Palace restored similar to Addington Palace/Beckenham Palace

• Site G – against demolition of existing shopfronts

- against demolition of residential housing and churches - support enhancement of retailing outside of conservation area • Site J – supports • Site K – against cinema development • Site L – St. Marks School & DHSS building

should be retained • Site M – against any encroachment of

more hardstanding into the green space for that cost to a cafe use

• Site N – support improvements in principle •


C29 Magpie Dance • supports emphasis on culture • supports creating stronger east-west axis in

the town especially if performance facilities are included.

C30 Development Valued

Lifestyles Partnership • would like to see inclusion of a one stop

health information shop/centre • support mix of shops and market • work experience for disabled • shop mobility schemes • more public toilets

C31 Churchill Theatre • support cultural quarter • support mixed use development, to include

restaurants and high quality cinema • support more use of open spaces through

integration with rest of town.

C32 CgMs Consultants on behalf of Royal Mail Property Holdings

• support objectives including enhancement of Bromley North

C33 GVA Grimley • support requirement for additional retail floorspace

• Site D should contain an anchor development • sufficient flexibility should be incorporated to

enable developers to bring forward viable, deliverable proposals, therefore options for Site D should be clarified

• site should be capable of delivering a landmark scheme

C34 GLA (including TfL

comments) • supports broad objectives • AAP needs to demonstrate in more detail

capacity/scale of new retail floorspace • policy should reflect London Plan policies

4B.3, 4A.9 • employment and training should be included

within S.106 contributions • traffic congestion is an issue and measures

should be taken to mitigate consistent with London Plan requirements

• better bus interchanges should be identified as well as improvements for pedestrians and cyclists

• the severance caused by The Glades and Kentish Way should be improved

• Bromley should identify the mechanism for funding and delivery of P & R facilities and a new transit initiative.


C35 Robert Neill AM • supports the thrust of the AAP • need a balanced economy in the town • supports more residential development as it

would balance late night economy and encourage diversity in the retail mix as well as improve security

• adequate parking is essential • Bromley South station should be

comprehensively redevelopment as soon as possible

• merit in extending DLR to Bromley or Tramlink

• Good design imperative and important that development blends in with existing heritage.

C36 Environment Agency • flood risk issues should be included in AAP in

accordance with PPG25 • support, long term, the re-opening of

culverted water courses • request additional para. to public realm and

environment section • more regard to natural environment/

biodiversity/ecological issues • open space should be identified as having a

more multi-functional role • reflect PPSI on biodiversity issues • new development should contribute to

ecological resources • flood risk assessment • sustainable construction should be included Site A – groundwater protection zone Site B – flood zone 3 Site C – groundwater protection zone Site D – county wildlife site at Martins Hill Site E – groundwater protection zone Site F – groundwater protection zone Site G – flood zone 3 and groundwater protection zone Site H – flood zone 3 and groundwater protection zone Site J – flood zone 3 Site K – flood zone 3 and groundwater protection zone Site L – flood zone 3 and groundwater protection zone Site M – flood zone 3 and groundwater protection zone Site N – flood zone 3 and groundwater protection zone


C37 RPS Planning • the housing types/size/tenures should not be restricted

• housing should be at high density as in PPS3 this should be reflected in AAP

• community facilities should only be included if need proven

• funding (para’s 6.5-6.6) seeks too wide range of contributions. Planning gain should reflect government guidance

C38 Bromley Town Church • more reference should be made regarding

the community facilities such as churches can bring to the town

C39 Ross Jones

APCA core panel member

• suggests BTC has eroded, improvement required urgently

• supports the conservation objectives • good design and architecture are important

C40 JP Austen • supports most points but suggests additional issues regarding parks,

• pedestrianisation of East Street and Elmfield Road on The Glades,

• direct connection between BN station and London,

• re-furbish Pavilion • and better priority for pedestrians generally

C41 Mr S.J. Fromont • Ringers Road site should remain in commercial use

• Bromley should not turn into Croydon but be kept small scale

• improve transport links • protect heritage buildings • retain existing car parking and Leisure Centre • cinema at site K would close Odeon • better signposting/notice boards

C42 Barbara Shand • Site F – office blocks should be retained for offices

• leisure facilities should not be lost to town • concerns regarding the consultation process

C43 D.Dulake • health facilities should reflect any increase in residential

• Site E – should retain leisure facility • against signposting open spaces • improvements for pedestrians


C44 A. Eastwood • against tall buildings • has concerns for local residents regarding the

re-development of the town • has issues regarding the consultation process

C45 C.P. England • has concerns regarding traffic congestion/lack of parking

• LBB should allow comprehensive development of buildings of no architectural merit

• improve the pedestrian environment • against social housing • against redevelopment of Site D and Site F

C46 Dr R.C. Skelton • Site D - against redevelopment

C47 Jolanta Allen • concerns regarding an increase in more retail units

• against relocation of leisure centre

C48 S. James • supports new department store/cinema/hotel/leisure

• considers heritage important • concerns regarding late night establishments

C49 Mrs M Fryatt • if leisure centre re-developed it should be replaced

C50 E.N. Slow • against St. Paul’s Square being included in

Site D • against moving leisure centre • against opening up parks and gardens • warns about future congestion caused by any

re-development

C51 Richard & Kate Dumville

• against re-development of St. Paul’s Square • against Site G and Site E re-developments • concerns about more pedestrianisation • support improvements to railway stations and

improved train services from Bromley North

C52 C.M. Ward • against re-development of St. Paul’s Square

C53 Miss B Jones • improvements needed to Bromley South Station for disabled/elderly etc.

• against more retail unless high class • against moving Pavilion


C54 Thomas F Pressinger • against loss of Ethelbert Close for more retail, concerned about blight to properties on site G

• against tall buildings that would overshadow Church House Gardens

• need improvements to public transport • Site F should be re-developed

C55 R.T.G. Marks • against re-developing Ethelbert Close although support the aims of the Council to improve the town

P e t i t i o n s : - a g a i n s t d e m o l i s h i n g h o m e s / i n c l u s i o n i n p o s s i b l e d e v e l o p m e n t s i t e

C56 St. Paul’s Square signed by numbers:-

1, 2, 3, 4, 5, 6, 7, 8, 12, 13, 17, 18, 20, 21

C57 Ethelbert Close and 9 completed forms from BR1 1JB plus

signed by numbers:- 2, 7, 9, 13, 14, 17, 21, 23, 27, 28, 31, 32, 34, 37, 38, 39, 40 • 43 Buckingham Way, Wallington, Surrey,

SM6 9LU • 26 Hazelwood House, Church Road,

Shortlands, BR2 0HE • 15 Standard Road, Orpington, BR6 7HJ • 10 Romanhurst Gardens, Bromley, BR2 0PA • 24 Nichol Lane, Bromley, BR1 4DE

C58 B.L. Kelly • against including St. Paul’s Square in Site D

C59 L. Colwell • concerns re-Ethelbert Close petitions


APPENDIX 3.1: AAP: PREFERRED OPTIONS (JANUARY-FEBRUARY 2006): RESPONSES TO CONSULTATION

BROMLEY TOWN CENTRE AAP / SA – Responses to Comments Received Ref No & Name

Summary of Representation LBB Comments/Response Proposed Changes to Preferred Options and/or inclusions in AAP

RPO1 Barry Wooding

Commented that Bromley South station has no provision for wheelchair users, and that assurances need to be given to wheelchair users that when redeveloped the station will be fully accessible to the disabled.

Bromley South Station is one of forty stations recently identified for inclusion on the DfT’s Access for All scheme programme. This programme, funded by the DfT and implemented by Network Rail, sees the redevelopment of station infrastructure to provide step free access as well as other accessible facilities including improved lighting, hearing induction loops and passenger information schemes. Network Rail will carry out a feasibility study for the station over the next 18 months to establish what improvements need to be made, before upgrading the station between 2012 and 2015.

The AAP will include policy regarding inclusive design and accessibility. Development guidelines for Sites A and J will include requirement for access improvements to Bromley South and Bromley North railway stations.

RP02 Richard Evans Surrey County Council

No concerns over proposed revisions. Opportunity sites and proposals of local importance

No comment No changes

RPO3 A Eastwood

Commented on an area of the map on the Revised Preferred Options leaflet around Palace View as being grey, asking if there is planned development there. Insufficient weight given to views of immediate residents

No planned development- the graphics denote existing urban area Views of local residents taken into account through formal consultation on AAP

New development will be required to protect existing residential amenity and incorporate appropriate mitigation to minimise impacts

RPO4 Ray Watson Bromley Friends of the Earth

Expressed concern at the conflict between development of retail space and increasing traffic congestion. Mitigation measures and park and ride schemes will not solve problems and will shift congestion and parking issues to the suburban areas. Propose relocation of civic centre from central Bromley to reduce trips to town centre

The transport assessment and sustainability assessment both encourage the development of park and ride schemes and promote modal shift onto public transport that aims to reduce private car use. It is considered that these measures can address issues of congestion and make Bromley a more attractive retail centre. The AAP includes a parking strategy to

AAP to include Transport Strategy and policies to promote sustainable transport modes. AAP to include requirement for relocation of the Pavilion Leisure Centre within town centre if site redeveloped for retail uses.

RP06 Amanda Bradshaw The Local (Hayes Keston Bromley Common)

Requested press release/ information Information provided

RP07 Marie Neal Craft Jungle

Need for bus service, one way street system, 2 hour parking restriction and security cameras along Chatterton Road

Chatterton Road is outside of the Bromley Town centre AAP boundary. Comment passed to Transportation section.

RPO8 Ian Sutton Play Strategy Manager

Children’s play areas would be beneficial in attracting families to the town centre and would provide children with a safe place to play. Need for a family friendly town There is currently no space for disabled people and children Play facilities in Church House Gardens too far from town centre to enable use as part of shopping trip. Potential for play facilities in Queens Gardens. Need to secure free play provision and child friendly public art- climbable and playable Need for accessible space for voluntary sector to run play and activity sessions for children with additional needs- this could be taken into account in proposals for site D.

New development will be required to make provision for childrens play space to meet needs of new residents. Existing children’s play space in Church House Gardens and St Martins Hill will be improved.

Policy relating to provision of childrens play space to be included in AAP. The potential for incorporation of public art will be highlighted Policy on inclusive design and access to be included in AAP Requirement for community facilities to be provided as part of development of opportunity sites.

RP09 Steve Shippey

Request further information Information provided

RPO10 Steve Best

Town is unsafe for families in the evenings – need to ensure that more bars do not add to problems Facilities for teenagers should be incorporated into future redevelopments. Need to encourage small independent shops- becoming a clone town with limited unique shopping character

Importance is placed on safety and security and making the town centre a more attractive destination for all ages in the evenings. A range of retail uses will be promoted to enhance the town centre offer and reinforce Bromley’s distinctiveness

AAP will include policies on design and town centre management

Relocation of pavilion conflicts with need to encourage evening and night life in town centre and reduce use by shoppers using Glades; impact on health and potential loss of green space Impact of retail development on shops in Bromley South and local shopping centres Possible extension to The Glades could result in Queens Gardens being overshadowed- loss of open space due to new cafes Need to ensure no loss of open space or negative effects on biodiversity.

promote increased utilisation of existing parking. Relocation of the pavilion leisure centre proposed within town centre. The AAP includes proposals to promote evening economy. The town centre is considered the most suitable location for civic facilities given its high level of accessibility by public transport. Retail development is required to maintain Bromley’s status as a metropolitan centre. The town centre provides a different range of facilities in comparison to smaller centres and will not impact on the viability of local centres. The extension to the Glades will be subject to environmental assessment. Sensitive design will be required to minimise impacts on Queens Gardens.

RPO5 Bernadette Manning

Increased traffic flow into the town centre will need to be addressed, particularly through Beckenham Lane and Shortlands Village. Lack of traffic calming in Beckenham Lane will contribute to problems

Extensive traffic modelling has been undertaken for Bromley town centre to understand the impact of development on the town centre traffic flows and wider network. Mitigation measures, such as a town centre wide travel plan, improvements to public transport and the management of parking, will be in place to ensure traffic levels are kept at a manageable level throughout the town centre.

AAP will include provision for highway improvements outside town centre to address issues of congestion and increased traffic.

RPO11 Dick Groves Disability Voice Bromley

Developments need to take into account the needs of the local disabled residents. Bromley has one of worst records for disabled access and safety in London- less than 30% crossings in town centre have provision for visually impaired. Recent improvements unsatisfactory and dangerous Need for meaningful consultation regarding access for disabled persons

Importance placed on improving accessibility for all users and the promotion of fully accessible developments. The AAP seeks to create an accessible and inclusive town centre. The Council are committed to ensuring that a full and representative consultation takes place with all sectors of the community. We will ensure your comments are taken on board. The Council is undertaking an Equalities Impact Assessment (EqIA) as part of the AAP. Consultation will be undertaken with disability groups as part of the EqIA

AAP includes policy on inclusive design and accessibility

RP012 Amanda Weston Bromley Police

General questions about AAP See RP70

See RP70 See RP70

RPO13 Vincent Stops, London Travel Watch

Improved permeability for cyclists and walkers is important- need for development to reduce barriers to pedestrians (particularly Kentish Way, one way streets and staggered pedestrian crossings from Bromley North to shopping areas). Kentish Way is often congested, and bus priority would be welcomed. Need for second accessible entrance to Bromley South Station from Kentish Way Town centre would benefit from the reinstallation of the market in a more accessible central location. AAP should promote a reduction in off-street parking. Support modal switch away from private car.

Initiatives for improving walking and cycling in Bromley town centre will be an important component of the Transport Strategy for the AAP. Planned cycle and walking improvements will include new links and pedestrian crossings. Consideration will be given to enhancing bus priority on the A21 (Kentish Way) as part of comprehensive transport strategy. Kentish Way is part of the TLRN for which TfL is the highway authority and Council will be investigating opportunities in conjunction with TfL. Network Rail are due to carry out a feasibility study on Bromley South Station over the next 18 months as part of the DfT Access for All scheme. This will establish what

Policies included in AAP to promote cycling and walking and improvements to public transport

improvements are needed for the station including the number and location of step free accesses. A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision and restraining parking where appropriate. Consideration is to be given to potential relocation of the Charter Market to the pedestrianised High St to provide improved accessibility and operation.

RPO14 Roger Bleach Telereal on behalf of BT

Support proposals to enhance economic and social vitality of town centre but asks for following to be taken into account:

• Bromley Telephone Exchange is operational • new technology has recently been installed to serve

future needs • BT has no plans to vacate the Telephone Exchange in

the foreseeable future • Relocation of Telephone Exchange would incur

substantial costs in terms of infrastructure and property.

Operational requirements of BT are noted. Proposals for development must be capable of delivery within timescale of the AAP.

In view of unavailability of Telephone Exchange for development, Site D is excluded from AAP because the site is considered too small to support a viable comprehensive redevelopment

RPO15 Linda Evans

Welcome proposals for regeneration and improved safety at night- may be assisted by housing in area. As a resident of Queens Road, concerned that access may be difficult after development and about increased traffic. May discourage people from shopping in town centre and disadvantage existing residents. Concern about costs of proposals and possible increase in Council Tax to pay for them.

No plans for altering the traffic flows in the Queens Road area, although the potential for improving the pedestrian environment is under review. The AAP seeks to improve Bromley Town Centre including how to bring it to life at night by improving the night time environment and improving safety issues.

AAP includes policies on design and town centre management which address issues of safety and security AAP includes a comprehensive transport strategy

RP016 Martin Helt

Request for information Information provided

RP017 Councillor Granger

Support relocation of Pavilion Leisure Centre Library and theatre should be located on periphery with access to parking Concern about impact of discouraging use of car on performance of town centre in relation to competitors- notably Bluewater with convenient access and free parking

Noted Development will be dependent on increased use of more sustainable transport modes but Transport Strategy will include measures for improvements to walking, cycling and public transport and a parking strategy which will seek to improve use of existing parking. New parking is proposed to serve proposed retail development Library and theatre will have improved access to parking

AAP includes a comprehensive transport strategy

RP018 Tom Tucker

Concern about decline of town centre, loss of quality retail, environmental quality, night time safety issues, anti-social behaviour. Need to promote quality development

AAP seeks to address decline of town centre and provide a more vibrant and attractive centre.

AAP includes policies to improve the appearance of the town centre and promote high quality design in new development

RP019 S Sykes

Request for details of Compensation Code applicable to home owners in Ethelbert Road

Information provided

RP20 Christine Diamond

Main concern relates to extended retail offer. Vital to have one or two department stores to compete with other towns. Preference for housing development closer to town centre rather than outlying areas.

AAP seeks to address decline of town centre and provide a more vibrant and attractive centre including provision for new department stores and town centre housing

Site L extended to ensure viable development can take place incorporating safeguarding requirements

Plan for next 5 years sensible- development of DHSS building for hotel/ residential uses supported and should be speeded up due to close proximity to rail links at Bromley South

Development of DHSS (Site L) in Phase 1 but needs to take into account safeguarding requirements for transport projects..

RPO21 Steve Dark, Bromley Fire Station

Need to establish whether existing site can meet LFEPA requirements. Charter Market site adjoining Bromley North Station may be a suitable location for a new fire station.

Council will work with LFEPA to identify suitable alternative site if relocation of fire station required in future. No suitable alternative site identified in Town Centre. Bromley North (Site A) identified for other uses to deliver transport improvements and mixed use development in accordance with London Plan. Development of Site C should take into account possible future redevelopment of fire station site,

Development guidelines for Site C highlight need to take into account possible future redevelopment of fire station site.

RPO22 D DasGupta, Adult and Community Services

Need to identify opportunities for meeting learning Disabilities needs through planned development. Concern about lack of parking spaces in Bromley Town Centre for minibuses, particularly for disabled users. This limits opportunities for adults with learning disabilities to integrate. Need for special facilities for disabled eg: changing facilities with hoists. Need to ensure town centre is inclusive.

An Equalities Impact Assessment (EqIA) is being undertaken.


RP023 Patrick Wall Bromley Court Hotel

Bromley Court Hotel already provides good conference/ hotel facilities- misleading to say Bromley does not have a quality hotel. Need to address the business sector to ensure hotels thrive. An additional hotel would dilute current business market between hotels. Bromley has a small business sector- limited number of medium to large companies. A lot of existing office space is empty- only one site identified for office space (Old Town Hall)- all other sites are for mixed use development including retail, leisure and residential. Need to place more emphasis on developing business sector and attracting business into Bromley. Concerned that hotel has not been consulted directly on market potential for another hotel.

The potential for additional hotel accommodation has been identified. This will enhance Bromley’s position as a metropolitan centre. AAP promotes improvements to existing business areas and protection of existing office accommodation

AAP includes policy on promotion of business sector and improvements to business areas

RPO24 Belinda Price

No requirement for new department store but town centre would benefit from multiplex cinema. Key issues relate to traffic and movement. Access to Bromley South station for those with wheelchairs or prams is very poor- needs to be addressed urgently. Bromley can only thrive when station is made more accessible- otherwise people will come by car leading to increased congestion and pressure on parking. Need to look at short term proposals to improve accessibility- cannot wait for development. Supports Bromley South as a transport interchange- could promote trains to Beckenham junction and links to tram. Need to give greater priority to public transport. Support for congestion charge at peak times. Concern about long walk from Kentish Way bus stop to Civic centre- suggests reception in the Glades

Requirement for new department store identified through market assessment. Site K has been identified for a multi-plex and interest has been shown from prospective developers. Both developments will enhance Bromley’s offer and position as a metropolitan centre. Redevelopment of stations will need to comply with DDA requirements, including wheelchair and pram access. AAP proposes improvements to Station in Phase 1. Transport Strategy is being developed to help improve highway movements and parking to ensure town is easier to navigate.

Improvements to stations proposed in Phase 1. AAP includes a comprehensive transport strategy including improvements to public transport facilities

RPO25 K Dumville

Concern about proposal to relocate the Pavilion to Civic Centre site:

• approval for Glades was granted with an undertaking that a leisure/ sports centre be built on the site for use by local residents. If the Pavilion facilities were withdrawn for any length of time while new sports centre constructed, this might have legal implications

• If Pavilion facilities withdrawn for any length of time, users of facilities might loose the impetus to exercise with impacts on health care. Withdrawal of sports facilities not an option even for a short period

• Many people use Pavilion and shop afterwards- loss of facilities will affect retail performance.

Need to ensure replacement sports facilities in place before Pavilion is closed.

An alternative sports/ leisure facility will have to be provided if the Pavilion is redeveloped. The civic centre has been identified as an appropriate site for a replacement improved leisure facility.

AAP includes a requirement for the relocation of the leisure facility

RP026 Tim Burrell

Queried size of proposed site for relocation of the pavilion- concerned it would not be large enough for swimming pool

Council considers proposed site to be of adequate size to accommodate requirements

RPO27 David Anderson

Concerned about lack of wheelchair/ pram access at Bromley South station. Need for lifts or escalators.

Redevelopment of stations will need to comply with DDA requirements, including wheelchair and pram access.

AAP policy requires access to stations to be improved and DDA compliant. Improvements to Bromley South proposed in Phase 1

RPO28 Glenis Ruston

Concerned that Pavilion facilities will be relocated Community use should include provision for art and culture. Support for independent shops

If site of Pavilion redeveloped, there will be a requirement to replace facilities within the town. The civic centre site has been identified as a suitable location. New facility will reflect changes in demand for leisure facilities and will be a modern facility which caters for needs and health of community. Community facilities identified as being important- Council seek to attract more live entertainment facilities into town. Bromley North seen as ideal area for independent retailers.

AAP includes a requirement for relocation of leisure facility Arts and culture promoted in AAP including public art, improvements to Churchill Theatre and Library and new public spaces

RPO29 David Corkrow

Queried the compensation code for Ethelbert Close residents.


RPO30 Mr James

Concerned about noise nuisance from existing pubs and clubs Expressed serious concern that a live music venue at Site D would cause further noise disturbance to residents.

Site D excluded. Future use of cinema will be subject to assessment of potential impacts on residential amenity.

RPO31 Nicholas Schoon

Supports proposals for new housing- should include significant proportion (25% or more) of family homes of 3 or more bedrooms, with local play areas and garden space. This will improve environment and design quality and encourage community engagement- improvements to security, privacy and amenity. Possible to build good family housing at medium to high densities. New development should reflect proximity to public transport- encourage walking, cycling and use of public transport and provide limited car parking.

The AAP identifies the need for mix of housing types including family housing. Community facilities including children’s play space and education facilities will be required to meet needs of new development. The increase in floorspace is a net increase on existing floorspace. The increase in retail floorspace meets requirements set out in the sub-regional strategy and the capacity identified

AAP includes policy to promote mix of housing types and tenure and associated community facilities.

Need to make clearer case for increase in retail floorspace- does this include space lost by closure of department stores. Emphasis should be on quality not quantity- significant increase in retail floorspace will increase traffic congestion and will not enhance competitiveness.

in the retail capacity study. Increase in retail floorspace and quality is required to enhance performance. It is recognised that retail development is dependent on a comprehensive transport strategy to address congestion and traffic impacts.

RP032 Adrian Tutchings Linays Commercial

Requested copy of brochure Information provided

RPO33 Mark Sansom Ringers Court Residents Association

Queried whether Ringers Court was within Site G and if so, why there had been no formal notification Queried details of compulsory purchase order/ compensation code.

Residents will be kept informed of AAP and any proposed changes. Details of CPO procedures will be made available at the appropriate time

RPO34 Michael Payne Babbacombe Road Residents Association

Site C- need to ensure any new build will reflect character of former town hall. Need to compensate for loss of car parking spaces Site P- site suitable for affordable housing. Development should include upgrading of Walters Yard and respect conservation area. Site A- development should preserve suburban character of area, improve transport interchange and safety and access. Local community must be fully consulted on development of site. Key concerns:

• Need to spread affordable housing between all sites

• Need to clarify existing parking • Need for improved access • Increased traffic • Development must complement character of

Station Road and Babbacombe Road • Impact of higher density development on water

resources and local neighbourhood • Existing PCT health facility is fit for purpose- further

clarification required of improved community and

AAP includes development guidelines development in keeping with character of surrounding area. Council policy to seek provision of affordable housing in all developments. Developers will be expected to contribute towards infrastructure requirements. Community will be fully consulted on development proposals

AAP includes development guidelines and policy framework for all proposal sites and town centre as a whole.

health facilities • Need for clarification of new transit system and

improved links with Bromley South station • Need clarification of proposals for improved or new

public open space • Need clarification of boundary changes

RPO35 Julia Stewart

Requested clarification regarding impacts of development of Site K and access to off street parking backing onto Simpsons Road.

Clarification provided. The culvert prevents development above it so the rear servicing road behind Newbury Road is left untouched

AAP provides development guidelines to minimise impacts of Site K on residential amenity.

RP036 B Jones and CM Ward

Pleased that St Paul’s Square removed from area for redevelopment but concerned about:

• Enhancement proposals for top end of Martins Hill • Traffic in Market Square- car journeys will be

increased without access through Market Square adding to congestion and pollution.

Site D excluded from AAP Comprehensive transport strategy to be prepared to address issues of access to town centre Martins Hill to be protected. Possible enhancements will include planting and promotion of biodiversity


RP037 Barbara Geere

Planned retail in Pavilion should be for quality department store Need for shops selling better quality goods More cultural activities required to raise Bromley’s profile in the arts- ideally a new arts centre and concert hall Need for more English style cafes

AAP seeks to improve town centre offer- better range and quality of retail and improved arts and culture offer. Emphasis on improving Churchill Theatre and existing facilities. No potential identified for new arts centre and concert hall

RP038 Christine Maddy

Lack of range and quality of restaurants in evenings People put off going to Bromley due to problems of young people/ binge drinking Need for department store- retail offer limited. Bromley becoming a clone town- lack of individual shops. Needs to be different to attract trade from Bluewater and Croydon and to retain high spending capacity within area.

AAP seeks to improve town centre offer and performance- better range and quality of retail and cafes/ restaurants. Objective to attract wider range of users in evenings and to enhance Bromley’s distinctiveness.

RPO39 Nigel Styles, Stylish Living

Freeholder of 10 Sherman Road adjoining Site A- preference for property to remain outside boundary of Site A to enable site to be redeveloped separately. No marriage value between property and Site A.

Comments noted. A comprehensive approach to development is proposed

No change

RPO40 Helen Booker, RPS on behalf of Fairview New Homes

Object to the requirement stated in paragraph 3.32 for a 70:30 split of social rented housing and intermediate housing within the 35% affordable housing provision. Affordable housing mix should be negotiated on a site by site basis with each case being treated on its merits having regard to Council’s objective for providing affordable housing based on an up to date Housing Needs Assessment.

The proposed split reflects London Plan and Council policy. However, it will be possible to review proposals on a site by site basis taking into account AAP objectives

AAP includes policy on affordable housing but allow for flexibility in application taking into account London Plan and AAP objectives

RPO41 Olivia Fawkes

Site K- concern about noise at night from people visiting cinema and restaurants. Newbury St a residential Road- unless hours of residential parking increased, risk of on street parking at night. Objection to restaurants having extended hours. Need to consider design and size of replacement car park to limit impacts on Newbury Road residents. Site J- 5-10 years is too long to wait for new station at Bromley South- existing station ahs poor facilities- cannot use station because no pram access. Need to make improvements to station a priority and moved to Phase 1.

Measures will be taken to minimise impacts on residential amenity in design of development. Pedestrian access to cinema and restaurants will be from High St. Parking to be provided on Site K Council will promote improved accessibility for all users to Bromley South Station in particular step free access. Bromley South Station is one of forty stations recently identified for inclusion on the DfT funded Access for All scheme programme. Network Rail will carry out a feasibility study for the station over the next 18 months to establish what improvements need to be made, before upgrading the station.

AAP promotes improvements to station as part of proposals for Site J. Improvements to Bromley South Station proposed to commence in Phase 1 AAP includes development guidelines for Site K

RPO43 Mr & Mrs Dumville

Proposed restrictions on car movements along North side of Market Square should allow access for residents. Without this, congestion would increase on Swan Hill. Would welcome a light rail link to Grove Park and Lewisham to link with DLR and link to Bromley South from Bromley North. Concerned about impact of development fronting onto Martins Hill. Opposed to inappropriate commercial development in Martins Hill area- should be an open space for benefit of residents will be met with major opposition. Not opposed to relocation of leisure centre within town centre but concerned that sports facilities may be withdrawn because funds unavailable to rebuild existing centre following closure. Need to ensure that new facilities available before existing centre closed. Appendix 4- questioned reference to lack of high quality development frontage to Martins Hill- Martins Hill is an area

Emphasis is being placed on improving the pedestrian environment. Full account will be taken of local access for residents. Potential for improvements to transit systems linking from Bromley South to Bromley north and beyond but this could take many forms e.g. extension of the Croydon Tramlink or DLR or a new transit system linking with park and ride sites. Options need to be considered as part of a longer term study

Reference to improvements to transit systems linking from Bromley South to Bromley North and beyond

for informal recreation and leisure although there is evidence of illegal/ anti-social behaviour - would support promotion of part of Martins Hill as nature reserve. Pleased that St Pauls square deleted from redevelopment area.

RPO44 Chris Glover, The Churchill Theatre

Support proposals for Site N and G- encourages restaurants/ cafes around theatre to keep High Street alive after 6 pm- this will increase footfall and make Churchill Theatre more attractive to older customers. Will contribute to a safer, more secure and vibrant town centre. A closer/ more welcoming car park would encourage customers to spend their evenings in Bromley rather than go to West End. The Hill and Pavilion car parks require patrons to walk along a quiet High St- a car park at site G with access to theatre through a more inviting restaurant/ café development would benefit town centre trade.

Preferred Options include new car park to serve Site G development.

AAP includes proposal for a new car park to serve Site G development.

RPO45 Gladys Edmonds

Criticised AAP for not making any provision for cyclists to reach the centre of town or to move from one side to other. More needs to be done to discourage people from using car to avoid increased congestion. Cycle facilities need to be implemented from outset- need to include cycle ways which link together to form network.

Initiatives for improving walking and cycling in Bromley town centre will be an important component of the Transport Strategy for the AAP. AAP will be more specific about planned cycle and walking improvements including new links and pedestrian crossings.

AAP includes policies for walking and cycling as part of Transport Strategy.

RPO46 Norman Wells

Site A Timescale for Site A is too long. Respondent’s offices are within site and long time scale is impacting on general maintenance/ planning blight etc. Network Rail owns most of site and with prospective developers wish to develop site at earlier stage than 10-15 years shown in Phase 3. Charter Market is poor quality and compares unfavourably with other local markets. Needs to be substantially upgraded. Suggests that introduction of Farmers/ continental style Markets selling local produce could enhance attractions. Potential to resurrect Annual Fairs in

Timescales in Draft AAP are indicative. Council supports relocation or retention of Charter Market and promotion of market activities. Council supports retention of existing and development of town centre’s cultural offer

Timescale for development of Site A brought forward. Site D deleted from Draft AAP. Improvements promoted to enhance distinctive character of Bromley North Village. Site K proposed for mixed use development incorporating cinema

2012 using Charter granted by Henry VI to coincide with 150th anniversary of last time they were held. Site D In event of cinema being replaced by new cinema in Site K, an independent cinema would be suitable on the site and would fit with the ‘East Street Village’ concept. This would benefit from proximity to the Little Theatre and restaurants in Bromley North and offer greater variety to develop Bromley’s cultural offer/ encourage a better mix of night time uses which would appeal to all ages and reduce anti-social behaviour. Site K Need for different cinema offer to standard multi-plex- preference for smaller independent cinemas serving local communities. Supports principles set out in Plan to make Bromley a more attractive centre to visit- but detail needs clarification with greater emphasis on cultural facilities that promotes diversity and inclusion and provides a wider mix of uses.

RPO47 Georgie Cook, Thames Water

No references to utility infrastructure needs in terms of water and waste water which is essential to any development. AAP needs to consider the net increase in water and waste water demand to serve the proposal as well as off site impacts in order to avoid no/ low water pressure and external/ internal sewage flooding of properties. Recommended that consideration be given to whether the following can be met:

• demand for water supply network infrastructure both on and off site;.

• demand for sewage network infrastructure both on and off site;

The SA encourages the minimisation of the use of water to enable residential developments to meet the higher levels of the Code for Sustainable Homes. Development proposals will be required to consider if the demand for water supply network infrastructure both on and off site for the development sites can be met

SA addresses the main issues raised. The AAP will require development proposals to address the net increase in water and waste water demand required to serve the proposal. Developers will be required to consider off site impacts to ensure no/ low water pressure and external/ internal sewage flooding of properties is to be avoided. The AAP will require new developments to consider the demand placed on the

• drainage and flood risk of the proposed development both on and off site.

sewage network infrastructure both on and off site and how this can be met. The AAP will ensure that new developments consider the drainage and flood risk of the development both on and off site. The AAP will promote greywater recycling and rainwater harvesting in new developments.

RP048 Siobhan Pender (Resident Bromley Gardens)

Need to embrace idea of urban living with a village feel- Council must encourage and help establish individuality within retail and café arena. Opportunity to designate areas which promote café culture for art and community spirit to flourish. Enjoyment of town centre limited by lack of good alternative restaurants and ‘yob culture’. Reference to Northcote Road Battersea as good model- village atmosphere and range of independent shops. Potential to promote Bromley as area with a lot to offer people without children- support for art gallery and venue for book launches etc.

Council seeks to enhance character and attractiveness of town centre as a place to live and enhanced provision of cafes and cultural provision.

Policies promote mixed uses and new cultural and leisure facilities and residential development in town centre.

RPO49 Mr Mortimer (resident of Ringers Road)

Concerned about lack of information about potential CPO in next 5 years- Request for details of compensation and CPO appeal procedures.

Council will manage any CPO process to minimise blight and ensure property owners fully consulted and receive appropriate compensation

RPO50 Pierre Appleby (BBRAG)

Concerned about proposals to discourage car usage and impact on retailers/ businesses. Support for more consideration to be given to cycling as a sustainable mode of transport for shoppers, commuters and school children. Expressed disappointment that cycle routes have not been given greater consideration in the AAP. Need to create new cycle facilities/ routes. Need for solution to ‘out of town’ traffic problem to encourage businesses to locate in Bromley. Support for widening of A21- over reliance has been placed on falling traffic counts which may not continue. Need to improve road accessibility. Need to consider park and ride- to south, west and east to reduce congestion at peak times. Proposed mitigation measures will not solve approach road congestion and are a disincentive to expansion of the town.

A balanced strategy is proposed which provides for necessary parking and promotes increased use of public transport and sustainable transport. The SA promotes the inclusion of cycle routes and facilities in new developments and throughout the town centre as part off mitigation measures. Council developing a comprehensive transport strategy to support AAP

AAP includes policies to promote pedestrian and cycle links and connectivity throughout the town centre as part of a comprehensive transport strategy AAP includes transport proposals

Increased parking tariffs will discourage people from staying longer in town centre. Suggested cycle routes for pupils to get to local schools.

including park & ride provision in longer term

RPO51 Ms Musto Mr Brennan Ethelbert Close

Unaware of proposals affecting property- request details of the compensation code and to be kept up to date on progress of proposals.

Council will manage any CPO process to minimise blight and ensure property owners fully consulted and receive appropriate compensation.

RPO52 Peter Brown Ringers Road

Supports proposals to benefit local community- plans directly affect property and concerned that residents should be more involved as decisions are being processed. Request clarification of plans and details of the compensation code.


RP053 Edwin Thompson Clerk of Bromley Quaker Meeting/ Member Churches together in central Bromley

Pleased that revised Plan recognises part churches play in life and community of Bromley. Need to give more attention to quality of life- should not be overtaken by retail and commercial considerations. Need to make Bromley a place people will want to live.


AAP recognises importance of churches and need to make provision for churches affected by development in town centre

RPO54 Penny Read

Plans for Site D should not mean end for the cinema. Suggests live entertainment venue on Site C- comedy club or ice rink and facilities for younger people. Car park on Site D ugly but useful. Site N provides good opportunity to improve appearance of area- supports idea of town square with wider open space and links to library and theatre and Church House gardens. Site F- good opportunity to open gardens up to public- parks bring history of area to life and bring town to life- potential for linked walks

Council seeks to retain entertainment facilities in any new development Proposals for Site N and Site F seek to enhance environment of town centre and to improve access to open space

Site D deleted from Draft AAP AAP includes guidelines for development of Sites N and F including enhancement of public open spaces

RP055 Peter and Audrey Hallows

Concern about proposed closure and relocation of leisure centre- fear scenario whereby there will be a hiatus between closure and completion of new facility. Retail development at side of Glades will centralise provision in small area- consideration should be given to incorporation of retail space within redevelopment of southern end of High Street. More vibrant town centre should not be at cost of existing facilities.

Council will ensure that re-provision of leisure centre secured before development of Site E proceeds. Council seeks to extend retail offer to southern end of High Street

AAP requires relocation of leisure centre secured before development of Site E proceeds AAP proposes extension of primary retail frontage to south of High Street

RPO56 Steve Price, MyTime

Quality and fabric of the Pavilion has deteriorated- need to take decision on case for investment and improvement. Concern about potential impacts of proposals on leisure centre- most significant leisure centre benefiting from footfall generated by proximity to town centre shops and attractions. The Pavilion has aged badly and does not meet growth in demand for health and fitness- sports hall and squash courts underused. However, it still represents a major opportunity for improvement/ investment- would reposition the leisure offer to complement the retail offer and contribute to objective of a successful and vibrant town centre. Key concerns:

• Replacement site on Civic Centre too small to re-provide existing facilities (smaller pool and possible loss of sports hall)- would also result in loss of Grand Hall a venue for community activities and Adventure Kingdom;

• Implementation period of AAP is likely to prevent significant investment in the current centre until decision is made. Virtual planning blight on existing site.

Request Council to consider a commitment to endorse the continued provision of a public sector leisure facility within the town centre and to provide a replacement to the Pavilion before demolition of the current site.

A new sports/ leisure facility will have to be provided if the Pavilion is redeveloped. Preliminary feasibility work undertaken to establish capacity of Site F to accommodate new recreation centre Council will work with MyTime to ensure quality of provision maintained

AAP identifies requirement for provision of new leisure facility in event of development of Site E

RPO57 James Stevens, Home Builders Federation

Concern that not all of objectives pp 33-34 are deliverable and whether some might prove incompatible (creating an attractive, healthy and peaceful place to live while also reviving commercial, employment and entertainment uses in town centre. Unlikely any one developer will be able to deliver all the S106 obligations listed on p85-86 on a single scheme and therefore the way that the obligations are calculated must reflect the circumstances of the development site and its ability to absorb those costs. Developers need more certainty and it is essential that Council prioritises obligations and relate these to specific residential locations in the AAP. Calculation of potential health and education contributions must be related to evidence of actual need. This requires monitoring of capacity- report to Bromley Council dated 13 February 2007 reveals substantial existing capacity and calls for reduction in published admission numbers to reduce costs. This suggests little need for new education infrastructure to be built.

Council will seek appropriate level of contributions from all developments

Policies included in implementation section of AAP regarding developer contributions

RPO58 Ian Shrubsall, RPS for Invista Foundation Property (freeholder of 100-102 High St)

Seeking to purchase 104-108 High St Welcome identification of 100-108 High St for mixed use development- opportunity to redevelop site to create landmark building at important focal point adjacent to theatre and entrance to Church House Gardens: would form attractive and active corner to new town square. Objection to Site G on grounds of the ability of the proposal to be delivered and the potential blight that could occur as a result of the wording of the proposals. Table 7.1 Site G- Car parking, community and faith uses of the site should be considered as applying to those parts of the site where they are existing, or in the case of parking

AAP is being prepared in the context of serving the town centre as a whole not in a piecemeal way. In terms of transport, this relates to parking to serve linked trips within the town centre and also sustainable policies such as travel planning, again orientated towards a whole town centre approach. Comprehensive approach to redevelopment of Site G is required to deliver objectives of AAP and capacity for new retail development. Feasibility work indicates Site G development can be delivered. Council will manage any CPO

AAP promotes a comprehensive Transport Strategy. Policy for development of Site G will require re-provision of community and faith uses and improved linkages to open space.

where required to serve new development. Linkages to public open space should not be a requirement for all parts of site. Welcome potential for taller buildings but reference to comprehensive approach needs to be clarified to prevent situation where Site G in multiple uses and tenancies will not otherwise come forward for development if it had to be assembled as a single ownership and development site. CPO should not be used if objective can be achieved in another way. Masterplan should allow individual parcels to come forward on a phase by phase basis to achieve deliverability and recognise individual property rights. Piecemeal development can be avoided by setting policy objectives for wider area. Propose new wording: ‘A comprehensive concept is proposed for Site G to which all individual parcels of land within Site G must comply in order to ensure the objectives for Site G are met. For the avoidance of doubt, development proposals for Site G will not be permitted unless they can demonstrate how they contribute to meeting the overall objectives for Site G and that they avoid prejudicing the subsequent development of adjacent land and other elements of the Site G proposals’. Accept that reference to ‘linkages/ integration with Park and Site N’ are necessary but clarification is required that proposals do not have to be delivered in a single phase or ownership with Site N, but that they should be complimentary and link to Site N and the park and allow for that development, but not be contingent on it, or required to deliver it. Welcome indicative floor areas for retail but caution that flexibility should be allowed for residential development as this is the most suitable use for the upper floors. Inappropriate to cap development at a level less than would make best use of site- priority should be given to achieving

process to minimise blight and ensure property owners fully consulted and receive appropriate compensation.

higher densities on sustainable town centre sites. Object to indicative timescale for development of Site G as Phase 2 for 5-10 years. Site is physically capable of development within Phase 1- no sound reason to delay positive regeneration/ development which can take place on phased basis. Object to statement that use of CPO will be necessary to promote comprehensive development- comprehensive approach can be achieved by individual parcels coming forward in a coordinated and complimentary way. Requirement for CPO will lead to planning blight and a disincentive to landowners bringing forward proposals. CPO will delay regeneration. Request meeting to discuss proposals.

RPO59 Katy Noseda-Vennard

Concern about development of Westmoreland Road Car Park- not in best interests of community:

• Need for Car park which is always in full use. If size of car park reduced, increased demand for parking and detrimental impact on residential roads. Existing lack of parking in area will be compounded by development;

• Existing cinema could be improved- no need for another cinema;

• Increased noise pollution and rubbish and anti-social behaviour at night;

• Increased traffic; • Development will have detrimental effect on house

prices and impact on residential amenity; • No need for additional cafes/ restaurants given

existing provision.

Parking will be re-provided in Town Centre. Existing cinema does not meet requirements for entertainment provision in town centre

Policy for development of Site K to require provision of public parking. Requirement for high quality design and mitigation of impacts on existing residential amenity. Any reduction in public parking on Site K to be re-provided on Site G. Requirement for any proposals for reuse/ redevelopment of existing cinema to include entertainment/ leisure use

RPO60 Carolyn Elliott

As resident of Ravensbourne Road, considers proposals for Site G to represent very high density and will have big impact on local services- doctors (proposals for Site H (Phase 3) will be too late), primary schools, secondary

A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision and restraining parking where appropriate. A Parking Plan will

New development being taken forward under the AAP will require detailed transport assessments to ensure traffic impacts are acceptable. Residents

schools and drainage. Better solution for new department Store on old Army & navy Store site- would remove requirement to demolish TK Maxx and retail/ residential properties. Impact on existing residents due to potential CPO. Bromley’s attraction relates partly to traditional ‘old town style’ feel- should not be competing with Bluewater. Traffic around Bromley South is already heavy with significant congestion at Masons Hill junction. New 400 space car park will exacerbate problem and discourage people from coming into Bromley. Inadequate residents parking bays to serve Ravensbourne Road, Ringers Road and Ethelbert Road- residents have to find alternative parking a distance away in Zone C. Publicity material has not clearly stated the enormity of the plans- most people do not understand the scale of demolition planned. Need further clarification of proposals. Closure of the Pavilion will result in loss of only sports facility in area before new facility is provided on Civic Centre site. Limited facilities for young people- a period without leisure facilities in town centre is unacceptable.

be prepared including on-street parking provision. Development of Site G will be required to include provision for community facilities

Re-provision of leisure facilities will be secured Developers will be expected to contribute towards the necessary infrastructure requirements

parking permits will not be made available to residents of new development in Town Centre. Development of Site J Bromley South Station modified to exclude mixed use development over tracks.

RPO61 Tinklin Springall Solicitors

Concern that youth element getting out of control in town centre- need to liaise with police and bring zero tolerance policy into effect. Support wider extension of CCTV system. Support 3-4* hotel as part of redevelopment of Bromley South given lack of hotel facilities in area

Hotel development included in proposals for Site C and L

Policy included in AAP relating to safety and security and town centre management.

RPO62 T O Burrell

Provision of health and leisure facilities was a major factor in agreement to original development of the Glades. Demolition of existing provision needs special consideration.

Replacement sports/ leisure facility will be provided if the Pavilion is redeveloped.

AAP includes policy requiring re-provision of sports/ leisure facilities if The Pavilion is redeveloped. Site F

John Lewis do not wish to use site and justification for proposed new department store diminished. Smaller additional shops would not justify loss of leisure facility. New leisure centre on the Civic Centre site must contain at least a swimming pool of similar size and nature to existing pool and a gym. Opposed to any closure of leisure centre prior to new facility being provided. Commercial development must nor take precedence over health and fitness of borough residents.

identified as suitable site for new facility. Provision will need to be secured before development of existing leisure centre (Site E) commences

RPO63 Peter Faulkner

Welcomes amended proposals provide for inclusion of Churches but concerned that there is no guarantee that Salvation Army and Town Church will not be moved to another part of town. These churches are used by community throughout week. If churches are moved their value may be diminished. Transport policy is unrealistic- idea that increasing number of people living and working in town centre can be achieved without significant number of parking spaces is wrong- existing parking restrictions mean that people often go to Bluewater instead of Bromley. Inability to go along Widmore Road through Market square and down Church Road will add to high levels of traffic on Tweedy Road. Lower part of High Street should not be closed to cars. Concern that buses will not be allowed to stop outside Boots- if it is moved this will result in longer walk to the Glades- a problem for old people.

Council will ensure provision for existing faith uses as part of redevelopment of Site G Comprehensive transport strategy developed to support AAP.

AAP will include polices relating to transport measures to improve accessibility to town centre

RP064 Valerie Walford

Supports preservation of open space and proposals to retain and improve access to it. Concerned that transport will remain difficult- suggests that Christmas Park & ride facility should continue to operate on trail basis to assess whether it would be viable and efficient as a permanent service and reduce congestion in town centre.

Comments noted AAP includes transport strategy which identifies park & ride as longer term measure. AAP seeks to improve retail offer and new department stores

Concerned about decline in quality of retail offer and loss of department stores. Supports proposals to revitalise retail shopping in High Street. Supports continuing presence of Salvation Army in town centre- contributes to civic life and provides facilities such as youth clubs and play groups which could not easily continue if premises moved. Need for more facilities in area. Provision to meet faith needs is essential. Salvation Army could not contribute as effectively to community if it did not continue to occupy space within Site G. Significant amount of money invested by community in upgrading existing premises. Concerned that revised proposals for Site G only provide for developers to be requested to accommodate Salvation Army in redevelopment proposals- should be altered to ‘requirement’ to accommodate Salvation Army.

RPO65 Michael Fearn on behalf of Barclays Bank

Highlights need for more diverse range of activities within the town centre- 2004 Retail Study showed that banks and financial institutions under-represented in Bromley compared to national position- but no intention set out in document to review the extent of primary area or modify wording to bring UDP policies S1 and S10 into line with government policy. UDP policies state uses within Classes A2-A5 may be appropriate: Uses in Part A of Use Classes order are by definition appropriate in shopping frontages and should be permitted. Designations of primary and secondary frontages should be realistically defined having regard to rental levels and yields- unclear how these issues have been addressed. If Council intends continuing to promote this type of policy these issues need to be addressed.

Council seeks to extend retail and business opportunities in town centre

AAP includes policies to extend retail and business opportunities

RPO66 Rose Freeman, The Theatres Trust

Welcomes recognition that cultural and creative economy is an important contributor to Bromley’s economy. Support proposals for Site N to develop a cultural quarter and civic square in front of the Churchill Theatre and Library.

Comments noted AAP includes policies to promote cultural and creative economy

Balanced leisure scene will entertain and stimulate visitors, residents and local businesses- will enliven surrounding area in evening and provide regular custom for bars and restaurants outside normal working and shopping hours

RPO67 Charles Muriithi, Environment Agency

Development and Flood Risk Southern area of town centre south of railway designated as Flood Zone 3- 1% or greater chance of flooding in an y given year. PPS25 requires new development to be steered to areas at lowest probability of flooding by applying a ‘Sequential Test’. No evidence provided to indicate sequential test undertaken- uses defined as vulnerable development must not be permitted in area and options to remove highly vulnerable development from these areas should be considered. SFRA should inform the Sustainability Appraisal. At present AAP does not accord with guidance in PPS12 because of lack of robust evidence base relating to flood risk. Revised Preferred Options should be assessed on basis of flood risk issues. Proposed development in Southern Gateway may not be appropriate due to flood risk and further investigation required (Sites H, J and K). FRA must determine actual flood risk to these sites. Selection of preferred options sites for residential development after SFRA undertaken may identify more suitable areas for development. Town Centre constrained by predominantly manmade rivers and capacity of existing sewer and surface water systems. Robust approach needed to manage flood risk in future- balance must be struck between maintaining and supporting natural floodplains and reducing flood risk. SFRA must be done prior to Council progressing plan. Surface Water Food Risk London Plan SPG on Sustainable Planning and Construction states that development should use SUDS wherever practical (essential); achieve 50% attenuation of undeveloped site’s surface water runoff at peak times

Comments noted SFRA undertaken

SA has assessed potential impacts of development and proposed mitigation measures Policies included in AAP to address impacts of development Text amended to reflect comments

(essential); achieve 100% attenuation of undeveloped site’s surface water runoff at peak times (preferred). Drainage must be designed to cope appropriately with peak runoff rates and volumes and allow for climate change in accordance with increases in rainfall predicted and outlined in PPS25. Climate Change Need to integrate climate change considerations into all spatial planning- transport, housing, economic growth and regeneration, water supply and waste management- view from wider sustainability objectives not just reducing impacts of flooding. Need to consider mitigation and adaptation and opportunities for integration in spatial strategies should be maximised. Consider area’s vulnerability to climate change and implications for built development, infrastructure and services and biodiversity. New development should be avoided in areas with likely increased vulnerability to climate change. Council should require development proposals to take account of expected changes in local climate conditions by adaptation or flexibility to allow future adaptation. Information on measures should be submitted with an application. Council should require major developments to:

• Identify type of and extent of main changes expected in local climate throughout lifetime of proposed development;

• Identify potential impacts of changes on proposed development and its neighbours;

• Indicate ways in which proposed development design overcomes hazards and exploits opportunities whilst meeting other sustainable development criteria, particularly need to achieve overall reductions in greenhouse gas emissions.

Ground Water and Land Contamination

Areas of town centre designated within Groundwater Source Protection Zone- provides water for public supply and vulnerable to pollution such as site drainage. Within these areas pollution prevention measures must be followed in accordance with ‘Policy and Practice for Protection of Groundwater’. Only roof water must be discharged to ground within inner source protection zones. Where development is proposed on or near a site known or believed to be contaminated, a site assessment will be required to establish nature and extent of contamination prior to determining the application. Remediation must reduce risk to acceptable levels. Surface water runoff should be treated through a SUDS system to improve water quality eg: pervious paving, green roofs, bio retention, filtration, ponds and storm water wetlands. Open Spaces and Biodiversity Pleased to see most of biodiversity issues addressed- AAP an ideal opportunity for enhancement of low value conservation sites and to create and enhance ecological networks and improving and linking green spaces to local residents. Proposals for improvements to public realm welcomed- development provides opportunity for green spaces to become a major educational and community resource- new green grid style development, improved entrance ways and knowledge of parks, enhancement and extension of existing green spaces. Recommend increased environmental recreation in and around river corridors eg: increased access to fishing and environmental education. Potential to improve ecological value of green spaces by removing hard concrete edges along river corridors and replacing with natural planting. Council should require development proposals to include landscaping and other ecological features that contribute to protecting, managing

and enhancing local biodiversity- information must be submitted with applications. Applicants should appoint an ecologist to prepare appraisal of proposals and if appropriate a biodiversity action plan for site. Design and Construction Importance of design quality of buildings and public spaces and need to enhance local character and support local services. Well designed neighbourhood should be socially, economically and environmentally sustainable. Building Regs will require new homes to be zero carbon by 2016. Need to create multi-functional landscapes with opportunities for water and energy saving- neighbourhoods should be convenient and safe to walk or cycle to shops, schools and access to public transport with range of tenures and types of housing. Buildings must be located and designed to reduce flood risk over lifetime of development- 60 years for residential and 100 years for residential. Encourage green roofs and surface water storage to reduce flood risk. AAP should show how needs of disabled and older people would be met- design must be required to provide for inclusive access. Development Control Policies Need for strategic and detailed policies relating to flooding and climate change- representations include proposed policies on:

• flooding to reduce flood risk and ensure capacity of flood plain is preserved and where possible increased;

• Enhancement of River Ravensbourne including options to open culverts and restore sections of

river; • Recreational use of River Ravensbourne.

Greening New Development Encourage incorporation of green roofs in new developments. Energy Efficiency and Renewables AAP should ensure that a significant proportion of energy supply of new development is gained on-site and renewably and/ or from decentralised, renewable or low carbon energy supply and support use of renewables, CHP and bio fuels. It should promote the use of recycled building materials and materials with low embodied energy and promote retrofitting existing buildings to make them more energy efficient. Need to monitor performance. AAP offers opportunity to produce development with highest environmental standards and to achieve environmental protection and enhancement. Environment agency want to work with Council on best ways to manage and improve green infrastructure and achieve improved water and energy efficiency.

RPO68 John Sercombe

Proposals for development of Site G generally sensible but will have adverse impact on properties in Ethelbert Close. Initial plans for last UDP showed boundary of Town centre Conservation Area being extended to include wood but never implemented. Overriding concern relates to traffic management and impacts of additional parking and housing in town centre. Roads unable to cope with increased traffic- scale of development must be restricted or changes made to bottom of High Street eg: ban right turn from High Street into

Comments noted AAP sets out development guidelines for development of Site G to minimise impacts

Westmoreland Road for all traffic. RPO69 Maggie Gebbett

Request confirmation of proposals for the Pavilion and provision for new swimming pool and relocation of facilities in Pavilion. Expectation that there should be a swimming pool in town centre.

Development of Site E dependent on relocation of leisure centre

AAP includes policy for reprovision of leisure centre

RPO70 Deborah Stephens, on behalf of the Metropolitan Police

Need to ensure infrastructure and services are provided to support new and existing economic development and housing. MPA have a key role to play in ensuring safe places to live are created as part of a sustainable community. London Plan recognises importance of initiatives relating to policing and community safety and crime reduction in improving quality of life. Developments should be safe and secure taking into account objectives of Secure by Design, designing out Crime and Circular 5/94. Such a commitment should be secured as part of any planning consent relating to large scale development schemes. London Plan Policy 3A.14 recognises that provision of police facilities is a key aspect of the provision of social infrastructure. Needs of MPA should be expressed in AAP and proposed development should make appropriate provision towards policing. Para 3.2 – should include reference to the provision of appropriate levels of police facilities. Para 4.6 – include reference to police services in the range of public services and facilities required to provide a ‘good’ environment. Chapter 5- AAP should include community safety and policing initiatives. Welcome safer neighbourhood Panel initiative and role of town centre manager in monitoring Para 6.4 – should include specific reference to ‘Designing out Crime’ and ‘Secured by Design’ principles within the

Comments noted AAP includes policies to ensure new development supported by necessary infrastructure Text amended

underlying principles of the Spatial Strategy. Community facilities should include specific references to the police service. The MPA request the provision of police shops in relevant locations. This advice should be considered in connection with all relevant proposal sites including Sites A, D and G. Planning Obligations- The AAP should allow additional community service contributions to be negotiated across the town centre, including contributions towards community safety and policing initiatives in order to promote inclusive, healthy, safe and crime free communities.

RPO71 Neil Coe, Alexandra Residents Association

Scope of consultation was too restricted, poorly advertised and insufficiently detailed for full responses- many residents unaware of AAP. Explanation of options superficial and level of questions inadequate to judge proposals. Overall concept of long term plan to enhance town centre rather than allowing speculative development welcomed- but share concerns of Friends of Bromley Town Parks and Gardens and Heart of Bromley Residents association in respect of Sites C,D,F,G and L. Emphasis should be on quality rather than quantity of new retail offer, and diversity should be encouraged within the historic quarters of the town. Assumption that Bromley must compete with larger local shopping centres is not necessarily valid if the whole retail/ culture/ entertainment/ leisure experience is more pleasurable and convenient.

Council committed to full consultation in accordance with Statement of Community Involvement Comments noted

Policies included in AAP to ensure high quality of development and provision of balanced mix of uses

Support objective of creating a vibrant day and night culture and provision of selection of restaurants/ cafes, cultural activities, leisure and entertainment facilities to attract full range of residents and visitors throughout week and at weekends. Concern that the historical, architectural and cultural elements of the town centre are not given sufficient importance and consideration in the AAP. Heritage and parkland gives Bromley a distinct advantage over centres such as Bluewater, Lewisham and Croydon and this should be exploited to maximum. Proposals for the Civic Centre are vague and inconclusive, and do not address the isolated nature of the location. Council offices should be located in natural centre of town or link with main High Street, shopping centre and parks Reuse of Old Town Hall site for reception and council meetings would refocus town on North village which is currently underused. Transport of paramount importance to success of AAP- Bromley North station must be refurbished and connected properly to road network to redress inaccessibility of Bromley from north. The proposed new multiplex cinema will jeopardise the existing Odeon cinema which should be preserved as a historic building and amenity. Requirement to retain an art house cinema or other suitable converted public use should be a condition of granting consent for multiplex. Alternatively, Odeon should become centre of the multiplex and adjacent land subject of CPO for additional screens, café and car parking.

Proposal for tall buildings should be strongly resisted particularly adjacent to the proposed new and enhanced town squares and close to parkland in order to maintain an appropriate skyline, protect strategic views and avoid overshadowing of communal spaces. Success of AAP dependent on Bromley North station becoming a primary transport interchange and LB Bromley using land and buildings to create right opportunities for change. Increase in shopping not an essential requirement. Need correct balance of heritage, culture, leisure and entertainment to become a vibrant town centre. Current AAP too biased towards large scale development to detriment of enhancing the existing townscape and retaining local character. Consultation should be expanded to all Bromley residents and wider range of community groups and consultees such as English Heritage, CABE, SPAB and Advisory Panel for Conservation Areas. Success of town centre of importance to whole Borough.

RPO72 Nicola Davies, Palace View

Congestion only partly due to car ownership levels. Best way of tackling congestion is to influence how people choose to travel. Problems of non-permit holding vehicles parking in adjoining residential streets- need to review CPZ. Concern that no mention made of current education needs and provision. Problems of availability of primary school places close to town centre. Shortage of nursery and primary school places for people living close to town centre creating a need to travel by car. Need to address issue of primary and nursery school places if new residential

A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision and restraining parking where appropriate. Parking Plan to review on-street parking provision. Upgrading Bromley North and Bromley South stations is not purely to improve the environment of the stations and attract car drivers to take the train, but rather to improve the accessibility of the stations. Balanced mix of uses proposed to create vibrant

Policies included in AAP relating to parking and improvements to public transport as part of Transport Strategy. Policy to promote high quality development and safety and security. Requirement for provision of community infrastructure/ financial contributions to meet needs of proposed residential development.

development proposed. Upgrading of stations unlikely to influence choice of travel in favour of train and away from car. Key problem is decreasing capacity of trains at Bromley South and Grove Park for people using Bromley North shuttle. Mixed use development needs to be defined- town already offers mix of uses. Not necessary for every site to offer mix of uses. Residential above retail will still provide inactive frontage at night- will not necessarily result in good development and contribute to solving evening problems eg: perception of crime. Further pedestrianisation unlikely to increase public transport, walking and cycling. Parking charges need to discourage long stay parking- should only allowed at extreme north and south (Westmoreland Road and The Hill). Should be combined with park & ride to encourage long stay visitors to leave cars on edge of centre. More bus priority measures and cycle lanes on main approaches to town centre could encourage drivers to shift modes. Additional pedestrianisation could result in longer walking distances to public transport. 2500 residential units represents a significant increase – needed to kickstart regeneration and expansion of town centre but concern about associated parking provision, healthcare and education needs. Car free development in areas of high accessibility can work but need commitment of developers and council to secure car clubs. Housing strategy needs to have regard to actual number of car-free flats that can be accommodated rather than a %. Can range from car free at Bromley South to higher level of provision at edge of town centre.

town centre.

CPZ areas around town centre must be revised to ensure car free development does not give rise to on-street parking. Already demand for more GPs and dentists close to town centre- locating facilities as part of mixed use buildings close to rail stations would be beneficial to commuters and residents.

RPO73 TFL

Welcomed the revisions made to the preferred options. TfL supports the objectives, vision and key themes and will work with LB Bromley in developing proposals. AAP should contain a policy that encourages developers to submit transport assessments for major developments. Given high PTAL score and underutilisation of some car parks, parking standards should be further reduced. In order to further reduce travel by car, as much car free residential development as possible should be encouraged in the town centre. Freight policy based on Policy 3C.24 of the London Plan should be added to the AAP taking into account the sustainability aspects of freight and servicing. Opposed to bus routeing along the pedestrianised length of the High Street as this would disrupt well established pedestrian area and negate proposals to increase pedestrian priority. Need to address missing and poorly defined links within walking and cycling networks between town centre and public spaces and gardens to west. Welcome inclusion of a travel plan and other soft measures. In order to maximise benefits from soft measures and to reduce reliance on car a holistic approach covering the whole town centre should be developed. This would allow

Initiatives for improving walking and cycling in Bromley town centre will be an important component of the Transport Strategy for the AAP.

Add words in the AAP to reflect the importance of developers submitting transport assessments ‘taking account of TfL TA Best Practice Guidance’. The AAP will reinforce that it supports car free residential development and will be looking at significantly reducing levels of residential parking in the AAP area. A section on freight will be included in the AAP Account taken of TfL views on bus routing. AAP includes specific policies relating to planned cycle and walking improvements including new links and pedestrian crossings. A town centre wide travel plan approach is proposed within the AAP for Bromley Town Centre.

for coordination of measures Suggested that plans to provide cycle parking facilities on Site A as a way of encouraging sustainable modes should be extended to cycle parking provision throughout the town centre and particularly the High Street. Expressed concern regarding the proposal for additional car parking on Site G given that current car parks are under utilised and it is in a location where car free development should be progressed.

A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision and restraining parking where appropriate. A Parking Strategy will be looking at on-street parking provision. Parking for Site G should be taken in context of the town centre wide strategy for parking, which looks to manage parking in order to support the increase in retail provision.

RPO74 Denis Wilson Partnership

Support development of Bromley North Station site- compliant with PPG13. Site can be more intensively developed as a main transport hub given its key location in town centre. Agree in principle with approach to transport assessment based on application of trip rate relating to car parking spaces rather than gross floor area but comments that new floorspace will attract some new primary shopping trips. However, it would be but wrong to assume that all new trips would be new trips and some allowance for linked trips should be made. In addition, maximum car parking provision has been applied in locations with high accessibility level 6a where some reduction in maximum standards would normally be expected. Emphasis placed on retail floorspace and modelling outputs could impact on any proposals to increase other land uses in town centre eg: more residential space. The traffic modelling shows adverse impacts on southern approached to town- due to focus on retail development, even the lowest increase in space would require substantial mitigation measures. Allowance for greater mix of uses may have beneficial effects. Case for reducing parking for residential development can equally apply to other forms of development. Potential car

The AAP supports pedestrian linkages across the A21 and improvements to the bus interchange at Bromley North Station. The transport impacts of increased residential units on Site A will need to be considered as part of a detailed transport assessment for that site alongside other planning implications. The AAP does not require any change to the number of car parking spaces provided on Site A. Proposals for how the existing quantum of parking is maintained can be a matter for consideration at detailed planning stage.

Amendments to proposals and design guidance for Site A

use associated with non-retail development may not be at peak times and impacts may not be significant. Need for equitable apportionment of car parking depending on quantum and type of development- should not penalise one type of development whilst allowing another to have higher levels of provision which may result in congestion on wider network. Support improvements to Bromley North Station as part of major redevelopment and potential for Bromley transit route. Need to consider frequency and demand for service to ensure it would not impact on other services. Many may chose to walk given distances and opportunity to visit shops on route. Question whether link would be well used given number of shoppers arriving by train compared to buses. Support improved crossing facilities in vicinity of station. Question phasing. Good case can be made for earlier development of schemes that will bring forward infrastructure improvements such as Bromley North. Concern that Bromley North site identified as cause of delays- development should be encouraged given high accessibility and public transport improvements. Consistent with policy to increase level of development at Bromley North (in particular residential). An increase to 400 residential units would result in small increase in traffic. Possible to introduce some signal control on Tweedy Road at Mitchell Way junction- would allow a pedestrian/ cycle phase to allow pedestrians to cross in one continuous movement and permit right turn onto Tweedy Road. This would reduce traffic movements through residential areas to north and allow buses to head north west from new bus interchange. Proposed development would not preclude future transit route between Bromley North and Bromley south.

RPO75 Lennon Planning on behalf of Linden Homes

Support high density mixed use redevelopment of Site A in line with general aims of Revised Preferred Options subject to following representations: • Amend reference to parking provision in a multi-storey

car park or decked parking to provide flexibility; • Amend site boundary to include properties facing

Sherman Road (6-12 Sherman Road) and Bromley North Clinic. Amend reference to possible redevelopment of clinic- ‘while there is no need at present to replace this facility, this building has been included within the site to allow for the potential enhancement of health facilities in this area should circumstances change’;

• AAP should recognise that higher density residential development may be necessary to cross subsidise other improvements sought by AAP. Scheme of 250 units would have a density of approximately 95 units per hectare- London Plan density matrix states that development in this location should have a density of between 240-435 units per hectare. Density should be amended in accordance with London Plan standards;

• Development of Site A should be brought forward from Phase 3 to Phase 2. Site will not be delivered in Phase 1.

Linden Homes control 6-8 Sherman Road and are in discussions with Network Rail about working together to deliver site development. An indicative masterplan has been prepared for Site A to illustrate comprehensive redevelopment of Bromley North to provide a sustainable residential community with associated improvements to transport infrastructure, provision of additional commercial space, community facilities and improved public realm. Rear of site proposed for residential with front part developed for a mix of uses including a bus interchange, refurbished station buildings, community uses and enhanced public

Council would wish to work with land owners and developers to secure redevelopment of Site A and improvements to station and public transport interchange

Proposals for Site A amended to incorporate changes to development mix and phasing

realm. Key components comprise

• 400 residential units (35% affordable) • 2,000 sq m commercial (excluding retained office

buildings and including 700 sq m A3/A5 uses within retained station buildings)

• 450 sq m community (health/ dentist) • 260 residential parking spaces (0.65 space/ unit) • Replacement of public parking (330 spaces)

Increase in residential units from 250 to 400 units would be consistent with principles of PPS1 and PPg13 which seek to make the most efficient use of land will not result in any significant increase in traffic. Maximum height of residential buildings 7 storeys in middle of site- least sensitive in terms of adjoining uses. Multi-storey carpark proposed in centre of site to be wrapped by residential and commercial frontage with direct link to improved bus interchange. Creation of new public space between existing and proposed station buildings provides opportunity for enhancement and relocation of Charter Market to more prominent location. Masterplan provides a safeguarded route for potential transit scheme- would facilitate the conversion of existing heavy rail services from Bromley North to Grove Park to light rail (tram or guided bus) and extension of route south to Bromley South station via the North Village and High Street.

RPO76 London Fire & Emergency Planning

Concerned that no mention is made to locally listed fire station and that no provision is made for an alternative and suitable site for a new fire station to replace Bromley fire

AAP seeks to protect and enhance heritage of town centre and historic buildings.

Policy refers to links between future development proposals and maintaining community safety.

Authority station. Seek support for a suitable site or building to be acknowledged and identified within the Borough for a new fire station facility. Bromley fire station contributes to Conservation Area but is not suited to current operational requirements- requires modernisation but is constrained by local listing. Seek support for: • demolition of fire station and new and modern facility

which is fully fit for purpose on existing site; • Relocation of fire station to adjacent car park site owned

by Bromley Council; • Provision for new fire station at one of proposal sites

identified as being suitable for development. Current location is optimum to provide fire cover. Authority has made commitment to provide an equitable fire and rescuie service. Location of fire station provides effective coverage for the local area based on risk profile of Borough. Unlikely that an alternative location away from present location will provide Borough with fire coverage as effective as that provided in current location. Extensive site search has failed to identify any suitable site alternatives except for car park site owned by Bromley Council. If car park site to be disposed of on open market, careful consideration must be given to potential impact on essential services that could be provided by fire station in this location. Financial contributions towards improving and expanding current fire services and facilities should be identified in policy on Section 106 requirements from development schemes. Need to consider capacity of key emergency services to improve community safety and maintain a speed of emergency response in line with LFPA standards.

No site identified as suitable for relocation of Fire Station in Town Centre. Council will work with LFPA to identify suitable site elsewhere in Borough in event of decision being taken to relocate existing facility. Redevelopment of existing site will be subject to policies in AAP.

Policy on design of new development to include requirement to design out risks from fire, especially in residential accommodation. Planning applications required to achieve high standards of fire safety; the close monitoring of building sites during construction.

Future growth within Borough will create additional risks from fire and other emergencies. Future policies should mention the links between future development proposals and maintaining community safety. Policies should address the need to grasp opportunities offered by new development to designing out risks from fire particularly in residential accommodation- includes giving consideration to installing hard wired smoke alarms and sprinkler systems where risks justify it. Efforts to reduce crime such as arson through good design should be promoted.

RPO77 Cecilia Yardley, Bromley United Reformed Church

Commented that a ‘weekday environment’ that caters for those who work in Bromley is important. Commented positively that faith groups have been acknowledged in the AAP. Commented that faith groups would benefit from expansion of premises and increased access to parking spaces after shopping hours.

AAP will seek upgrading of existing car parking provision throughout Bromley Town Centre to provide a better quality and safer environment both in the day and evening periods.

Inclusion of appropriate policies

RPO78 LXB Properties Ltd

LXB supports proposals for sites G,H and N in terms of mix of uses but there is an opportunity and requirement to increase residential content on these sites. This is consistent with increasing emphasis being put on need to deliver housing to meet housing demand and support evening economy and prevent anti-social behaviour. More residential development is necessary to support retail improvements. Scale of retail improvements is not commercially viable without additional residential development. Proposed amendments: • Sites G,H and N to be amalgamated and shown as one

large site for comprehensive development- should include Habitat shop and car park and upper terrace of Church House Gardens.

• Extend primary retail frontage along length of Site H; • Number of residential units should be increased from 500

Council seeks to work with landowners and developers to secure regeneration of western side of High Street and comprehensive development of Site G to accommodate capacity for retail development and to improve offer of town centre

Proposals for Site G amended to ensure scheme delivery and high design quality and mitigation of impacts on existing amenity and wider town centre.

to 1200 units; • Office uses should be included; • Community uses including faith uses should be

accommodated within the redevelopment area or relocated;

• Use of tall buildings should be supported subject to high quality design;

• Allow safeguarding routes at vital junctions- along front of the Liverpool Victoria building to increase capacity and A21 masons Hill between Kentish Way and B265 intersection as proposed in adopted UDP.

• AAP should set standards for parking in town centre RPO79 GVA Grimley on behalf of St James Investments

Previous preferred options identified Site D as suitable for mixed use development comprising residential and retail including a large foodstore- support recognition of area’s potential to meet identified requirements. Support principle of mixed use for Site D but considers the proposals to reduce the site area and other constraints are likely to prejudice the prospects for securing a viable mixed use development. Site D is one of the few opportunities for retail and residential development which is needed to maintain and enhance Bromley’s role as a metropolitan town centre. Reduction in Site D and constraints on scale of development may result in loss of opportunity for comprehensive regeneration - as a consequence, this will undermine the prospects for new investment in the area. There is significant capacity and quantitative and qualitative need for a large new foodstore. Highway consultants do not consider traffic analysis represents a clear justification for imposing constraints on size of store likely to be appropriate on Site D. Therefore inappropriate to impose a precise ‘cap’ on size of foodstore- contrary to wider development plan aspirations to maximise retail investment. Detailed matters

Modelling work done to date has suggested that it would be inappropriate to have a large new foodstore on Site D because of likely traffic congestion on Beckenham Lane and London Road. If there are proposals for such a development this would need to be supported by detailed traffic analysis as part of a planning application at a later stage. Land excluded from Site G because it is unavailable for development within Plan period. Remaining site area inadequate for comprehensive development. Inclusion of Site P addresses possible demand for additional convenience floorspace.

Site D excluded from AAP due to reduction in site area. Development to be considered in context fo other policies in AAP and proposals for North Village Improvement Area.

such as parking and highway capacity are more appropriately dealt with at planning application stage or through detailed development brief and or SPD. This would provide opportunity to take a more comprehensive approach to Site D and North Village. Clients would like to work with council to develop a comprehensive masterplan.

RPO80 Doug Black, Bromley Civic Society

College Green would benefit from public footpath from corner of College Slip to Gordon way- to create pedestrian route from tweedy Road to town centre Proposed leisure facilities must be more than just pubs- need greater provision of leisure facilities especially for youth Use of Bromley Little Theatre as Theatre should be protected in AAP. AAP lacks strategy for built heritage- Council should produce conservation area appraisal to inform implementation of AAP proposals Concerned about design quality- especially signage and shop fronts. Need to improve town centre with emphasis on quality. Bromley North Village area should be made an area of Special Signage Control Housing on west St and North St should be subject to Article 4 Direction to prevent unsympathetic change. Development briefs should be prepared for each site so local groups can contribute Concerned that AAP must integrate better with ‘Building a better Bromley’ especially in relation to commitment to children and young people, access to Council services, well being/ health and improving public realm/ environment.

Comments noted. Council committed to enhancing town centre appearance and character. Redevelopment is required to meet objectives of AAP. Site A- requirement for relocation or reprovision of market Site B- development will be required to respect setting of Bromley College Site C- there is no requirement for civic use of former town hall. A suitable use of the listed building will be secured. Site F- no loss of existing parkland will be permitted. Site G- comprehensive development required to secure regeneration and delivery of benefits. Site K- need for improved entertainment facilities identified through consultation. Sites M, N and P will be subject to requirement to respect and enhance character of surrounding area and open spaces.

Policies included to protect end enhance appearance of town centre and setting of historic buildings and conservation area. Site D- site to be deleted due to unavailability of land for development. Requirement for incorporation of leisure use in event of building no longer being used as cinema. Reprovision of leisure centre must be secured prior to redevelopment of Site E Boundary of Site J amended to exclude HG Wells building.

Site A- Retention/ improvement of market in central Bromley Site B- concern that increased densities will result in tall development that will harm Bromley College (Grade 1 Listed) and views in and out of the Conservation Area. Development should be kept low. Public sculpture for open space at corner would be a more appropriate gateway than a tall building. Family housing inappropriate due to busy road. Site C- need to resist loss of historic features and overdevelopment. Building should be returned to civic use Site D- Object to demolition of existing historic buildings fronting High Street- Odeon cinema makes positive contribution to townscape and is worthy of retention. If no longer used as cinema should be designated for entertainment, sports or leisure use. Development must respect setting of and views from Masons Hill. No objection to good infill development which respects conservation area Site E- essential to retain a leisure centre accessible to all- existing site benefits from collocation with retail centre- very accessible. Relocation to Civic Centre would be less convenient and disincentive for many. Redevelopment should not increase height or bulk of building and impact on Queen’s Gardens- overshadowing/ loss of sunlight. Quality of development to be in keeping with Glades architecture and Queens Gardens. Need to protect Bromley Oak. Site F- no objection in principle to demolition of modern buildings but concerned about loss of parkland and inappropriate new development. Concern about overdevelopment Any development must respect historic, social and environmental value of parkland. New development should be confined to footprint of existing buildings to north and north west of site and landscape reinstated to south with removal of existing buildings- would reinstate visual relationship between listed folly on Rafford Way and Palace. Concern about loss of community facilities if civic centre

moves. Site G- object to demolition of residential properties in Ethelbert Close. Any new development must be sympathetic to local context of conservation area including views from Church House Gardens and Library Gardens. Development must not turn its back on Gardens, cause overshadowing or detract from its character- concern that site proposed for tall buildings. Northern part of site in Conservation Area contains buildings which contribute to its character- demolition of these buildings will be resisted. Buildings added to conservation area by Council in 1991 because of their contribution to traditional character of High Street. Nos 72-82 (corner of Ethelbert Road) and 84 are good examples of their type. Ravensfell House is a historic building- could be restored as part of a new civic space. Semi-rural character of views from across the Shortlands Valley and impact on High Street frontage need to be considered in design of new buildings. Portico of Bromley Church in Ethelbert Road dates from 18th century and should be retained- reused on site in 1930. Site H- No objection subject to securing good design Site J- No objection in principle but HG Wells Centre provides an important community role and facility must be retained in some form. New development should introduce greenery and better public spaces. Site K- essential that town retains a cinema but a greater variety of facilities should be provided: consideration should be given to using site for leisure facility not already provided by cinemas in Bromley and Beckenham- both will be lost with no net gain in leisure variety if Site K developed as currently proposed. Site L- no objection to sympathetic replacement of DHSS building. Site M- no objection to enhancement of this part of Glades building if it reinforces the garden character and does not require additional building/ hard standing in Queens

Gardens or lead to loss of trees/ landscape features. Site N- welcome principle of town square and improved environment- consideration should be given to microclimate: central library causes wind tunnel which makes forecourt unpleasant on windy days. Would wish to see Ravensfell House on High Street retained along with some of neighbours that make a positive contribution. Unwilling to see loss of any trees or landscaping in Church House Gardens to accommodate development. Greenery should extend to High Street. Consideration should be given to making area around the theatre/ High Street safer and more vibrant in the evening. Council could lead way by introducing a new arts centre or cultural facility into shop units below library tower. Site P- aspirations of AAP could lead to over-development. Semi-rural character of College Slip should be preserved and enhanced. New development should retain the public art panels on Sainsburys and respond to historic context behind High Street and address access yard on West Street. Rear views of historic buildings and trees make a positive contribution to conservation area and setting of listed building. Housing on west Street adjoining site must be protected.

RPO81 Highways Agency

Supports proposals to focus employment and retail development in town centre and high density mixed use development which should reduce need to travel but concerned about scale of retail development and proposed mitigation measures. Supports Objective 2 to extend range and quality of facilities and services: this will reduce need to travel by car by location of community facilities in locations with high levels of public transport accessibility. Recommended that Objective 8 should also seek to reduce dependence on the car for town centre residents and visitors. This would encourage transport strategy to focus on improvements to sustainable modes of transport. HA is concerned that despite identified impacts, the AAP is still proposing a very high level of retail development supported by widening of A21 and sustainable transport initiatives put forward by the Transport Strategy. The HA is concerned that widening of the A21 could increase car trip generation associated with town centre and traffic impact on the SRN. Focus of the Transport Strategy should be on capacity enhancements. LDF should incorporate policy mechanisms to minimise demand at source and seek to encourage a modal shift. HA would support bus priority measures on A21 south of Bromley. Presumption should be to give preference to solutions other than new road capacity to accommodate new development. Transport Strategy should seek to implement a full range of sustainable transport initiatives in preference to widening of A21. If the Borough pursues the widening of the A21 further modelling may be required to assess the potential impact of increased impact on the SRN (M25 Junction 4). Such

Comments noted. A comprehensive transport strategy has been prepared to support the AAP.

AAP includes policies on transport and implementation of comprehensive programme of measures to accommodate proposed development.

modelling would help to ensure that the plan meets with PPS12 Test of Soundness. Concerned that consideration has not been given to the wider traffic impacts of development in the town centre. Objective 3 should be updated to state: ‘ to not significantly increase in the overall level of traffic that needs to be accommodated on the highway network within the town centre and on the wider Strategic Road Network’. Supports inclusion of suite of soft measures including workplace and school travel plans, personalised travel planning and car clubs. Recommends that all developments should be required to produce a travel plan to ensure that combined impacts are adequately mitigated. Clear guidance should be given as to when travel plan required and expected content- could be in AAP or Planning Obligations SPD providing the SPD adopted alongside the AAP. Content should be based on latest government guidance. Supports town centre wide travel plan including existing and new businesses. Supports proposals to improve public transport and interchanges- improved bus links to Bromley North and Bromley South Stations will increase viability of public transport. HA supports improvements to walking and cycling. Supports use of parking policies to promote sustainable transport choices- increased parking charges including levy on business parking permits, car free and low car housing and establishment of Controlled Parking Zones. AAP should include maps of proposed extensions for increasing coverage of CPZs.

HA recommends that whilst maximum standards should be set for private parking (based on London Plan) policy statements should clarify that opportunities to reduce parking below these levels should be sought. Existing businesses should be encouraged to reduce dependence on car as part of town-centre wide transport plan. HA would expect a robust assessment to be carried out to identify the deliverability of park and ride sites should the Council wish to push forward this policy. Transport modelling may be necessary within the LDF process. This would be required in support of the inclusion of these sites in the site-specific allocations- would expect a reduction in town centre parking to support the strategy. Strategic Delivery Plan- who is responsible for funding/ delivery of strategy and how public transport improvements will be phased should be brought forward as part of emerging AAP. Development should not take place at a faster rate than provision of related sustainable transport initiatives to ensure maximum uptake of sustainable transport alternatives. Plan policies may be dependent on key infrastructure being delivered. HA would be supportive of early guidance to developers at pre-application stage to allow required infrastructure to be implemented within an appropriate timeframe. In order to ensure that traffic impacts of AAp and success of transport strategy are adequately monitored, HA would request that following indicators are monitored through SA or Strategy Delivery Plan:

• Level of growth of traffic on key routes • Proportion of new development which is meeting

travel plan objectives Targets should be set to provide benchmarks that Plan will aim to achieve. Travel plans will be a way of monitoring development transport impacts. Town centre wide Travel Plan could form basis for monitoring new and existing developments.

RPO82 Turley Associates on behalf of Sainsbury’s Supermarkets Ltd

Pleased that Sainsburys Store identified as Site P to allow for reconfiguration of store and car park. Request following changes:

• Development Options for Site P should refer to a replacement or extension to the food retail.

• Development Principles should refer to: Creation of active frontage to the store on West Street, where practical.

• In terms of the proposed residential element, the Council should remove reference to the number of units, as it is too prescriptive. The number of units on the site will need to be considered as part of the detailed design process, and the Council will have the opportunity to consider proposals as part of the application process.

• Given the importance of the Sainsbury’s store in providing a foodstore anchor for the Town Centre, the Secondary Frontage should be extended along the west side of West Street and take in the existing frontage of the Sainsbury’s Store (fronting the store car park ).

Comments noted. It is necessary to indicate likely capacity of site for residential development to understand cumulative impacts of development. The figures are however indicative and will be subject to determination at planning application stage.

AAP provides guidance on development of Site P and recognises importance of site within Bromley North and contribution to overall retail offer.

RPO83 Graham Snewin, Northpoint Residents

Residents of Northpoint and other residential blocks in area have not been directly consulted with on AAP. Ward’s Safer Neighbourhoods Panel was not included in consultation exercise- an important omission given importance of urban design in crime prevention and fear of crime. Brief should include reference to need for any development proposals to incorporate and fund appropriate crime prevention measures. Any proposals should be subject of full consultation with Safer Neighbourhoods Panel and Police. Council should be more inclusive in consultation processes and ensure all relevant bodies and residents receive direct communication. . Welcome general regeneration proposals for the area, particularly around Bromley North station. But reserve position on any specific proposals when these come forward fro planning consent. Northpoint residents oppose the prospect of Bromley North station having a vehicular access onto Sherman Road- will result in increased traffic and would be unacceptable on highway safety grounds. Vehicular access to station should be from west side of station.

Details of site access will take into account impact on the local environment and other crucial aspects such as safety. Council is committed to full consultation. All planning applications for sites identified in the AAP will be subject to full consultation.

Guidance provided on development of Site A but details are not fixed in AAP.

RPO84 Mark Wiltshire, Bromley Christian Centre

Requested that the removal of Bromley Christian Centre and St Marks School from Site L be re-examined given Church’s stated intention to redevelop site and uncertainty about school buildings. School should be designated as an opportunity site- would offer scope for comprehensive development.

Due to safeguarding for highway improvements, Council has reconsidered boundary of Site L to ensure it is of sufficient size for suitable redevelopment. School is a listed building and Council does not consider it provides opportunity for redevelopment. Future use of the building will be subject to planning policies.

Boundary of Site L amended to include Bromley Christian Centre.

RPO85 Miss Spratt & Mr Lidsey

Development of Site K must not be any higher than the existing car park and should be decreased to improve views from gardens and that it must not encroach any further on the surrounding housing ie: no closer or higher than existing car park. Development should be visually appealing with the opportunity to develop landmark buildings in keeping with local heritage/ unique. There should be no increase in noise pollution or traffic to Newbury Road and no overlooking the residents of Newbury Road from the new development. Developing Site K could be attractive but concerned about possible height, encroachment and visual impact.

Comments noted. Council will seek a high standard of design and to minimise impacts of development on existing residential amenity.

AAP provides guidance on development of Site L and policies on design and height of buildings.

RPO86 Simon Robbins, Bromley PCT

Proposed options and proposals include residential developments of 1600 units, which will increase demand for primary and community health services in the area. Current primary and community health services are at or close to full capacity, and would therefore be unable to meet the needs of additional residents from their current premises. Estimated that an additional 2-3 whole time GPs would be required together with associated primary and community healthcare. PCT are committed to ensuring that health services are delivered from modern, fit for purpose premises, and need to work with LBB to ensure that this can be achieved as part of the AAP.

Council will seek to secure provision for necessary community infrastructure. Sites identified for future provision and Developers will be required to make an appropriate contribution to provision of facilities.

AAP includes policy requirement to make provision for additional and suitable social and community infrastructure to meet needs of increasing town centre population

RPO87 David Hammond, Natural England

Welcomes reference to protection and enhancement of environmental value of area (para 1.8). Broadly supports strategic objectives Key issues identified in para 3.2 make no specific mention of green/ open spaces- should be identified as a key issues and linked to objectives. AAP should highlight opportunity to improve open space surrounding Bromley College as a public open space. Lack of accessibility, poor animation and fragmentation of open spaces together with lack of linkages to each other is a key issue to be highlighted in AAP. Soft measures in para 6.16 are welcomed and broadly supported in context of transport initiatives. Welcomes any initiatives to promote and increase take up of public transport. De-culverting of River Ravensbourne and potential for biodiversity enhancement is encouraged. Site M- should give consideration to enhancing and improving ecological value of area not just economic/ amenity value. This would link in with overall feeling that area’s green spaces are fragmented, under utilised and lack animation. Improvements to overall variety and condition of sites could provide animation and help increase biodiversity potential. Implementation and delivery- support indicator relating to contribution to enhancement of biodiversity (para 8.15) PPS9- Biodiversity needs to be more explicitly referenced in

Council seeks improvement of green / open spaces, as well as promotion of linkages and accessibility throughout the town centre.

AAP makes reference to protection, promotion, enhancement and active promotion of green / open spaces including potential to enhance the open space surrounding Bromley College. Vision for the town centre revised to emphasise the environmental aspects of improvements and enhancements. Reference to need to consider de-culverting the Ravensbourne where feasible in Monitoring and Mitigation section of the SA. Site M- reference included to enhancing and improving the ecological value of the area as well as it’s economic value. Need to repair fragmentation between the town centre’s green / open spaces reinforced. Policies to promote sustainable development including improved green / open space and linkages between. Policy to address poor accessibility throughout the town centre and encourage softer measures such as car clubs and travel plans as part of comprehensive Transport Strategy..

Action Plan- need to state that improvements to green/open spaces need to include environmental enhancement as well as amenity and economic value. Action Plan an ideal opportunity to address fragmentation of open spaces and lack of animation. Sustainability Appraisal- support reference to green roofs and Sustainable Urban drainage Systems- Council should also give consideration to brown roofs and green walls to link with PPS9. Need to consult Greenspace Information for London (GIGL) for records of biodiversity data including statutory and non-statutory sites and habitat locations.

RPO88 Capital Shopping Centres

AAP must address failure of town centre to deliver significant new retail space since The Glades opened. AAP must identify how amount, range and quality of retail offer can be secured to maintain its competitiveness. Support extension of Glades and relocation of leisure centre to accommodate new retail floorspace. Object to deletion of extension to the car park at Bromley Civic as result of traffic modelling. Increased retail floorspace will give rise to increased usage and pressure on existing parking. Support public transport improvements but this needs to be complemented by an ample supply of parking to ensure that high levels of parking do not impede accessibility into town centre. Supports timescale for extension of The Glades. Extension of car parking should be reinstated in Site F. Supports use of Queens Gardens for open space and public realm improvements but need more flexibility for The Glades to respond to changing retail and commercial needs. Allocation should recognise that there may be justification for incursion into public space subject to mitigation eg: replacement open space or enhancement of existing areas.

A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision and restraining parking where appropriate. A Parking Plan will be looking at both off-street and on-street parking provision. It would be inappropriate to have a major expansion of car parking due to the traffic impacts. A balanced approach is being adopted as part a comprehensive transport strategy.

Development of Site E moved to Phase 3 to secure relocation of leisure centre and to ensure transport impacts can be accommodated as part of comprehensive strategy.

Development must be phased in relation to retail needs- failure to do this may result in less favourable sites coming forward for development in advance of those that best satisfy policy requirements. Welcome identification of Site E in Phase 1- can meet retail needs to 2012.

RPO89 Daniel Meades

Town centre is too linear and lacks a heart. Unclear from the proposals what the plan is for the North End of Market Square. Need to remove heavy traffic and address dangerous vehicle access to Church Road and Glassmill Lane. Need more choice in small independent shops. Support for public art to reflect Bromley’s past literary and historic culture and a good modern public building eg: a sports centre resulting from a competition. Early improvements to Bromley South Station and relocated post office are early priorities. Need to address poor quality environment and improved quality of retail offer.

Objective 8 of the AAP states, ‘Improving transport and accessibility and encouraging use of more sustainable modes of transport’. The AAP seeks to improve pedestrian safety and accessibility within the town centre and detailed proposals. Council places importance on improvement to public transport facilities and will work with Network Rail to secure improvements to Bromley North and South Stations.

Inclusion of policies on transport and accessibility, range of retail, incorporation of public art and high design quality. AAP seeks to secure improvements to station interchanges and provides guidance on this.

RPO90 Mick Lane, Crime Prevention design Advisor, Metropolitan Police

AAP should include a policy around security with designing out crime with respect to new developments and those which may be altered. All new development should be designed to meet the requirements of the Secure By Design scheme. Should a large development be proposed including associated car parking, car parks should be designed to meet a Safer Parking accreditation. This will achieve a consistency in safe, secure and sustainable design and build rather than relying on individual design statements. Highlight importance of anti-terrorism measures, e.g. bollard

Council is committed to secure by design principles.

Requirements to meet Secure by Design included in policy.

installation and CCTV installation. RPO91 Major Andy Cox, Salvation Army

Wish to stay within Site G as part of development proposals- have been established on site for 68 years, easy access makes site convenient for people to use facilities, have recently invested over £200,000 in refurbishment of on-site café and shop. Need to be in heart of community. Request that as development of Site G takes place, developers will relocate the centre within area so as to retain high profile.

Comments noted Reference to requirement for re-provision of existing faith groups in development of Site G strengthened

RPO92 Richard T Marks, MSE Property

Expressed concern that the addition of 500,000 sq ft of retail space will have a detrimental impact on the secondary and fringe locations. Businesses on upper High St north of Market square are struggling and additional retail space (particularly A3) will exacerbate this).

Bromley has capacity for increased retail floorspace and the Council is required to demonstrate how this can be accommodated. A range of retail space is proposed.

Polices included for improvements to North Village and promotion of independent traders

RPO93 Chris Price, Network Rail

Residential potential of Site A is greater than 250 units. London plan density matrix suggests site could achieve density of 240-435 units/ ha in this location. Need to increase number of units to ensure viability and delivery of benefits identified in AAP. Reference to replacement public car parking on Site A should also include the replacement of station car parking. Site A area does not reflect the full extent of the land that may be required for a comprehensive development and that properties fronting onto Sherman Road should be incorporated into the site area. This will assist in providing station interchange facilities Support reference to creating a comprehensive scheme and the potential use of compulsory purchase powers, however the statement should also state that a phased approach to the comprehensive development is acceptable in the interests of flexibility of development. Commented that Network Rail believe that Site A should be developed within the next 5-10 years (Phase 2).

Comments noted. Council will work with Network Rail and developers to secure redevelopment of Site A including improvements to station. The transport impacts of increased residential units on Site A will be considered as part of a detailed transport assessment.

Reference included to requirement for comprehensive approach to development of Site A to secure comprehensive redevelopment and transport improvements. Reference to the replacement of public car parking includes the replacement of station car parking. Timescale for development of Site A brought forward to Phases 1/ 2. Mixed use development over railway removed from Site J due to uncertainty regarding viability and delivery.

Area included in Site J does not reflect the full development potential of the site (could include land shown in Site H). Support reference to creating a comprehensive scheme that comes forward in a phased manner. Welcome reference to the Town Centre Improvement Initiative and pooling of planning obligations eg: public transport. Hoped that Town Centre Improvement Initiative can help contribute to improvements to Bromley South and North Stations which will have significant benefits. AAP should make clear that proposals which directly provide public benefits at substantial cost to development will have these costs taken into account during Section 106 negotiations and will not be subject to normal requirements.

RPO94 Government Office for London

Queried whether key diagram would be included in AAP. Para 1.10 which states that policies in UDP can be saved for 3 years until 2009 -LPA can apply for extension of UDP policies after that time Cross reference to density location and parking matrix in UDP to avoid duplication (can exclude Table 2.1) Information in Table 2.21 incorrect- all UDP policies saved for 3 years from date of adoption. Welcome reference to sustainable Community Strategy. Welcome inclusion of ‘Context and Issues’- background information will provide more meaningful responses to consultation Question whether Strategic Flood Risk assessment be completed in time for findings to be taken into account prior to submitting AAP to Secretary of State.

Comments noted. The findings and recommendations of the final SFRA will be incorporated in the SA and AAP. Collaborative workshops, presentations and meetings were carried out at the Issues and Options Consultation stage. Proposals have been subject to discussion with TfL and other stakeholders. It is proposed that further discussion will take place to assist the revision of the document in preparation for the final draft of the AAP. Only non prescriptive references will be made for taller buildings as their specific heights will relate to the quality of the specific development. Each development will have to adhere to strict environmental assessments, including views analysis.

AAP text and tables amended to reflect comments. Vision for the Town Centre includes cross reference to SA and Sustainable Community Strategy References to taller buildings clarified in guidance on Sites G, K and A. Clarification of engagement of stakeholders including businesses and land owners. AAP includes risk assessment. Mixed use development in Site J deleted due to uncertainty about viability and delivery

Vision for Town Centre- should be cross referenced to Sustainability Appraisal and Sustainable Community Strategy. Has exploration of scenarios with stakeholders included initial Issues and Options Consultation stage. Would be helpful to cross reference preliminary Scenarios to sustainability Appraisal Transport Strategy- have proposals for network/ junction improvements and freight distribution been discussed with TfL in relation to feasibility and funding? Will there be any implications for taking forward AAP if any transport proposals do not go ahead? Need to clarify what Code for Sustainable Homes means. The potential for taller buildings is identified on Site G and Site J. Will there be a maximum height and what environmental considerations will they be subject to? Welcome inclusion of Table 7.1- would be useful to cross reference to Table 8.1 in relation to implementation and phasing. Need to clarify what work has been undertaken with local and key stakeholders and businesses in preparing AAP including Local Strategic partnership. Question whether the Council has cooperation of all local owner/ occupiers to take forward proposals. If not, will this prevent the regeneration of sites if CPO powers cannot be used. Would preferred options be flexible enough to cope with this and could alternative uses be provided? This relates to Tests of Soundness.

The process of producing the AAP has involved public engagement from the very earliest stages in accordance with the SCI. Consultation with a range of stakeholders occurred between May to September 2005. Further public consultation was held on the Preferred Options over a six week period commencing 13 January and ending 24 February 2006. Through workshops with key stakeholders and public consultation on the initial Preferred Options early in 2006 the Council has sought to hear the views of those with an interest in the town. The draft AAP will be accompanied by a report outlining details of the whole public consultation and engagement process which was undertaken during the preparation of the plan. The Council will undertake a feasibility study on future accommodation prior to proposals for redevelopment of Site F.

Site F highlights action to undertake feasibility Study to assess current and future requirements for civic accommodation, potential relocation of leisure facility and extent to which surplus land can be made available for low density residential development. Will this be completed before submission of AAP? Question how work is progressing with network Rail, landowners and developers to promote phased comprehensive scheme for Site J Welcome the inclusion of assessment of proposals against tests of soundness.

RP095 Mr G Faratro Capisano Restaurant Mr Hasip Surtex Textiles Care Centre

Strong objection to redevelopment of Westmoreland Road Car Park. Owners of family businesses in Simpsons Road which will be threatened with closure if site redeveloped. Council has advised that leases will not be renewed. Would like to be considered for possible relocation in mixed use redevelopment of site

Comments noted. Replacement of car park required as it is in poor state of repair. Redevelopment of site is required to take forward vision for town centre and to secure new facilities and regeneration. Proposed uses for Site G include cafes and restaurants. These premises would be available to the market.

No change

RPO96 Mr & Mrs Winter

Need to resist proposals to reduce or damage open spaces or affect public access- in particular the Civic Centre grounds and Bishop’s Palace. Bishops Palace should be developed as the Bromley Museum with surrounding gardens. Civic Centre grounds should not be developed for housing.

The vision of the AAP is to promote a distinctive centre with high quality public spaces. Improvements and enhancements to the public realm are proposed which will benefit the town centre.

References strengthened to protection and enhancement of open spaces

RP097 Religious Society of Friends

Welcomes provision for religious needs of faith community. Questions availability of sufficient car parking to meet needs of groups.

Public parking will be available for town centre uses as part of comprehensive transport strategy. Use of public transport will also be encouraged.

No change

RP098, Bromley Little Theatre

Planned development of theatre will add to contribution to achieving aims of AAP- should be explicitly recognised in AAP. Seek designation of Bromley Little Theatre as a theatre on the grounds that it has been a theatre for 70 years and forms part of town’s heritage. Will ensure a diverse range of activities and cultural and leisure facilities for planned population increase; management of evening economy to attract a wider range of visitors including families with children; extend range and quality of leisure and entertainment facilities; protect and enhance the heritage and distinctive character of the town centre, particularly North Village. Propose physical development of site to provide improved facilities: adding a studio to provide a third live theatre venue in town centre; training facilities; doubling of capacity and a community facility for arts and culture. Also propose to develop community arts and cultural programmes and to work with council to deliver Borough-wide initiatives such as arts festivals.

Comments noted. Council welcomes proposals to improve facilities and recognises important role played by Bromley Little Theatre in cultural and community life.

AAP includes policy relating to cultural and entertainment facilities and need to protect and enhance existing facilities. Specific reference included to importance of Bromley Little Theatre.

RP099 Friends of Bromley Towns and Gardens

Welcome value placed on historic environment and parks and gardens- however, heritage issues not addressed in any meaningful way. Economic strategy is at odds with Council’s statutory duty to preserve elements that contribute to character and appearance of town centre conservation area. AAP must address past damage caused by development. AAP is unbalanced and biased towards development and visitors- no concern for heritage and will result in loss of historic character of the town. Object to proposals for Site F- Proposals to sell off heritage sites such as Bishops Palace and park for housing to raise revenue and relocate the pavilion is unacceptable. Propose reinstatement of Listed palace building as central feature in restored parkland; cultural and leisure use and park status with full public access; visitor attraction. Object to proposals for Site B- will be harmful to setting of town centre conservation area and views of grade I Listed Bromley College. Wish to see green setting of Bromley College and building as landmark gateway to Bromley rather than a block of flats; landscaping of site to preserve open aspect into College Grounds; open up views of college facing Tweedy road; consider low scale development such as a nursery school- making use of open areas for play and allowing views to be preserved and enhanced. Object to Site G- any buildings on site taller than roof heights of houses in Ethelbert Close will be harmful to character and appearance of Library Gardens, Church House Gardens, Martins Hill and Queens mead and the High Street. Development will contravene Council’s statutory duty to preserve or enhance character or appearance of conservation area. Propose that historic open views from parks and gardens within conservation area should be

Comments noted. The vision of the AAP is to promote a distinctive centre with high quality public spaces. Improvements and enhancements to the public realm are proposed which will benefit the town centre. Open spaces will be protected and enhanced. Discussion taking place with Environment regarding culvert. No loss of existing parkland will be permitted in redevelopment of Site F and parkland will be available to public access. New developments will be required to contribute to open space and play provision and enhancements of existing facilities.

Guidelines for Sites B, F and G strengthened to highlight importance of protection and enhancement of open spaces, conservation area and setting of listed buildings.

retained with skyline of trees rather than urban development. Site M- no objection in principle to café/restaurant provision provided it does not encroach on garden with any permanent or semi-permanent structure. Opposed to any loss of green space. Any café use should be restricted to Glades terrace. Queens garden is a drinking control area- sale of alcohol must be prevented or restricted. Site E- design of building must complement the Garden and be of a height no greater than the pavilion to protect what remains of open aspect of garden. Bromley Oak must be preserved. Preservation of open aspect and sunlight on south side of garden must be preserved as part of essential character of conservation area. Site D-,opposed to further urbanisation of upper margin of Martins Hill- will result in loss of character and appearance. Site N- generally welcome proposals if they offer enhancement of Library gardens and no part of Gardens paved over and Ravensfell House retained to give heritage status to enlarged space Would like to see firm proposals for integration of town parks into social and commercial life of Bromley without detriment to their essential character and appearance and improved leisure facilities. Would like to see firm proposals for green linkages between town and parks including palace grounds with signage and landscaping. AAP should include recognition of value of restoring River Ravensbourne to a natural amenity

RP100 Sonia Whitaker

Concern about traffic congestion- many routes already subject to delays before new developments take place. Need to give traffic problems high priority.

Comments noted. The Council has prepared a comprehensive transport strategy which addresses issues of congestion and impacts of new development

AAP includes proposals for transport improvements to address congestion.

RPO101 Rob Cundy, Bromley Town Business Forum

General support but raised following concerns: • progress of the AAP should be made available to

the forum group, businesses and public. • Car parking is an issue- if new retailers are to be

introduced into the area there will be a significant increase in the number of staff and customers into the area. Need to increase number of car parking spaces including cheaper and more convenient park and ride facilities for staff thus freeing up spaces for customers

• Temporary/ interim car parking facilities should be made available before Westmoreland Road car park is demolished to ensure sufficient capacity is maintained.

• Ongoing work needed to encourage improvements to street scene, pavements and shop frontages, business and people needs to be constantly addressed, including street scene, pavements and shop fronts.

A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision. The Parking Plan considers both off-street and on-street parking provision and future park and ride initiatives. Temporary facilities will be provided during redevelopment of Westmoreland Road Car Park. Council is promoting improvements to street scene to create a more attractive business and retail environment. Consultation undertaken with local businesses

AAP includes proposals for transport improvements and comprehensive parking strategy

RPO104 A Sheppeck

Commented that the roads in and out of Bromley cannot cope with the current high-level of traffic, and will be far worse once redevelopment begins. Commented that Bromley is lacking some essential shops such as a drapers, hardware shop and butchers. Suggested that a commuter car park over the platforms at Bromley South would alleviate current parking problems.

The AAP is looking at transport provision in the town centre and how this can be taken forward in a holistic way through a transport strategy and parking plan. The AAP supports the use of sustainable modes of transport to encourage travel into the town centre by modes other than the car. A range of retail will be supported including independent traders.

AAP includes proposals for transport improvements and parking strategy Bromley North designated as Improvement Area to enhance environment for smaller retailers

RPO105 Rob Bristow

Concerned about mixed use proposals for Bromley North- may conflict with residential character of surrounding area. Plan needs to be more specific about location of uses and acknowledge the importance of safeguarding existing residents’ amenities. Commercial uses should be located adjacent to station. Questions need for more parking. Plan should specify that residential is preferred use. Should allow for residential on northern part of site to proceed in advance of southern part- not interdependent.

Comments noted Development guidelines included for Site A to ensure appropriate distribution of land uses and interface with adjoining residential areas. Residential mixed use development is proposed

RPO106 J R Goodman Property Consultants

Object to development of Site G: • Traffic congestion, parking and lack of space cause grid-

locking • Pollution and disturbance to residents during construction • Reduction in property value • Department stores extending down Ethelbert Road will be

too close to residents and cut in to the conservation area. • Delivery vehicles will cause disturbance to residents. • Proposals are over-ambitious • Lack of consultation

Comments noted. There has been widespread consultation on the preferred options and revised options. Comprehensive redevelopment of Site G considered to be necessary to accommodate retail requirements and to achieve regeneration of town centre. This could not be achieved by piecemeal development schemes

Development guidelines for Site G seek to protect residential amenity and set out requirements for transport improvements and other mitigation measures to minimise impacts

RPO107 Tamara Galloway, Green St Green Village Society

Expressed concern that the Civic Centre site may be sold off for residential development. Commented that the current Pavilion leisure centre should stay where it is. Commented that enlarging the Glades may have a detrimental impact on the rest of the High Street. Commented that a café or coffee house in the Queens Garden should be within the Glades building to avoiding eating up any of the garden space.

Redevelopment of Civic Centre site could include small element of lower density residential development. This will not be main use of site. There is a need to accommodate additional retail demand in town centre. Council seeks to enhance leisure facilities. New leisure centre would provide opportunity to meet current needs and would be as accessible as The Glades. No loss of garden will be permitted in Queens Garden

AAP includes guidelines for Opportunity Sites to address issues of leisure provision and protection of open space

RPO108 Simon Taylor, AtisReal

Welcome the amendments to Site L and exclusion of adjacent sites. No objection to indicative development areas for the purposes of calculating housing supply in the borough. Would oppose any restriction on development density on Site L which would be contrary to other policies in the UDP and AAP. Currently looking at scheme for 124 residential units and 90 bed hotel on grounds of design and viability. Opening the culvert of the River Ravensbourne would be inappropriate as it would sterilise parts of the town centre for future development. Expressed concern that there is a lack of clarity regarding necessary junction improvements and Section 106 contributions and would stress that every attempt should be made to prevent delays in development whilst necessary junction improvements are made.

Comments noted. The boundary of Site L has been amended due to need to accommodate transport safeguarding line. This has required inclusion of adjacent site to achieve suitable development area. The capacities shown in the AAP are indicative figures and will be subject to determination of planning application.

AAP includes proposals for transport improvements and developer contributions. Guidelines for development of Site L including need for FRA.

RPO109 Mrs Brodie

Expressed concern that the roads around Bromley will come to a standstill if all the AAP proposals go ahead. Commented that the town centre is too contained to allow for a new road system. Expressed concern that the local schools, hospitals and

Extensive traffic modelling has been undertaken for Bromley town centre to understand the impact of development on the town centre traffic flows.

AAP includes proposals for transport improvements and parking strategy

to demonstrate significant regard for historic environment assets impacted upon by the development. All listed buildings and their settings are expected to be protected and enhanced. The archaeological implications of any application will need to be fully assessed at pre-application stage and further archaeological advice sought from the Greater London Archaeological Service (GLAAS) at English Heritage.

• Include need for archaeological assessment at pre-application stage in proposed mitigation column

• Recommend adding Buildings at Risk to indicator column in Table 8.4.

Comments on AAP: • Refer to nationally and locally listed buildings. Concept of

historical development section would be better developed as a mini-characterisation of area. Need to provide greater sense of Bromley’s identity.

• Welcome historic assets map- but should include archaeological priority areas and scheduled monuments

• Include reference to need for full archaeological assessment at pre-application stage for sites involving historic assets

• Bromley North- include reference to need to avoid compromising legibility of listed building: benefits include protection and enhancement of historic environment (also Sites B and F)

• Protection and enhancement of historic environment should be a principle underpinning AAP

• Early consultation with English Heritage should form part of Actions column in table 8.1 for sites of historic importance (especially Sites A, B and F). Include reference to need for full archaeological assessment at pre-application stage

• Need to include PPG16 Archaeology in Appendix 2 • Welcome heritage statements under Design and

doctor’s surgeries would not be able to cope with the proposals. Commented that the junction at Hayes Lane/ Westmoreland Road is a dangerous area.

Council has prepared a comprehensive transport strategy including measures to address congestion.

RPO110 Claire Craig, English Heritage

Welcomes proposals to regenerate town centre- congratulates Borough on demonstrating a high level of awareness of need to protect and enhance historic environment. Specific points need strengthening in SA: • Historic environment objective in SA to be strengthened

by substituting ‘valued’ with ‘the’ • Adjust heading in SA from Design to Heritage and Design • Need to ensure consistency between SA and AAP

objectives- need to consider impact on cultural heritage as distinct from other aspects of built environment

• Does not concur with view on p29 that heritage protection and enhancement can conflict with principles for a vibrant centre- preservation of historic environment is a fundamental requirement for a vibrant centre- text should be amended

• Welcome recognition of heritage significance of North Village- would like to see same acknowledgement of heritage elements of Northern gateway site

• Would like to see heritage requirements specified at Bromley North station and Bromley Civic Centre

• Welcomes recognition of importance of setting of Bromley College and design considerations for Site B.

• Heritage considerations pivotal for Sites A,B, and F • Incorporation of Listed Station Building in site A will need

to avoid compromising its legibility. • Archaeology needs greater inclusion. Archaeological

implications need full assessment at pre-application stage and further advice can be given by Greater London Archaeological advisory Service at English Heritage. Particularly important for Sites B and F

• Revise para 8.1.8 Planning applications will be expected

Comments noted. SA strengthened to reflect comments. AAP policy and Guidelines for Opportunity Sites highlight need to protect and enhance historic environment and need for early consultation with English Heritage.

Conservation objectives but request that historic elements of public realm and environment be included in Appendix 4

RPO112 Tom Sharland, SUSTRANDS

Queried whether the proposals include any provisions for improving cycle facilities- in particular safe routes and parking. This would fit in with leisure objectives.

Council has prepared a comprehensive transport strategy including provision for cyclists.

AAP includes proposals for transport improvements including facilities for cycling

RPO113 Dennis Barkway

Need to give consideration to phasing and timescale for development. Need implementation plan to identify aspects in council’s control, those that require consent of others and those that are dependent on 3rd party investment. Council must commit itself to doing things that will help to achieve inward investment eg: park and ride. Need statement on when Council is prepared to use CPO powers Interesting debate to be had on location of new leisure centre and whether a town centre location is essential or Stockwell Close the best or adequate location

Park and ride has been put forward as an option within the transport strategy. The A21 has been included in the strategy as a priority for consideration. These issues will be considered in further detail in implementation of AAP

AAP includes policies on implementation and phasing.

RP114 Trustees of Bromley and Sheppards College

Object to Site B on grounds of impacts on Colleges. Segment of site on junction of Tweedy Road/ London road should be excluded- college enhances entry to town and development would close off views. Concerned about density- proposals should be considered on merits particularly where heritage sites are concerned. AAP should not specify number of units or density. Range should be 60-100 applying the SDS formula- would be lower if area reduced Density range is based on flatted development only- should be 25-100 units Concerned that AAP is being driven by Broomleigh proposals- should not defer to a particular developer. Shift in density supports concern that AAP is being tailored to suit

Comments noted. The number of units and density is indicative and will be determined at the planning application stage.

AAP includes development guidance for Site B to protect setting of historic buildings. A high quality design and development will be required.

specific development RP115 Mayor of London

Raises key issues to be addressed prior to submission: • Deliverability- clarification sought about how realistic it

will be to expect sites to be delivered within prescribed timescales especially with regard to amount of housing (specifically family housing). A number of sites have not been identified in the 2004 Housing Capacity Study and the evidence base for proposals must be substantiated more fully;

• Residential development- expected that any applications will meet Mayor’s target for affordable housing in levels of provision and tenure split. Questions raised about how children’s play space and other amenity space needed to support family housing will be accommodated in high density development.

Broad planning objectives heading towards conformity with London Plan but if issues not addressed this may lead to an opinion of non-conformity at submission stage. Supports intention to promote significant change and development in town centre in order for it to realise its full potential and provide a more attractive place to shop, work, live and visit. Promotion of variety of uses is welcomed. However, AAP still needs to demonstrate in more detail that the town centre has capacity to accommodate proposed uses. Should justify scale of increased retail floorspace proposed and any significant increases should be based on comprehensive assessment of retail need and capacity and tested sub-regionally through Sub-Regional Development Framework which has set a limit between 35,000- 51,000 sq m. Evidence base must show how much additional new floorspace is proposed and why the tested limit in SRDF should be exceeded.

Comments noted. The Council has addressed issues of deliverability in modifications to the preferred options. Comprehensive transport strategy seeks to address issues of congestion and promote public transport. Evidence base for retail development consistent with SRDF. Council concerned about protecting character of Bromley Town Centre with emphasis on maximising development potential of sites. Density of development must reflect character of surrounding area.

Policies included on housing mix and play provision. Sites which may be suitable for delivery of larger units suitable for family occupation identified. Policy included on improving use of energy in line with London Plan. Reference to local training included in potential Section 106 contributions.

Inclusion of a policy approach that seeks to maximise development potential of sites consistent with London Plan Policy 4B.3 would be welcomed. Key policy area relates to improving use of energy (London Plan Policy 4A.7). AAP will need to include policies that support relevant London Plan policies and require applications for major developments to include energy assessments as set out in London Plan Policy 4A.9. AAP will need to require major developments to provide for renewable energy (London Plan Policy 4A.10). LDA requests inclusion of employment and training for local people and creation of opportunities for local businesses especially SMEs and those owned by BAMEs to be included in list of potential Section 106 contributions. Tacking high levels of traffic congestion and improving image, accessibility and reliability of public transport is a fundamental issue. Supports partnership working with TfL and others.


APPENDIX 3.2:

AAP: PREFERRED OPTIONS (JANUARY-FEBRUARY 2006): REPORT TO COMMITTEE

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London Borough of Bromley

Report No. E&LS 06140

PART 1 - PUBLIC <Please select>

Agenda Item No. XX

Title: AREA ACTION PLAN FOR BROMLEY TOWN CENTRE -

RESULT OF CONSULTATION

Decision Maker: Development Control Committee Decision Date: 01 Apr 2006

Decision Type: Non-Urgent Non-Executive Non-Key

Budget/Policy Framework: Within policy and budget

Chief Officer: Chief Planner

Contact Officer: Rita Westlotorn, Head of Planning Project Management Tel: 020 8313 4582 E-Mail: [email protected] Frank Whiting, , Town Centre Project Director Tel: 020 8313 4847 E-mail: [email protected]

Ward: Bromley Town

1. SUMMARY

1.1 This feedback from the recent public consultation is part of the continuing process of developing a Bromley Town Centre Area Action Plan (BTCAAP) over the coming months and all comments made will be considered when finalising the draft Area Action Plan later in the year.

1.2 The public consultation on the Options for Bromley Town Centre has been one of the most comprehensive consultation exercises undertaken by the Council. There was good coverage in the local newspapers as well as prominent exhibitions in The Glades, the Central Library, the Adult Education Centre and the Civic Centre. Approximately 8,000 leaflets were distributed, along with flyers advertising the exhibition at the two railway stations, also individual letters were sent, or hand delivered, to around 600 other, statutory and non-statutory consultees as well as to town centre businesses and residents in the identified opportunity sites.

1.3 In all the Council received a response from 1420 individuals or companies and this is considered to be a reliable indication of public opinion. Of these, 1264 completed ‘freepost’ questionnaires, 57 were more detailed written responses, 74 questionnaires were completed on line together with a further 23 responses being made via the website specifically set up for the Action Plan plus 2 petitions from residents of Site D and G.

1.4 A summary of the responses made are attached as an Appendix to this report.

2. RECOMMENDATIONS

2.1 Members note the report.

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3. COMMENTARY

3.1 Members have recognised that Bromley Town Centre needs to evolve if it is to retain its competitive position and that is why the future vitality of Bromley and the borough’s other town centres is one of the Council's key priorities. It was, however, clear from the response that the town remains popular and well used.

3.2 Consultation was carried out over a six-week period commencing Friday 13th January 2006 and ending 24th February 2006. A staffed exhibition was held over three days in The Glades, after which a static exhibition, with leaflets, was placed in the Bromley Public Library, the Civic Centre Main Reception and at Bromley Adult Education Centre, Nightingale Lane. The consultation process also included other ways of inviting comment via the local press and online. All those who had previously been involved through the stakeholders workshops, including Members, were also invited to a presentation in January. Talks to interested groups have also taken place and these are on-going during the action plan process.

3.3 The findings from the consultation have been analysed in order to inform the next stage of the BTCAAP process. Highlighted below is a brief précis of the results and Appendix 1 gives a summary of the responses received.

• There was strong support for a new department store. Following the closure of Allders and the Army & Navy, the lack of a good department store was one of the main concerns raised by visitors to staff during the exhibition in The Glades.

• There was a high level of support given for new entertainment facilities, to include a new multiplex cinema and a wider range of cafes and restaurants.

• Whilst strong support was given to plans that will revitalize the town a clear majority wanted to see Bromley retain its character and heritage.

• Parking and congestion issues were raised by a number of people. However, with the exception of Bluewater, our car parking charges compare favourably with other centres although a Parking strategy will be produced as part of the AAP. This strategy will cover the management of the parking stock through various methods such as for example; Variable Message Signing (VMS), the number and quality of the spaces available and their use i.e whether long or short stay. Also Transport for London (TfL) have commissioned Hyder Consulting to build a micro simulation model of Bromley Town Centre so that various ideas for improving the road network can be tested. This traffic model is an extremely useful tool in that it enables the Council to test the sustainability, in terms of traffic implications, of the development proposals being considered as part of the AAP process. This includes possible changes to the A21, which forms part of the Transport for London Road Network, and borough roads within the town centre.

• Concern was raised regarding additional residential units in the town with some respondents citing the increase pressure on existing parking, and others questioning who would live in the units. However, mixed use schemes that include an element of residential development would give a better balance to the central area of the town. While the economic viability of the town is vital the AAP also needs to address how we can encourage sustainable communities. Such new housing opportunities could help meet the needs of those who have difficulties accessing work opportunities in the town. Also the possible number of new residential units will go some way to meet future housing supply within the Borough as indicated in the London Plan.

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• A considerable number of responses identified the benefits churches in the town can bring to the community. Within the document ecclesiastical buildings are brought together under the term ‘community uses’ and these have been identified on a number of opportunity sites. If a site were to be developed any such existing community use would have the right to be replaced on-site or be suitably located elsewhere.

• A high percentage of responses were received from the older age groups, reflecting somewhat the population of the Borough, and BR1, BR2 and BR3 residents formed the main bulk of those who responded (75.6%), confirming that those local to the town were aware of the consultation process. Responses were also received from people in Croydon, Dartford, Eltham and Tonbridge areas showing the extent to which visitors travel to the town.

3.4 There are only two opportunity sites where occupied residential property has been included, Sites D and G. Residents in both sites have petitioned the Council as part of the consultation process regarding the loss of their homes and concerns over future blight. Officers have had several meetings with people who live or own property in these areas, as well as with residents’ groups, to re-assure them and to discuss their concerns, as well as to give them information about the way compensation will be assessed if their property is purchased. If the development of these sites does proceed, the compensation code ensures that people being displaced receive market value and all other costs associated with their move. Owners also receive additional payments to reflect the compulsory nature of their move.

4. POLICY IMPLICATIONS

4.1 The AAP will be one of the Council’s first Development Plan Documents (DPD) under the new planning system, known as the Local Development Framework (LDF). As the AAP will constitute a DPD it would therefore be subject to independent examination in public as it will introduce new policies.

4.2 Any proposals for the town centre will have to take account of government policy, especially PPS6 – Planning for town Centres, as well as other relevant documents. Prior to the adoption of the AAP any new development proposal sites within the town centre that are not currently contained in the adopted UDP or 2nd Deposit draft UDP, are likely to be considered as ‘departures’ from the Plan and may therefore be referable to the Secretary of State. The current draft Unitary Development Plan (UDP) policies can be viewed on the Council’s website or at the Civic Centre or local libraries.

4.3 The DPD will list and specifically identify Opportunity Sites as well as key objectives and policies for the town centre. Bromley Town Centre is planned to be the subject of considerable development over the next 10 to 15 years, including providing substantial new housing, retail and leisure/recreational development. The extent of change envisaged makes it essential that a detailed and locationally specific planning document is in place to guide and manage future changes and to maximise the benefit derived from the expected development.

4.4 The advice the Council have received from DTZ and other property advisors involved in the AAP process is that there are over 100 major retailers and leisure operators who are looking to be represented in Bromley or if they are already here are looking for bigger or better premises. The main issue is that most of the shops that do become available are either in the wrong location or of the wrong size to satisfy very prescriptive market requirements. The number of interested retailers was obtained from a database that records expressions of interest directly from the operators.

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4.5 The work undertaken by DTZ prior to the Council embarking on the AAP included a substantial amount of research including household surveys both inside and outside the borough. This approach was essential and is indeed recommended as good practice, subsequent work on the AAP is to be based on independent and objective professional analysis by experts in the field, which is important when the draft AAP is tested at a public Inquiry.

5. FINANCIAL IMPLICATIONS

5.1 The opportunity sites that have been the subject of consultation are opportunities for private sector investment of the type that resulted in the provision of The Glades. While the Council may incur expenditure in assisting in site assembly it would only do so if it is assured that those costs will ultimately be met by the developer. There is also an opportunity for the Council to obtain capital receipts for the sale of its own land.

Non-Applicable Sections: LEGAL IMPLICATIONS PERSONNEL IMPLICATIONS

Background Documents: (Access via Contact Officer)

UDP Inspectors Report 2005 PPS6 ODPM March 2005 DTZ Retail Capacity Study 2004 Preferred Options Document January 2006


APPENDIX 4

REVISED PREFERRED OPTIONS (NOVEMBER 2007-JANUARY 2008): RESPONSES TO CONSULTATION

BROMLEY TOWN CENTRE AAP / SA – Responses to Comments Received Ref No & Name

Summary of Representation LBB Comments/Response Proposed Changes to Preferred Options and/or inclusions in AAP

RPO1 Barry Wooding

Commented that Bromley South station has no provision for wheelchair users, and that assurances need to be given to wheelchair users that when redeveloped the station will be fully accessible to the disabled.

Bromley South Station is one of forty stations recently identified for inclusion on the DfT’s Access for All scheme programme. This programme, funded by the DfT and implemented by Network Rail, sees the redevelopment of station infrastructure to provide step free access as well as other accessible facilities including improved lighting, hearing induction loops and passenger information schemes. Network Rail will carry out a feasibility study for the station over the next 18 months to establish what improvements need to be made, before upgrading the station between 2012 and 2015.

The AAP will include policy regarding inclusive design and accessibility. Development guidelines for Sites A and J will include requirement for access improvements to Bromley South and Bromley North railway stations.

RP02 Richard Evans Surrey County Council

No concerns over proposed revisions. Opportunity sites and proposals of local importance

No comment No changes

RPO3 A Eastwood

Commented on an area of the map on the Revised Preferred Options leaflet around Palace View as being grey, asking if there is planned development there. Insufficient weight given to views of immediate residents

No planned development- the graphics denote existing urban area Views of local residents taken into account through formal consultation on AAP

New development will be required to protect existing residential amenity and incorporate appropriate mitigation to minimise impacts

RPO4 Ray Watson Bromley Friends of the Earth

Expressed concern at the conflict between development of retail space and increasing traffic congestion. Mitigation measures and park and ride schemes will not solve problems and will shift congestion and parking issues to the suburban areas. Propose relocation of civic centre from central Bromley to reduce trips to town centre

The transport assessment and sustainability assessment both encourage the development of park and ride schemes and promote modal shift onto public transport that aims to reduce private car use. It is considered that these measures can address issues of congestion and make Bromley a more attractive retail centre. The AAP includes a parking strategy to

AAP to include Transport Strategy and policies to promote sustainable transport modes. AAP to include requirement for relocation of the Pavilion Leisure Centre within town centre if site redeveloped for retail uses.

RP06 Amanda Bradshaw The Local (Hayes Keston Bromley Common)

Requested press release/ information Information provided

RP07 Marie Neal Craft Jungle

Need for bus service, one way street system, 2 hour parking restriction and security cameras along Chatterton Road

Chatterton Road is outside of the Bromley Town centre AAP boundary. Comment passed to Transportation section.

RPO8 Ian Sutton Play Strategy Manager

Children’s play areas would be beneficial in attracting families to the town centre and would provide children with a safe place to play. Need for a family friendly town There is currently no space for disabled people and children Play facilities in Church House Gardens too far from town centre to enable use as part of shopping trip. Potential for play facilities in Queens Gardens. Need to secure free play provision and child friendly public art- climbable and playable Need for accessible space for voluntary sector to run play and activity sessions for children with additional needs- this could be taken into account in proposals for site D.

New development will be required to make provision for childrens play space to meet needs of new residents. Existing children’s play space in Church House Gardens and St Martins Hill will be improved.

Policy relating to provision of childrens play space to be included in AAP. The potential for incorporation of public art will be highlighted Policy on inclusive design and access to be included in AAP Requirement for community facilities to be provided as part of development of opportunity sites.

RP09 Steve Shippey

Request further information Information provided

RPO10 Steve Best

Town is unsafe for families in the evenings – need to ensure that more bars do not add to problems Facilities for teenagers should be incorporated into future redevelopments. Need to encourage small independent shops- becoming a clone town with limited unique shopping character

Importance is placed on safety and security and making the town centre a more attractive destination for all ages in the evenings. A range of retail uses will be promoted to enhance the town centre offer and reinforce Bromley’s distinctiveness

AAP will include policies on design and town centre management

Relocation of pavilion conflicts with need to encourage evening and night life in town centre and reduce use by shoppers using Glades; impact on health and potential loss of green space Impact of retail development on shops in Bromley South and local shopping centres Possible extension to The Glades could result in Queens Gardens being overshadowed- loss of open space due to new cafes Need to ensure no loss of open space or negative effects on biodiversity.

promote increased utilisation of existing parking. Relocation of the pavilion leisure centre proposed within town centre. The AAP includes proposals to promote evening economy. The town centre is considered the most suitable location for civic facilities given its high level of accessibility by public transport. Retail development is required to maintain Bromley’s status as a metropolitan centre. The town centre provides a different range of facilities in comparison to smaller centres and will not impact on the viability of local centres. The extension to the Glades will be subject to environmental assessment. Sensitive design will be required to minimise impacts on Queens Gardens.

RPO5 Bernadette Manning

Increased traffic flow into the town centre will need to be addressed, particularly through Beckenham Lane and Shortlands Village. Lack of traffic calming in Beckenham Lane will contribute to problems

Extensive traffic modelling has been undertaken for Bromley town centre to understand the impact of development on the town centre traffic flows and wider network. Mitigation measures, such as a town centre wide travel plan, improvements to public transport and the management of parking, will be in place to ensure traffic levels are kept at a manageable level throughout the town centre.

AAP will include provision for highway improvements outside town centre to address issues of congestion and increased traffic.

RPO11 Dick Groves Disability Voice Bromley

Developments need to take into account the needs of the local disabled residents. Bromley has one of worst records for disabled access and safety in London- less than 30% crossings in town centre have provision for visually impaired. Recent improvements unsatisfactory and dangerous Need for meaningful consultation regarding access for disabled persons

Importance placed on improving accessibility for all users and the promotion of fully accessible developments. The AAP seeks to create an accessible and inclusive town centre. The Council are committed to ensuring that a full and representative consultation takes place with all sectors of the community. We will ensure your comments are taken on board. The Council is undertaking an Equalities Impact Assessment (EqIA) as part of the AAP. Consultation will be undertaken with disability groups as part of the EqIA


RP012 Amanda Weston Bromley Police

General questions about AAP See RP70

See RP70 See RP70

RPO13 Vincent Stops, London Travel Watch

Improved permeability for cyclists and walkers is important- need for development to reduce barriers to pedestrians (particularly Kentish Way, one way streets and staggered pedestrian crossings from Bromley North to shopping areas). Kentish Way is often congested, and bus priority would be welcomed. Need for second accessible entrance to Bromley South Station from Kentish Way Town centre would benefit from the reinstallation of the market in a more accessible central location. AAP should promote a reduction in off-street parking. Support modal switch away from private car.

Initiatives for improving walking and cycling in Bromley town centre will be an important component of the Transport Strategy for the AAP. Planned cycle and walking improvements will include new links and pedestrian crossings. Consideration will be given to enhancing bus priority on the A21 (Kentish Way) as part of comprehensive transport strategy. Kentish Way is part of the TLRN for which TfL is the highway authority and Council will be investigating opportunities in conjunction with TfL. Network Rail are due to carry out a feasibility study on Bromley South Station over the next 18 months as part of the DfT Access for All scheme. This will establish what

Policies included in AAP to promote cycling and walking and improvements to public transport

improvements are needed for the station including the number and location of step free accesses. A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision and restraining parking where appropriate. Consideration is to be given to potential relocation of the Charter Market to the pedestrianised High St to provide improved accessibility and operation.

RPO14 Roger Bleach Telereal on behalf of BT

Support proposals to enhance economic and social vitality of town centre but asks for following to be taken into account:

• Bromley Telephone Exchange is operational • new technology has recently been installed to serve

future needs • BT has no plans to vacate the Telephone Exchange in

the foreseeable future • Relocation of Telephone Exchange would incur

substantial costs in terms of infrastructure and property.

Operational requirements of BT are noted. Proposals for development must be capable of delivery within timescale of the AAP.

In view of unavailability of Telephone Exchange for development, Site D is excluded from AAP because the site is considered too small to support a viable comprehensive redevelopment

RPO15 Linda Evans

Welcome proposals for regeneration and improved safety at night- may be assisted by housing in area. As a resident of Queens Road, concerned that access may be difficult after development and about increased traffic. May discourage people from shopping in town centre and disadvantage existing residents. Concern about costs of proposals and possible increase in Council Tax to pay for them.

No plans for altering the traffic flows in the Queens Road area, although the potential for improving the pedestrian environment is under review. The AAP seeks to improve Bromley Town Centre including how to bring it to life at night by improving the night time environment and improving safety issues.

AAP includes policies on design and town centre management which address issues of safety and security AAP includes a comprehensive transport strategy

RP016 Martin Helt

Request for information Information provided

RP017 Councillor Granger

Support relocation of Pavilion Leisure Centre Library and theatre should be located on periphery with access to parking Concern about impact of discouraging use of car on performance of town centre in relation to competitors- notably Bluewater with convenient access and free parking

Noted Development will be dependent on increased use of more sustainable transport modes but Transport Strategy will include measures for improvements to walking, cycling and public transport and a parking strategy which will seek to improve use of existing parking. New parking is proposed to serve proposed retail development Library and theatre will have improved access to parking


RP018 Tom Tucker

Concern about decline of town centre, loss of quality retail, environmental quality, night time safety issues, anti-social behaviour. Need to promote quality development

AAP seeks to address decline of town centre and provide a more vibrant and attractive centre.

AAP includes policies to improve the appearance of the town centre and promote high quality design in new development

RP019 S Sykes

Request for details of Compensation Code applicable to home owners in Ethelbert Road


RP20 Christine Diamond

Main concern relates to extended retail offer. Vital to have one or two department stores to compete with other towns. Preference for housing development closer to town centre rather than outlying areas.

AAP seeks to address decline of town centre and provide a more vibrant and attractive centre including provision for new department stores and town centre housing

Site L extended to ensure viable development can take place incorporating safeguarding requirements

Plan for next 5 years sensible- development of DHSS building for hotel/ residential uses supported and should be speeded up due to close proximity to rail links at Bromley South

Development of DHSS (Site L) in Phase 1 but needs to take into account safeguarding requirements for transport projects..

RPO21 Steve Dark, Bromley Fire Station

Need to establish whether existing site can meet LFEPA requirements. Charter Market site adjoining Bromley North Station may be a suitable location for a new fire station.

Council will work with LFEPA to identify suitable alternative site if relocation of fire station required in future. No suitable alternative site identified in Town Centre. Bromley North (Site A) identified for other uses to deliver transport improvements and mixed use development in accordance with London Plan. Development of Site C should take into account possible future redevelopment of fire station site,

Development guidelines for Site C highlight need to take into account possible future redevelopment of fire station site.

RPO22 D DasGupta, Adult and Community Services

Need to identify opportunities for meeting learning Disabilities needs through planned development. Concern about lack of parking spaces in Bromley Town Centre for minibuses, particularly for disabled users. This limits opportunities for adults with learning disabilities to integrate. Need for special facilities for disabled eg: changing facilities with hoists. Need to ensure town centre is inclusive.

An Equalities Impact Assessment (EqIA) is being undertaken.


RP023 Patrick Wall Bromley Court Hotel

Bromley Court Hotel already provides good conference/ hotel facilities- misleading to say Bromley does not have a quality hotel. Need to address the business sector to ensure hotels thrive. An additional hotel would dilute current business market between hotels. Bromley has a small business sector- limited number of medium to large companies. A lot of existing office space is empty- only one site identified for office space (Old Town Hall)- all other sites are for mixed use development including retail, leisure and residential. Need to place more emphasis on developing business sector and attracting business into Bromley. Concerned that hotel has not been consulted directly on market potential for another hotel.

The potential for additional hotel accommodation has been identified. This will enhance Bromley’s position as a metropolitan centre. AAP promotes improvements to existing business areas and protection of existing office accommodation

AAP includes policy on promotion of business sector and improvements to business areas

RPO24 Belinda Price

No requirement for new department store but town centre would benefit from multiplex cinema. Key issues relate to traffic and movement. Access to Bromley South station for those with wheelchairs or prams is very poor- needs to be addressed urgently. Bromley can only thrive when station is made more accessible- otherwise people will come by car leading to increased congestion and pressure on parking. Need to look at short term proposals to improve accessibility- cannot wait for development. Supports Bromley South as a transport interchange- could promote trains to Beckenham junction and links to tram. Need to give greater priority to public transport. Support for congestion charge at peak times. Concern about long walk from Kentish Way bus stop to Civic centre- suggests reception in the Glades

Requirement for new department store identified through market assessment. Site K has been identified for a multi-plex and interest has been shown from prospective developers. Both developments will enhance Bromley’s offer and position as a metropolitan centre. Redevelopment of stations will need to comply with DDA requirements, including wheelchair and pram access. AAP proposes improvements to Station in Phase 1. Transport Strategy is being developed to help improve highway movements and parking to ensure town is easier to navigate.

Improvements to stations proposed in Phase 1. AAP includes a comprehensive transport strategy including improvements to public transport facilities

RPO25 K Dumville

Concern about proposal to relocate the Pavilion to Civic Centre site:

• approval for Glades was granted with an undertaking that a leisure/ sports centre be built on the site for use by local residents. If the Pavilion facilities were withdrawn for any length of time while new sports centre constructed, this might have legal implications

• If Pavilion facilities withdrawn for any length of time, users of facilities might loose the impetus to exercise with impacts on health care. Withdrawal of sports facilities not an option even for a short period

• Many people use Pavilion and shop afterwards- loss of facilities will affect retail performance.

Need to ensure replacement sports facilities in place before Pavilion is closed.

An alternative sports/ leisure facility will have to be provided if the Pavilion is redeveloped. The civic centre has been identified as an appropriate site for a replacement improved leisure facility.

AAP includes a requirement for the relocation of the leisure facility

RP026 Tim Burrell

Queried size of proposed site for relocation of the pavilion- concerned it would not be large enough for swimming pool

Council considers proposed site to be of adequate size to accommodate requirements

RPO27 David Anderson

Concerned about lack of wheelchair/ pram access at Bromley South station. Need for lifts or escalators.

Redevelopment of stations will need to comply with DDA requirements, including wheelchair and pram access.

AAP policy requires access to stations to be improved and DDA compliant. Improvements to Bromley South proposed in Phase 1

RPO28 Glenis Ruston

Concerned that Pavilion facilities will be relocated Community use should include provision for art and culture. Support for independent shops

If site of Pavilion redeveloped, there will be a requirement to replace facilities within the town. The civic centre site has been identified as a suitable location. New facility will reflect changes in demand for leisure facilities and will be a modern facility which caters for needs and health of community. Community facilities identified as being important- Council seek to attract more live entertainment facilities into town. Bromley North seen as ideal area for independent retailers.

AAP includes a requirement for relocation of leisure facility Arts and culture promoted in AAP including public art, improvements to Churchill Theatre and Library and new public spaces

RPO29 David Corkrow

Queried the compensation code for Ethelbert Close residents.


RPO30 Mr James

Concerned about noise nuisance from existing pubs and clubs Expressed serious concern that a live music venue at Site D would cause further noise disturbance to residents.

Site D excluded. Future use of cinema will be subject to assessment of potential impacts on residential amenity.

RPO31 Nicholas Schoon

Supports proposals for new housing- should include significant proportion (25% or more) of family homes of 3 or more bedrooms, with local play areas and garden space. This will improve environment and design quality and encourage community engagement- improvements to security, privacy and amenity. Possible to build good family housing at medium to high densities. New development should reflect proximity to public transport- encourage walking, cycling and use of public transport and provide limited car parking.

The AAP identifies the need for mix of housing types including family housing. Community facilities including children’s play space and education facilities will be required to meet needs of new development. The increase in floorspace is a net increase on existing floorspace. The increase in retail floorspace meets requirements set out in the sub-regional strategy and the capacity identified

AAP includes policy to promote mix of housing types and tenure and associated community facilities.

Need to make clearer case for increase in retail floorspace- does this include space lost by closure of department stores. Emphasis should be on quality not quantity- significant increase in retail floorspace will increase traffic congestion and will not enhance competitiveness.

in the retail capacity study. Increase in retail floorspace and quality is required to enhance performance. It is recognised that retail development is dependent on a comprehensive transport strategy to address congestion and traffic impacts.

RP032 Adrian Tutchings Linays Commercial

Requested copy of brochure Information provided

RPO33 Mark Sansom Ringers Court Residents Association

Queried whether Ringers Court was within Site G and if so, why there had been no formal notification Queried details of compulsory purchase order/ compensation code.

Residents will be kept informed of AAP and any proposed changes. Details of CPO procedures will be made available at the appropriate time

RPO34 Michael Payne Babbacombe Road Residents Association

Site C- need to ensure any new build will reflect character of former town hall. Need to compensate for loss of car parking spaces Site P- site suitable for affordable housing. Development should include upgrading of Walters Yard and respect conservation area. Site A- development should preserve suburban character of area, improve transport interchange and safety and access. Local community must be fully consulted on development of site. Key concerns:

• Need to spread affordable housing between all sites

• Need to clarify existing parking • Need for improved access • Increased traffic • Development must complement character of

Station Road and Babbacombe Road • Impact of higher density development on water

resources and local neighbourhood • Existing PCT health facility is fit for purpose- further

clarification required of improved community and

AAP includes development guidelines development in keeping with character of surrounding area. Council policy to seek provision of affordable housing in all developments. Developers will be expected to contribute towards infrastructure requirements. Community will be fully consulted on development proposals

AAP includes development guidelines and policy framework for all proposal sites and town centre as a whole.

health facilities • Need for clarification of new transit system and

improved links with Bromley South station • Need clarification of proposals for improved or new

public open space • Need clarification of boundary changes

RPO35 Julia Stewart

Requested clarification regarding impacts of development of Site K and access to off street parking backing onto Simpsons Road.

Clarification provided. The culvert prevents development above it so the rear servicing road behind Newbury Road is left untouched

AAP provides development guidelines to minimise impacts of Site K on residential amenity.

RP036 B Jones and CM Ward

Pleased that St Paul’s Square removed from area for redevelopment but concerned about:

• Enhancement proposals for top end of Martins Hill • Traffic in Market Square- car journeys will be

increased without access through Market Square adding to congestion and pollution.

Site D excluded from AAP Comprehensive transport strategy to be prepared to address issues of access to town centre Martins Hill to be protected. Possible enhancements will include planting and promotion of biodiversity


RP037 Barbara Geere

Planned retail in Pavilion should be for quality department store Need for shops selling better quality goods More cultural activities required to raise Bromley’s profile in the arts- ideally a new arts centre and concert hall Need for more English style cafes

AAP seeks to improve town centre offer- better range and quality of retail and improved arts and culture offer. Emphasis on improving Churchill Theatre and existing facilities. No potential identified for new arts centre and concert hall

RP038 Christine Maddy

Lack of range and quality of restaurants in evenings People put off going to Bromley due to problems of young people/ binge drinking Need for department store- retail offer limited. Bromley becoming a clone town- lack of individual shops. Needs to be different to attract trade from Bluewater and Croydon and to retain high spending capacity within area.

AAP seeks to improve town centre offer and performance- better range and quality of retail and cafes/ restaurants. Objective to attract wider range of users in evenings and to enhance Bromley’s distinctiveness.

RPO39 Nigel Styles, Stylish Living

Freeholder of 10 Sherman Road adjoining Site A- preference for property to remain outside boundary of Site A to enable site to be redeveloped separately. No marriage value between property and Site A.

Comments noted. A comprehensive approach to development is proposed

No change

RPO40 Helen Booker, RPS on behalf of Fairview New Homes

Object to the requirement stated in paragraph 3.32 for a 70:30 split of social rented housing and intermediate housing within the 35% affordable housing provision. Affordable housing mix should be negotiated on a site by site basis with each case being treated on its merits having regard to Council’s objective for providing affordable housing based on an up to date Housing Needs Assessment.

The proposed split reflects London Plan and Council policy. However, it will be possible to review proposals on a site by site basis taking into account AAP objectives

AAP includes policy on affordable housing but allow for flexibility in application taking into account London Plan and AAP objectives

RPO41 Olivia Fawkes

Site K- concern about noise at night from people visiting cinema and restaurants. Newbury St a residential Road- unless hours of residential parking increased, risk of on street parking at night. Objection to restaurants having extended hours. Need to consider design and size of replacement car park to limit impacts on Newbury Road residents. Site J- 5-10 years is too long to wait for new station at Bromley South- existing station ahs poor facilities- cannot use station because no pram access. Need to make improvements to station a priority and moved to Phase 1.

Measures will be taken to minimise impacts on residential amenity in design of development. Pedestrian access to cinema and restaurants will be from High St. Parking to be provided on Site K Council will promote improved accessibility for all users to Bromley South Station in particular step free access. Bromley South Station is one of forty stations recently identified for inclusion on the DfT funded Access for All scheme programme. Network Rail will carry out a feasibility study for the station over the next 18 months to establish what improvements need to be made, before upgrading the station.

AAP promotes improvements to station as part of proposals for Site J. Improvements to Bromley South Station proposed to commence in Phase 1 AAP includes development guidelines for Site K

RPO43 Mr & Mrs Dumville

Proposed restrictions on car movements along North side of Market Square should allow access for residents. Without this, congestion would increase on Swan Hill. Would welcome a light rail link to Grove Park and Lewisham to link with DLR and link to Bromley South from Bromley North. Concerned about impact of development fronting onto Martins Hill. Opposed to inappropriate commercial development in Martins Hill area- should be an open space for benefit of residents will be met with major opposition. Not opposed to relocation of leisure centre within town centre but concerned that sports facilities may be withdrawn because funds unavailable to rebuild existing centre following closure. Need to ensure that new facilities available before existing centre closed. Appendix 4- questioned reference to lack of high quality development frontage to Martins Hill- Martins Hill is an area

Emphasis is being placed on improving the pedestrian environment. Full account will be taken of local access for residents. Potential for improvements to transit systems linking from Bromley South to Bromley north and beyond but this could take many forms e.g. extension of the Croydon Tramlink or DLR or a new transit system linking with park and ride sites. Options need to be considered as part of a longer term study

Reference to improvements to transit systems linking from Bromley South to Bromley North and beyond

for informal recreation and leisure although there is evidence of illegal/ anti-social behaviour - would support promotion of part of Martins Hill as nature reserve. Pleased that St Pauls square deleted from redevelopment area.

RPO44 Chris Glover, The Churchill Theatre

Support proposals for Site N and G- encourages restaurants/ cafes around theatre to keep High Street alive after 6 pm- this will increase footfall and make Churchill Theatre more attractive to older customers. Will contribute to a safer, more secure and vibrant town centre. A closer/ more welcoming car park would encourage customers to spend their evenings in Bromley rather than go to West End. The Hill and Pavilion car parks require patrons to walk along a quiet High St- a car park at site G with access to theatre through a more inviting restaurant/ café development would benefit town centre trade.

Preferred Options include new car park to serve Site G development.

AAP includes proposal for a new car park to serve Site G development.

RPO45 Gladys Edmonds

Criticised AAP for not making any provision for cyclists to reach the centre of town or to move from one side to other. More needs to be done to discourage people from using car to avoid increased congestion. Cycle facilities need to be implemented from outset- need to include cycle ways which link together to form network.

Initiatives for improving walking and cycling in Bromley town centre will be an important component of the Transport Strategy for the AAP. AAP will be more specific about planned cycle and walking improvements including new links and pedestrian crossings.

AAP includes policies for walking and cycling as part of Transport Strategy.

RPO46 Norman Wells

Site A Timescale for Site A is too long. Respondent’s offices are within site and long time scale is impacting on general maintenance/ planning blight etc. Network Rail owns most of site and with prospective developers wish to develop site at earlier stage than 10-15 years shown in Phase 3. Charter Market is poor quality and compares unfavourably with other local markets. Needs to be substantially upgraded. Suggests that introduction of Farmers/ continental style Markets selling local produce could enhance attractions. Potential to resurrect Annual Fairs in

Timescales in Draft AAP are indicative. Council supports relocation or retention of Charter Market and promotion of market activities. Council supports retention of existing and development of town centre’s cultural offer

Timescale for development of Site A brought forward. Site D deleted from Draft AAP. Improvements promoted to enhance distinctive character of Bromley North Village. Site K proposed for mixed use development incorporating cinema

2012 using Charter granted by Henry VI to coincide with 150th anniversary of last time they were held. Site D In event of cinema being replaced by new cinema in Site K, an independent cinema would be suitable on the site and would fit with the ‘East Street Village’ concept. This would benefit from proximity to the Little Theatre and restaurants in Bromley North and offer greater variety to develop Bromley’s cultural offer/ encourage a better mix of night time uses which would appeal to all ages and reduce anti-social behaviour. Site K Need for different cinema offer to standard multi-plex- preference for smaller independent cinemas serving local communities. Supports principles set out in Plan to make Bromley a more attractive centre to visit- but detail needs clarification with greater emphasis on cultural facilities that promotes diversity and inclusion and provides a wider mix of uses.

RPO47 Georgie Cook, Thames Water

No references to utility infrastructure needs in terms of water and waste water which is essential to any development. AAP needs to consider the net increase in water and waste water demand to serve the proposal as well as off site impacts in order to avoid no/ low water pressure and external/ internal sewage flooding of properties. Recommended that consideration be given to whether the following can be met:

• demand for water supply network infrastructure both on and off site;.

• demand for sewage network infrastructure both on and off site;

The SA encourages the minimisation of the use of water to enable residential developments to meet the higher levels of the Code for Sustainable Homes. Development proposals will be required to consider if the demand for water supply network infrastructure both on and off site for the development sites can be met

SA addresses the main issues raised. The AAP will require development proposals to address the net increase in water and waste water demand required to serve the proposal. Developers will be required to consider off site impacts to ensure no/ low water pressure and external/ internal sewage flooding of properties is to be avoided. The AAP will require new developments to consider the demand placed on the

• drainage and flood risk of the proposed development both on and off site.

sewage network infrastructure both on and off site and how this can be met. The AAP will ensure that new developments consider the drainage and flood risk of the development both on and off site. The AAP will promote greywater recycling and rainwater harvesting in new developments.

RP048 Siobhan Pender (Resident Bromley Gardens)

Need to embrace idea of urban living with a village feel- Council must encourage and help establish individuality within retail and café arena. Opportunity to designate areas which promote café culture for art and community spirit to flourish. Enjoyment of town centre limited by lack of good alternative restaurants and ‘yob culture’. Reference to Northcote Road Battersea as good model- village atmosphere and range of independent shops. Potential to promote Bromley as area with a lot to offer people without children- support for art gallery and venue for book launches etc.

Council seeks to enhance character and attractiveness of town centre as a place to live and enhanced provision of cafes and cultural provision.

Policies promote mixed uses and new cultural and leisure facilities and residential development in town centre.

RPO49 Mr Mortimer (resident of Ringers Road)

Concerned about lack of information about potential CPO in next 5 years- Request for details of compensation and CPO appeal procedures.

Council will manage any CPO process to minimise blight and ensure property owners fully consulted and receive appropriate compensation

RPO50 Pierre Appleby (BBRAG)

Concerned about proposals to discourage car usage and impact on retailers/ businesses. Support for more consideration to be given to cycling as a sustainable mode of transport for shoppers, commuters and school children. Expressed disappointment that cycle routes have not been given greater consideration in the AAP. Need to create new cycle facilities/ routes. Need for solution to ‘out of town’ traffic problem to encourage businesses to locate in Bromley. Support for widening of A21- over reliance has been placed on falling traffic counts which may not continue. Need to improve road accessibility. Need to consider park and ride- to south, west and east to reduce congestion at peak times. Proposed mitigation measures will not solve approach road congestion and are a disincentive to expansion of the town.

A balanced strategy is proposed which provides for necessary parking and promotes increased use of public transport and sustainable transport. The SA promotes the inclusion of cycle routes and facilities in new developments and throughout the town centre as part off mitigation measures. Council developing a comprehensive transport strategy to support AAP

AAP includes policies to promote pedestrian and cycle links and connectivity throughout the town centre as part of a comprehensive transport strategy AAP includes transport proposals

Increased parking tariffs will discourage people from staying longer in town centre. Suggested cycle routes for pupils to get to local schools.

including park & ride provision in longer term

RPO51 Ms Musto Mr Brennan Ethelbert Close

Unaware of proposals affecting property- request details of the compensation code and to be kept up to date on progress of proposals.


RPO52 Peter Brown Ringers Road

Supports proposals to benefit local community- plans directly affect property and concerned that residents should be more involved as decisions are being processed. Request clarification of plans and details of the compensation code.


RP053 Edwin Thompson Clerk of Bromley Quaker Meeting/ Member Churches together in central Bromley

Pleased that revised Plan recognises part churches play in life and community of Bromley. Need to give more attention to quality of life- should not be overtaken by retail and commercial considerations. Need to make Bromley a place people will want to live.


AAP recognises importance of churches and need to make provision for churches affected by development in town centre

RPO54 Penny Read

Plans for Site D should not mean end for the cinema. Suggests live entertainment venue on Site C- comedy club or ice rink and facilities for younger people. Car park on Site D ugly but useful. Site N provides good opportunity to improve appearance of area- supports idea of town square with wider open space and links to library and theatre and Church House gardens. Site F- good opportunity to open gardens up to public- parks bring history of area to life and bring town to life- potential for linked walks

Council seeks to retain entertainment facilities in any new development Proposals for Site N and Site F seek to enhance environment of town centre and to improve access to open space

Site D deleted from Draft AAP AAP includes guidelines for development of Sites N and F including enhancement of public open spaces

RP055 Peter and Audrey Hallows

Concern about proposed closure and relocation of leisure centre- fear scenario whereby there will be a hiatus between closure and completion of new facility. Retail development at side of Glades will centralise provision in small area- consideration should be given to incorporation of retail space within redevelopment of southern end of High Street. More vibrant town centre should not be at cost of existing facilities.

Council will ensure that re-provision of leisure centre secured before development of Site E proceeds. Council seeks to extend retail offer to southern end of High Street

AAP requires relocation of leisure centre secured before development of Site E proceeds AAP proposes extension of primary retail frontage to south of High Street

RPO56 Steve Price, MyTime

Quality and fabric of the Pavilion has deteriorated- need to take decision on case for investment and improvement. Concern about potential impacts of proposals on leisure centre- most significant leisure centre benefiting from footfall generated by proximity to town centre shops and attractions. The Pavilion has aged badly and does not meet growth in demand for health and fitness- sports hall and squash courts underused. However, it still represents a major opportunity for improvement/ investment- would reposition the leisure offer to complement the retail offer and contribute to objective of a successful and vibrant town centre. Key concerns:

• Replacement site on Civic Centre too small to re-provide existing facilities (smaller pool and possible loss of sports hall)- would also result in loss of Grand Hall a venue for community activities and Adventure Kingdom;

• Implementation period of AAP is likely to prevent significant investment in the current centre until decision is made. Virtual planning blight on existing site.

Request Council to consider a commitment to endorse the continued provision of a public sector leisure facility within the town centre and to provide a replacement to the Pavilion before demolition of the current site.

A new sports/ leisure facility will have to be provided if the Pavilion is redeveloped. Preliminary feasibility work undertaken to establish capacity of Site F to accommodate new recreation centre Council will work with MyTime to ensure quality of provision maintained

AAP identifies requirement for provision of new leisure facility in event of development of Site E

RPO57 James Stevens, Home Builders Federation

Concern that not all of objectives pp 33-34 are deliverable and whether some might prove incompatible (creating an attractive, healthy and peaceful place to live while also reviving commercial, employment and entertainment uses in town centre. Unlikely any one developer will be able to deliver all the S106 obligations listed on p85-86 on a single scheme and therefore the way that the obligations are calculated must reflect the circumstances of the development site and its ability to absorb those costs. Developers need more certainty and it is essential that Council prioritises obligations and relate these to specific residential locations in the AAP. Calculation of potential health and education contributions must be related to evidence of actual need. This requires monitoring of capacity- report to Bromley Council dated 13 February 2007 reveals substantial existing capacity and calls for reduction in published admission numbers to reduce costs. This suggests little need for new education infrastructure to be built.

Council will seek appropriate level of contributions from all developments

Policies included in implementation section of AAP regarding developer contributions

RPO58 Ian Shrubsall, RPS for Invista Foundation Property (freeholder of 100-102 High St)

Seeking to purchase 104-108 High St Welcome identification of 100-108 High St for mixed use development- opportunity to redevelop site to create landmark building at important focal point adjacent to theatre and entrance to Church House Gardens: would form attractive and active corner to new town square. Objection to Site G on grounds of the ability of the proposal to be delivered and the potential blight that could occur as a result of the wording of the proposals. Table 7.1 Site G- Car parking, community and faith uses of the site should be considered as applying to those parts of the site where they are existing, or in the case of parking

AAP is being prepared in the context of serving the town centre as a whole not in a piecemeal way. In terms of transport, this relates to parking to serve linked trips within the town centre and also sustainable policies such as travel planning, again orientated towards a whole town centre approach. Comprehensive approach to redevelopment of Site G is required to deliver objectives of AAP and capacity for new retail development. Feasibility work indicates Site G development can be delivered. Council will manage any CPO

AAP promotes a comprehensive Transport Strategy. Policy for development of Site G will require re-provision of community and faith uses and improved linkages to open space.

where required to serve new development. Linkages to public open space should not be a requirement for all parts of site. Welcome potential for taller buildings but reference to comprehensive approach needs to be clarified to prevent situation where Site G in multiple uses and tenancies will not otherwise come forward for development if it had to be assembled as a single ownership and development site. CPO should not be used if objective can be achieved in another way. Masterplan should allow individual parcels to come forward on a phase by phase basis to achieve deliverability and recognise individual property rights. Piecemeal development can be avoided by setting policy objectives for wider area. Propose new wording: ‘A comprehensive concept is proposed for Site G to which all individual parcels of land within Site G must comply in order to ensure the objectives for Site G are met. For the avoidance of doubt, development proposals for Site G will not be permitted unless they can demonstrate how they contribute to meeting the overall objectives for Site G and that they avoid prejudicing the subsequent development of adjacent land and other elements of the Site G proposals’. Accept that reference to ‘linkages/ integration with Park and Site N’ are necessary but clarification is required that proposals do not have to be delivered in a single phase or ownership with Site N, but that they should be complimentary and link to Site N and the park and allow for that development, but not be contingent on it, or required to deliver it. Welcome indicative floor areas for retail but caution that flexibility should be allowed for residential development as this is the most suitable use for the upper floors. Inappropriate to cap development at a level less than would make best use of site- priority should be given to achieving

process to minimise blight and ensure property owners fully consulted and receive appropriate compensation.

higher densities on sustainable town centre sites. Object to indicative timescale for development of Site G as Phase 2 for 5-10 years. Site is physically capable of development within Phase 1- no sound reason to delay positive regeneration/ development which can take place on phased basis. Object to statement that use of CPO will be necessary to promote comprehensive development- comprehensive approach can be achieved by individual parcels coming forward in a coordinated and complimentary way. Requirement for CPO will lead to planning blight and a disincentive to landowners bringing forward proposals. CPO will delay regeneration. Request meeting to discuss proposals.

RPO59 Katy Noseda-Vennard

Concern about development of Westmoreland Road Car Park- not in best interests of community:

• Need for Car park which is always in full use. If size of car park reduced, increased demand for parking and detrimental impact on residential roads. Existing lack of parking in area will be compounded by development;

• Existing cinema could be improved- no need for another cinema;

• Increased noise pollution and rubbish and anti-social behaviour at night;

• Increased traffic; • Development will have detrimental effect on house

prices and impact on residential amenity; • No need for additional cafes/ restaurants given

existing provision.

Parking will be re-provided in Town Centre. Existing cinema does not meet requirements for entertainment provision in town centre

Policy for development of Site K to require provision of public parking. Requirement for high quality design and mitigation of impacts on existing residential amenity. Any reduction in public parking on Site K to be re-provided on Site G. Requirement for any proposals for reuse/ redevelopment of existing cinema to include entertainment/ leisure use

RPO60 Carolyn Elliott

As resident of Ravensbourne Road, considers proposals for Site G to represent very high density and will have big impact on local services- doctors (proposals for Site H (Phase 3) will be too late), primary schools, secondary

A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision and restraining parking where appropriate. A Parking Plan will

New development being taken forward under the AAP will require detailed transport assessments to ensure traffic impacts are acceptable. Residents

schools and drainage. Better solution for new department Store on old Army & navy Store site- would remove requirement to demolish TK Maxx and retail/ residential properties. Impact on existing residents due to potential CPO. Bromley’s attraction relates partly to traditional ‘old town style’ feel- should not be competing with Bluewater. Traffic around Bromley South is already heavy with significant congestion at Masons Hill junction. New 400 space car park will exacerbate problem and discourage people from coming into Bromley. Inadequate residents parking bays to serve Ravensbourne Road, Ringers Road and Ethelbert Road- residents have to find alternative parking a distance away in Zone C. Publicity material has not clearly stated the enormity of the plans- most people do not understand the scale of demolition planned. Need further clarification of proposals. Closure of the Pavilion will result in loss of only sports facility in area before new facility is provided on Civic Centre site. Limited facilities for young people- a period without leisure facilities in town centre is unacceptable.

be prepared including on-street parking provision. Development of Site G will be required to include provision for community facilities

Re-provision of leisure facilities will be secured Developers will be expected to contribute towards the necessary infrastructure requirements

parking permits will not be made available to residents of new development in Town Centre. Development of Site J Bromley South Station modified to exclude mixed use development over tracks.

RPO61 Tinklin Springall Solicitors

Concern that youth element getting out of control in town centre- need to liaise with police and bring zero tolerance policy into effect. Support wider extension of CCTV system. Support 3-4* hotel as part of redevelopment of Bromley South given lack of hotel facilities in area

Hotel development included in proposals for Site C and L

Policy included in AAP relating to safety and security and town centre management.

RPO62 T O Burrell

Provision of health and leisure facilities was a major factor in agreement to original development of the Glades. Demolition of existing provision needs special consideration.

Replacement sports/ leisure facility will be provided if the Pavilion is redeveloped.

AAP includes policy requiring re-provision of sports/ leisure facilities if The Pavilion is redeveloped. Site F

John Lewis do not wish to use site and justification for proposed new department store diminished. Smaller additional shops would not justify loss of leisure facility. New leisure centre on the Civic Centre site must contain at least a swimming pool of similar size and nature to existing pool and a gym. Opposed to any closure of leisure centre prior to new facility being provided. Commercial development must nor take precedence over health and fitness of borough residents.

identified as suitable site for new facility. Provision will need to be secured before development of existing leisure centre (Site E) commences

RPO63 Peter Faulkner

Welcomes amended proposals provide for inclusion of Churches but concerned that there is no guarantee that Salvation Army and Town Church will not be moved to another part of town. These churches are used by community throughout week. If churches are moved their value may be diminished. Transport policy is unrealistic- idea that increasing number of people living and working in town centre can be achieved without significant number of parking spaces is wrong- existing parking restrictions mean that people often go to Bluewater instead of Bromley. Inability to go along Widmore Road through Market square and down Church Road will add to high levels of traffic on Tweedy Road. Lower part of High Street should not be closed to cars. Concern that buses will not be allowed to stop outside Boots- if it is moved this will result in longer walk to the Glades- a problem for old people.

Council will ensure provision for existing faith uses as part of redevelopment of Site G Comprehensive transport strategy developed to support AAP.

AAP will include polices relating to transport measures to improve accessibility to town centre

RP064 Valerie Walford

Supports preservation of open space and proposals to retain and improve access to it. Concerned that transport will remain difficult- suggests that Christmas Park & ride facility should continue to operate on trail basis to assess whether it would be viable and efficient as a permanent service and reduce congestion in town centre.

Comments noted AAP includes transport strategy which identifies park & ride as longer term measure. AAP seeks to improve retail offer and new department stores

Concerned about decline in quality of retail offer and loss of department stores. Supports proposals to revitalise retail shopping in High Street. Supports continuing presence of Salvation Army in town centre- contributes to civic life and provides facilities such as youth clubs and play groups which could not easily continue if premises moved. Need for more facilities in area. Provision to meet faith needs is essential. Salvation Army could not contribute as effectively to community if it did not continue to occupy space within Site G. Significant amount of money invested by community in upgrading existing premises. Concerned that revised proposals for Site G only provide for developers to be requested to accommodate Salvation Army in redevelopment proposals- should be altered to ‘requirement’ to accommodate Salvation Army.

RPO65 Michael Fearn on behalf of Barclays Bank

Highlights need for more diverse range of activities within the town centre- 2004 Retail Study showed that banks and financial institutions under-represented in Bromley compared to national position- but no intention set out in document to review the extent of primary area or modify wording to bring UDP policies S1 and S10 into line with government policy. UDP policies state uses within Classes A2-A5 may be appropriate: Uses in Part A of Use Classes order are by definition appropriate in shopping frontages and should be permitted. Designations of primary and secondary frontages should be realistically defined having regard to rental levels and yields- unclear how these issues have been addressed. If Council intends continuing to promote this type of policy these issues need to be addressed.

Council seeks to extend retail and business opportunities in town centre

AAP includes policies to extend retail and business opportunities

RPO66 Rose Freeman, The Theatres Trust

Welcomes recognition that cultural and creative economy is an important contributor to Bromley’s economy. Support proposals for Site N to develop a cultural quarter and civic square in front of the Churchill Theatre and Library.

Comments noted AAP includes policies to promote cultural and creative economy

Balanced leisure scene will entertain and stimulate visitors, residents and local businesses- will enliven surrounding area in evening and provide regular custom for bars and restaurants outside normal working and shopping hours

RPO67 Charles Muriithi, Environment Agency

Development and Flood Risk Southern area of town centre south of railway designated as Flood Zone 3- 1% or greater chance of flooding in an y given year. PPS25 requires new development to be steered to areas at lowest probability of flooding by applying a ‘Sequential Test’. No evidence provided to indicate sequential test undertaken- uses defined as vulnerable development must not be permitted in area and options to remove highly vulnerable development from these areas should be considered. SFRA should inform the Sustainability Appraisal. At present AAP does not accord with guidance in PPS12 because of lack of robust evidence base relating to flood risk. Revised Preferred Options should be assessed on basis of flood risk issues. Proposed development in Southern Gateway may not be appropriate due to flood risk and further investigation required (Sites H, J and K). FRA must determine actual flood risk to these sites. Selection of preferred options sites for residential development after SFRA undertaken may identify more suitable areas for development. Town Centre constrained by predominantly manmade rivers and capacity of existing sewer and surface water systems. Robust approach needed to manage flood risk in future- balance must be struck between maintaining and supporting natural floodplains and reducing flood risk. SFRA must be done prior to Council progressing plan. Surface Water Food Risk London Plan SPG on Sustainable Planning and Construction states that development should use SUDS wherever practical (essential); achieve 50% attenuation of undeveloped site’s surface water runoff at peak times

Comments noted SFRA undertaken

SA has assessed potential impacts of development and proposed mitigation measures Policies included in AAP to address impacts of development Text amended to reflect comments

(essential); achieve 100% attenuation of undeveloped site’s surface water runoff at peak times (preferred). Drainage must be designed to cope appropriately with peak runoff rates and volumes and allow for climate change in accordance with increases in rainfall predicted and outlined in PPS25. Climate Change Need to integrate climate change considerations into all spatial planning- transport, housing, economic growth and regeneration, water supply and waste management- view from wider sustainability objectives not just reducing impacts of flooding. Need to consider mitigation and adaptation and opportunities for integration in spatial strategies should be maximised. Consider area’s vulnerability to climate change and implications for built development, infrastructure and services and biodiversity. New development should be avoided in areas with likely increased vulnerability to climate change. Council should require development proposals to take account of expected changes in local climate conditions by adaptation or flexibility to allow future adaptation. Information on measures should be submitted with an application. Council should require major developments to:

• Identify type of and extent of main changes expected in local climate throughout lifetime of proposed development;

• Identify potential impacts of changes on proposed development and its neighbours;

• Indicate ways in which proposed development design overcomes hazards and exploits opportunities whilst meeting other sustainable development criteria, particularly need to achieve overall reductions in greenhouse gas emissions.

Ground Water and Land Contamination

Areas of town centre designated within Groundwater Source Protection Zone- provides water for public supply and vulnerable to pollution such as site drainage. Within these areas pollution prevention measures must be followed in accordance with ‘Policy and Practice for Protection of Groundwater’. Only roof water must be discharged to ground within inner source protection zones. Where development is proposed on or near a site known or believed to be contaminated, a site assessment will be required to establish nature and extent of contamination prior to determining the application. Remediation must reduce risk to acceptable levels. Surface water runoff should be treated through a SUDS system to improve water quality eg: pervious paving, green roofs, bio retention, filtration, ponds and storm water wetlands. Open Spaces and Biodiversity Pleased to see most of biodiversity issues addressed- AAP an ideal opportunity for enhancement of low value conservation sites and to create and enhance ecological networks and improving and linking green spaces to local residents. Proposals for improvements to public realm welcomed- development provides opportunity for green spaces to become a major educational and community resource- new green grid style development, improved entrance ways and knowledge of parks, enhancement and extension of existing green spaces. Recommend increased environmental recreation in and around river corridors eg: increased access to fishing and environmental education. Potential to improve ecological value of green spaces by removing hard concrete edges along river corridors and replacing with natural planting. Council should require development proposals to include landscaping and other ecological features that contribute to protecting, managing

and enhancing local biodiversity- information must be submitted with applications. Applicants should appoint an ecologist to prepare appraisal of proposals and if appropriate a biodiversity action plan for site. Design and Construction Importance of design quality of buildings and public spaces and need to enhance local character and support local services. Well designed neighbourhood should be socially, economically and environmentally sustainable. Building Regs will require new homes to be zero carbon by 2016. Need to create multi-functional landscapes with opportunities for water and energy saving- neighbourhoods should be convenient and safe to walk or cycle to shops, schools and access to public transport with range of tenures and types of housing. Buildings must be located and designed to reduce flood risk over lifetime of development- 60 years for residential and 100 years for residential. Encourage green roofs and surface water storage to reduce flood risk. AAP should show how needs of disabled and older people would be met- design must be required to provide for inclusive access. Development Control Policies Need for strategic and detailed policies relating to flooding and climate change- representations include proposed policies on:

• flooding to reduce flood risk and ensure capacity of flood plain is preserved and where possible increased;

• Enhancement of River Ravensbourne including options to open culverts and restore sections of

river; • Recreational use of River Ravensbourne.

Greening New Development Encourage incorporation of green roofs in new developments. Energy Efficiency and Renewables AAP should ensure that a significant proportion of energy supply of new development is gained on-site and renewably and/ or from decentralised, renewable or low carbon energy supply and support use of renewables, CHP and bio fuels. It should promote the use of recycled building materials and materials with low embodied energy and promote retrofitting existing buildings to make them more energy efficient. Need to monitor performance. AAP offers opportunity to produce development with highest environmental standards and to achieve environmental protection and enhancement. Environment agency want to work with Council on best ways to manage and improve green infrastructure and achieve improved water and energy efficiency.

RPO68 John Sercombe

Proposals for development of Site G generally sensible but will have adverse impact on properties in Ethelbert Close. Initial plans for last UDP showed boundary of Town centre Conservation Area being extended to include wood but never implemented. Overriding concern relates to traffic management and impacts of additional parking and housing in town centre. Roads unable to cope with increased traffic- scale of development must be restricted or changes made to bottom of High Street eg: ban right turn from High Street into

Comments noted AAP sets out development guidelines for development of Site G to minimise impacts

Westmoreland Road for all traffic. RPO69 Maggie Gebbett

Request confirmation of proposals for the Pavilion and provision for new swimming pool and relocation of facilities in Pavilion. Expectation that there should be a swimming pool in town centre.

Development of Site E dependent on relocation of leisure centre

AAP includes policy for reprovision of leisure centre

RPO70 Deborah Stephens, on behalf of the Metropolitan Police

Need to ensure infrastructure and services are provided to support new and existing economic development and housing. MPA have a key role to play in ensuring safe places to live are created as part of a sustainable community. London Plan recognises importance of initiatives relating to policing and community safety and crime reduction in improving quality of life. Developments should be safe and secure taking into account objectives of Secure by Design, designing out Crime and Circular 5/94. Such a commitment should be secured as part of any planning consent relating to large scale development schemes. London Plan Policy 3A.14 recognises that provision of police facilities is a key aspect of the provision of social infrastructure. Needs of MPA should be expressed in AAP and proposed development should make appropriate provision towards policing. Para 3.2 – should include reference to the provision of appropriate levels of police facilities. Para 4.6 – include reference to police services in the range of public services and facilities required to provide a ‘good’ environment. Chapter 5- AAP should include community safety and policing initiatives. Welcome safer neighbourhood Panel initiative and role of town centre manager in monitoring Para 6.4 – should include specific reference to ‘Designing out Crime’ and ‘Secured by Design’ principles within the

Comments noted AAP includes policies to ensure new development supported by necessary infrastructure Text amended

underlying principles of the Spatial Strategy. Community facilities should include specific references to the police service. The MPA request the provision of police shops in relevant locations. This advice should be considered in connection with all relevant proposal sites including Sites A, D and G. Planning Obligations- The AAP should allow additional community service contributions to be negotiated across the town centre, including contributions towards community safety and policing initiatives in order to promote inclusive, healthy, safe and crime free communities.

RPO71 Neil Coe, Alexandra Residents Association

Scope of consultation was too restricted, poorly advertised and insufficiently detailed for full responses- many residents unaware of AAP. Explanation of options superficial and level of questions inadequate to judge proposals. Overall concept of long term plan to enhance town centre rather than allowing speculative development welcomed- but share concerns of Friends of Bromley Town Parks and Gardens and Heart of Bromley Residents association in respect of Sites C,D,F,G and L. Emphasis should be on quality rather than quantity of new retail offer, and diversity should be encouraged within the historic quarters of the town. Assumption that Bromley must compete with larger local shopping centres is not necessarily valid if the whole retail/ culture/ entertainment/ leisure experience is more pleasurable and convenient.

Council committed to full consultation in accordance with Statement of Community Involvement Comments noted

Policies included in AAP to ensure high quality of development and provision of balanced mix of uses

Support objective of creating a vibrant day and night culture and provision of selection of restaurants/ cafes, cultural activities, leisure and entertainment facilities to attract full range of residents and visitors throughout week and at weekends. Concern that the historical, architectural and cultural elements of the town centre are not given sufficient importance and consideration in the AAP. Heritage and parkland gives Bromley a distinct advantage over centres such as Bluewater, Lewisham and Croydon and this should be exploited to maximum. Proposals for the Civic Centre are vague and inconclusive, and do not address the isolated nature of the location. Council offices should be located in natural centre of town or link with main High Street, shopping centre and parks Reuse of Old Town Hall site for reception and council meetings would refocus town on North village which is currently underused. Transport of paramount importance to success of AAP- Bromley North station must be refurbished and connected properly to road network to redress inaccessibility of Bromley from north. The proposed new multiplex cinema will jeopardise the existing Odeon cinema which should be preserved as a historic building and amenity. Requirement to retain an art house cinema or other suitable converted public use should be a condition of granting consent for multiplex. Alternatively, Odeon should become centre of the multiplex and adjacent land subject of CPO for additional screens, café and car parking.

Proposal for tall buildings should be strongly resisted particularly adjacent to the proposed new and enhanced town squares and close to parkland in order to maintain an appropriate skyline, protect strategic views and avoid overshadowing of communal spaces. Success of AAP dependent on Bromley North station becoming a primary transport interchange and LB Bromley using land and buildings to create right opportunities for change. Increase in shopping not an essential requirement. Need correct balance of heritage, culture, leisure and entertainment to become a vibrant town centre. Current AAP too biased towards large scale development to detriment of enhancing the existing townscape and retaining local character. Consultation should be expanded to all Bromley residents and wider range of community groups and consultees such as English Heritage, CABE, SPAB and Advisory Panel for Conservation Areas. Success of town centre of importance to whole Borough.

RPO72 Nicola Davies, Palace View

Congestion only partly due to car ownership levels. Best way of tackling congestion is to influence how people choose to travel. Problems of non-permit holding vehicles parking in adjoining residential streets- need to review CPZ. Concern that no mention made of current education needs and provision. Problems of availability of primary school places close to town centre. Shortage of nursery and primary school places for people living close to town centre creating a need to travel by car. Need to address issue of primary and nursery school places if new residential

A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision and restraining parking where appropriate. Parking Plan to review on-street parking provision. Upgrading Bromley North and Bromley South stations is not purely to improve the environment of the stations and attract car drivers to take the train, but rather to improve the accessibility of the stations. Balanced mix of uses proposed to create vibrant

Policies included in AAP relating to parking and improvements to public transport as part of Transport Strategy. Policy to promote high quality development and safety and security. Requirement for provision of community infrastructure/ financial contributions to meet needs of proposed residential development.

development proposed. Upgrading of stations unlikely to influence choice of travel in favour of train and away from car. Key problem is decreasing capacity of trains at Bromley South and Grove Park for people using Bromley North shuttle. Mixed use development needs to be defined- town already offers mix of uses. Not necessary for every site to offer mix of uses. Residential above retail will still provide inactive frontage at night- will not necessarily result in good development and contribute to solving evening problems eg: perception of crime. Further pedestrianisation unlikely to increase public transport, walking and cycling. Parking charges need to discourage long stay parking- should only allowed at extreme north and south (Westmoreland Road and The Hill). Should be combined with park & ride to encourage long stay visitors to leave cars on edge of centre. More bus priority measures and cycle lanes on main approaches to town centre could encourage drivers to shift modes. Additional pedestrianisation could result in longer walking distances to public transport. 2500 residential units represents a significant increase – needed to kickstart regeneration and expansion of town centre but concern about associated parking provision, healthcare and education needs. Car free development in areas of high accessibility can work but need commitment of developers and council to secure car clubs. Housing strategy needs to have regard to actual number of car-free flats that can be accommodated rather than a %. Can range from car free at Bromley South to higher level of provision at edge of town centre.

town centre.

CPZ areas around town centre must be revised to ensure car free development does not give rise to on-street parking. Already demand for more GPs and dentists close to town centre- locating facilities as part of mixed use buildings close to rail stations would be beneficial to commuters and residents.

RPO73 TFL

Welcomed the revisions made to the preferred options. TfL supports the objectives, vision and key themes and will work with LB Bromley in developing proposals. AAP should contain a policy that encourages developers to submit transport assessments for major developments. Given high PTAL score and underutilisation of some car parks, parking standards should be further reduced. In order to further reduce travel by car, as much car free residential development as possible should be encouraged in the town centre. Freight policy based on Policy 3C.24 of the London Plan should be added to the AAP taking into account the sustainability aspects of freight and servicing. Opposed to bus routeing along the pedestrianised length of the High Street as this would disrupt well established pedestrian area and negate proposals to increase pedestrian priority. Need to address missing and poorly defined links within walking and cycling networks between town centre and public spaces and gardens to west. Welcome inclusion of a travel plan and other soft measures. In order to maximise benefits from soft measures and to reduce reliance on car a holistic approach covering the whole town centre should be developed. This would allow

Initiatives for improving walking and cycling in Bromley town centre will be an important component of the Transport Strategy for the AAP.

Add words in the AAP to reflect the importance of developers submitting transport assessments ‘taking account of TfL TA Best Practice Guidance’. The AAP will reinforce that it supports car free residential development and will be looking at significantly reducing levels of residential parking in the AAP area. A section on freight will be included in the AAP Account taken of TfL views on bus routing. AAP includes specific policies relating to planned cycle and walking improvements including new links and pedestrian crossings. A town centre wide travel plan approach is proposed within the AAP for Bromley Town Centre.

for coordination of measures Suggested that plans to provide cycle parking facilities on Site A as a way of encouraging sustainable modes should be extended to cycle parking provision throughout the town centre and particularly the High Street. Expressed concern regarding the proposal for additional car parking on Site G given that current car parks are under utilised and it is in a location where car free development should be progressed.

A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision and restraining parking where appropriate. A Parking Strategy will be looking at on-street parking provision. Parking for Site G should be taken in context of the town centre wide strategy for parking, which looks to manage parking in order to support the increase in retail provision.

RPO74 Denis Wilson Partnership

Support development of Bromley North Station site- compliant with PPG13. Site can be more intensively developed as a main transport hub given its key location in town centre. Agree in principle with approach to transport assessment based on application of trip rate relating to car parking spaces rather than gross floor area but comments that new floorspace will attract some new primary shopping trips. However, it would be but wrong to assume that all new trips would be new trips and some allowance for linked trips should be made. In addition, maximum car parking provision has been applied in locations with high accessibility level 6a where some reduction in maximum standards would normally be expected. Emphasis placed on retail floorspace and modelling outputs could impact on any proposals to increase other land uses in town centre eg: more residential space. The traffic modelling shows adverse impacts on southern approached to town- due to focus on retail development, even the lowest increase in space would require substantial mitigation measures. Allowance for greater mix of uses may have beneficial effects. Case for reducing parking for residential development can equally apply to other forms of development. Potential car

The AAP supports pedestrian linkages across the A21 and improvements to the bus interchange at Bromley North Station. The transport impacts of increased residential units on Site A will need to be considered as part of a detailed transport assessment for that site alongside other planning implications. The AAP does not require any change to the number of car parking spaces provided on Site A. Proposals for how the existing quantum of parking is maintained can be a matter for consideration at detailed planning stage.

Amendments to proposals and design guidance for Site A

use associated with non-retail development may not be at peak times and impacts may not be significant. Need for equitable apportionment of car parking depending on quantum and type of development- should not penalise one type of development whilst allowing another to have higher levels of provision which may result in congestion on wider network. Support improvements to Bromley North Station as part of major redevelopment and potential for Bromley transit route. Need to consider frequency and demand for service to ensure it would not impact on other services. Many may chose to walk given distances and opportunity to visit shops on route. Question whether link would be well used given number of shoppers arriving by train compared to buses. Support improved crossing facilities in vicinity of station. Question phasing. Good case can be made for earlier development of schemes that will bring forward infrastructure improvements such as Bromley North. Concern that Bromley North site identified as cause of delays- development should be encouraged given high accessibility and public transport improvements. Consistent with policy to increase level of development at Bromley North (in particular residential). An increase to 400 residential units would result in small increase in traffic. Possible to introduce some signal control on Tweedy Road at Mitchell Way junction- would allow a pedestrian/ cycle phase to allow pedestrians to cross in one continuous movement and permit right turn onto Tweedy Road. This would reduce traffic movements through residential areas to north and allow buses to head north west from new bus interchange. Proposed development would not preclude future transit route between Bromley North and Bromley south.

RPO75 Lennon Planning on behalf of Linden Homes

Support high density mixed use redevelopment of Site A in line with general aims of Revised Preferred Options subject to following representations: • Amend reference to parking provision in a multi-storey

car park or decked parking to provide flexibility; • Amend site boundary to include properties facing

Sherman Road (6-12 Sherman Road) and Bromley North Clinic. Amend reference to possible redevelopment of clinic- ‘while there is no need at present to replace this facility, this building has been included within the site to allow for the potential enhancement of health facilities in this area should circumstances change’;

• AAP should recognise that higher density residential development may be necessary to cross subsidise other improvements sought by AAP. Scheme of 250 units would have a density of approximately 95 units per hectare- London Plan density matrix states that development in this location should have a density of between 240-435 units per hectare. Density should be amended in accordance with London Plan standards;

• Development of Site A should be brought forward from Phase 3 to Phase 2. Site will not be delivered in Phase 1.

Linden Homes control 6-8 Sherman Road and are in discussions with Network Rail about working together to deliver site development. An indicative masterplan has been prepared for Site A to illustrate comprehensive redevelopment of Bromley North to provide a sustainable residential community with associated improvements to transport infrastructure, provision of additional commercial space, community facilities and improved public realm. Rear of site proposed for residential with front part developed for a mix of uses including a bus interchange, refurbished station buildings, community uses and enhanced public

Council would wish to work with land owners and developers to secure redevelopment of Site A and improvements to station and public transport interchange

Proposals for Site A amended to incorporate changes to development mix and phasing

realm. Key components comprise

• 400 residential units (35% affordable) • 2,000 sq m commercial (excluding retained office

buildings and including 700 sq m A3/A5 uses within retained station buildings)

• 450 sq m community (health/ dentist) • 260 residential parking spaces (0.65 space/ unit) • Replacement of public parking (330 spaces)

Increase in residential units from 250 to 400 units would be consistent with principles of PPS1 and PPg13 which seek to make the most efficient use of land will not result in any significant increase in traffic. Maximum height of residential buildings 7 storeys in middle of site- least sensitive in terms of adjoining uses. Multi-storey carpark proposed in centre of site to be wrapped by residential and commercial frontage with direct link to improved bus interchange. Creation of new public space between existing and proposed station buildings provides opportunity for enhancement and relocation of Charter Market to more prominent location. Masterplan provides a safeguarded route for potential transit scheme- would facilitate the conversion of existing heavy rail services from Bromley North to Grove Park to light rail (tram or guided bus) and extension of route south to Bromley South station via the North Village and High Street.

RPO76 London Fire & Emergency Planning

Concerned that no mention is made to locally listed fire station and that no provision is made for an alternative and suitable site for a new fire station to replace Bromley fire

AAP seeks to protect and enhance heritage of town centre and historic buildings.

Policy refers to links between future development proposals and maintaining community safety.

Authority station. Seek support for a suitable site or building to be acknowledged and identified within the Borough for a new fire station facility. Bromley fire station contributes to Conservation Area but is not suited to current operational requirements- requires modernisation but is constrained by local listing. Seek support for: • demolition of fire station and new and modern facility

which is fully fit for purpose on existing site; • Relocation of fire station to adjacent car park site owned

by Bromley Council; • Provision for new fire station at one of proposal sites

identified as being suitable for development. Current location is optimum to provide fire cover. Authority has made commitment to provide an equitable fire and rescuie service. Location of fire station provides effective coverage for the local area based on risk profile of Borough. Unlikely that an alternative location away from present location will provide Borough with fire coverage as effective as that provided in current location. Extensive site search has failed to identify any suitable site alternatives except for car park site owned by Bromley Council. If car park site to be disposed of on open market, careful consideration must be given to potential impact on essential services that could be provided by fire station in this location. Financial contributions towards improving and expanding current fire services and facilities should be identified in policy on Section 106 requirements from development schemes. Need to consider capacity of key emergency services to improve community safety and maintain a speed of emergency response in line with LFPA standards.

No site identified as suitable for relocation of Fire Station in Town Centre. Council will work with LFPA to identify suitable site elsewhere in Borough in event of decision being taken to relocate existing facility. Redevelopment of existing site will be subject to policies in AAP.

Policy on design of new development to include requirement to design out risks from fire, especially in residential accommodation. Planning applications required to achieve high standards of fire safety; the close monitoring of building sites during construction.

Future growth within Borough will create additional risks from fire and other emergencies. Future policies should mention the links between future development proposals and maintaining community safety. Policies should address the need to grasp opportunities offered by new development to designing out risks from fire particularly in residential accommodation- includes giving consideration to installing hard wired smoke alarms and sprinkler systems where risks justify it. Efforts to reduce crime such as arson through good design should be promoted.

RPO77 Cecilia Yardley, Bromley United Reformed Church

Commented that a ‘weekday environment’ that caters for those who work in Bromley is important. Commented positively that faith groups have been acknowledged in the AAP. Commented that faith groups would benefit from expansion of premises and increased access to parking spaces after shopping hours.

AAP will seek upgrading of existing car parking provision throughout Bromley Town Centre to provide a better quality and safer environment both in the day and evening periods.

Inclusion of appropriate policies

RPO78 LXB Properties Ltd

LXB supports proposals for sites G,H and N in terms of mix of uses but there is an opportunity and requirement to increase residential content on these sites. This is consistent with increasing emphasis being put on need to deliver housing to meet housing demand and support evening economy and prevent anti-social behaviour. More residential development is necessary to support retail improvements. Scale of retail improvements is not commercially viable without additional residential development. Proposed amendments: • Sites G,H and N to be amalgamated and shown as one

large site for comprehensive development- should include Habitat shop and car park and upper terrace of Church House Gardens.

• Extend primary retail frontage along length of Site H; • Number of residential units should be increased from 500

Council seeks to work with landowners and developers to secure regeneration of western side of High Street and comprehensive development of Site G to accommodate capacity for retail development and to improve offer of town centre

Proposals for Site G amended to ensure scheme delivery and high design quality and mitigation of impacts on existing amenity and wider town centre.

to 1200 units; • Office uses should be included; • Community uses including faith uses should be

accommodated within the redevelopment area or relocated;

• Use of tall buildings should be supported subject to high quality design;

• Allow safeguarding routes at vital junctions- along front of the Liverpool Victoria building to increase capacity and A21 masons Hill between Kentish Way and B265 intersection as proposed in adopted UDP.

• AAP should set standards for parking in town centre RPO79 GVA Grimley on behalf of St James Investments

Previous preferred options identified Site D as suitable for mixed use development comprising residential and retail including a large foodstore- support recognition of area’s potential to meet identified requirements. Support principle of mixed use for Site D but considers the proposals to reduce the site area and other constraints are likely to prejudice the prospects for securing a viable mixed use development. Site D is one of the few opportunities for retail and residential development which is needed to maintain and enhance Bromley’s role as a metropolitan town centre. Reduction in Site D and constraints on scale of development may result in loss of opportunity for comprehensive regeneration - as a consequence, this will undermine the prospects for new investment in the area. There is significant capacity and quantitative and qualitative need for a large new foodstore. Highway consultants do not consider traffic analysis represents a clear justification for imposing constraints on size of store likely to be appropriate on Site D. Therefore inappropriate to impose a precise ‘cap’ on size of foodstore- contrary to wider development plan aspirations to maximise retail investment. Detailed matters

Modelling work done to date has suggested that it would be inappropriate to have a large new foodstore on Site D because of likely traffic congestion on Beckenham Lane and London Road. If there are proposals for such a development this would need to be supported by detailed traffic analysis as part of a planning application at a later stage. Land excluded from Site G because it is unavailable for development within Plan period. Remaining site area inadequate for comprehensive development. Inclusion of Site P addresses possible demand for additional convenience floorspace.

Site D excluded from AAP due to reduction in site area. Development to be considered in context fo other policies in AAP and proposals for North Village Improvement Area.

such as parking and highway capacity are more appropriately dealt with at planning application stage or through detailed development brief and or SPD. This would provide opportunity to take a more comprehensive approach to Site D and North Village. Clients would like to work with council to develop a comprehensive masterplan.

RPO80 Doug Black, Bromley Civic Society

College Green would benefit from public footpath from corner of College Slip to Gordon way- to create pedestrian route from tweedy Road to town centre Proposed leisure facilities must be more than just pubs- need greater provision of leisure facilities especially for youth Use of Bromley Little Theatre as Theatre should be protected in AAP. AAP lacks strategy for built heritage- Council should produce conservation area appraisal to inform implementation of AAP proposals Concerned about design quality- especially signage and shop fronts. Need to improve town centre with emphasis on quality. Bromley North Village area should be made an area of Special Signage Control Housing on west St and North St should be subject to Article 4 Direction to prevent unsympathetic change. Development briefs should be prepared for each site so local groups can contribute Concerned that AAP must integrate better with ‘Building a better Bromley’ especially in relation to commitment to children and young people, access to Council services, well being/ health and improving public realm/ environment.

Comments noted. Council committed to enhancing town centre appearance and character. Redevelopment is required to meet objectives of AAP. Site A- requirement for relocation or reprovision of market Site B- development will be required to respect setting of Bromley College Site C- there is no requirement for civic use of former town hall. A suitable use of the listed building will be secured. Site F- no loss of existing parkland will be permitted. Site G- comprehensive development required to secure regeneration and delivery of benefits. Site K- need for improved entertainment facilities identified through consultation. Sites M, N and P will be subject to requirement to respect and enhance character of surrounding area and open spaces.

Policies included to protect end enhance appearance of town centre and setting of historic buildings and conservation area. Site D- site to be deleted due to unavailability of land for development. Requirement for incorporation of leisure use in event of building no longer being used as cinema. Reprovision of leisure centre must be secured prior to redevelopment of Site E Boundary of Site J amended to exclude HG Wells building.

Site A- Retention/ improvement of market in central Bromley Site B- concern that increased densities will result in tall development that will harm Bromley College (Grade 1 Listed) and views in and out of the Conservation Area. Development should be kept low. Public sculpture for open space at corner would be a more appropriate gateway than a tall building. Family housing inappropriate due to busy road. Site C- need to resist loss of historic features and overdevelopment. Building should be returned to civic use Site D- Object to demolition of existing historic buildings fronting High Street- Odeon cinema makes positive contribution to townscape and is worthy of retention. If no longer used as cinema should be designated for entertainment, sports or leisure use. Development must respect setting of and views from Masons Hill. No objection to good infill development which respects conservation area Site E- essential to retain a leisure centre accessible to all- existing site benefits from collocation with retail centre- very accessible. Relocation to Civic Centre would be less convenient and disincentive for many. Redevelopment should not increase height or bulk of building and impact on Queen’s Gardens- overshadowing/ loss of sunlight. Quality of development to be in keeping with Glades architecture and Queens Gardens. Need to protect Bromley Oak. Site F- no objection in principle to demolition of modern buildings but concerned about loss of parkland and inappropriate new development. Concern about overdevelopment Any development must respect historic, social and environmental value of parkland. New development should be confined to footprint of existing buildings to north and north west of site and landscape reinstated to south with removal of existing buildings- would reinstate visual relationship between listed folly on Rafford Way and Palace. Concern about loss of community facilities if civic centre

moves. Site G- object to demolition of residential properties in Ethelbert Close. Any new development must be sympathetic to local context of conservation area including views from Church House Gardens and Library Gardens. Development must not turn its back on Gardens, cause overshadowing or detract from its character- concern that site proposed for tall buildings. Northern part of site in Conservation Area contains buildings which contribute to its character- demolition of these buildings will be resisted. Buildings added to conservation area by Council in 1991 because of their contribution to traditional character of High Street. Nos 72-82 (corner of Ethelbert Road) and 84 are good examples of their type. Ravensfell House is a historic building- could be restored as part of a new civic space. Semi-rural character of views from across the Shortlands Valley and impact on High Street frontage need to be considered in design of new buildings. Portico of Bromley Church in Ethelbert Road dates from 18th century and should be retained- reused on site in 1930. Site H- No objection subject to securing good design Site J- No objection in principle but HG Wells Centre provides an important community role and facility must be retained in some form. New development should introduce greenery and better public spaces. Site K- essential that town retains a cinema but a greater variety of facilities should be provided: consideration should be given to using site for leisure facility not already provided by cinemas in Bromley and Beckenham- both will be lost with no net gain in leisure variety if Site K developed as currently proposed. Site L- no objection to sympathetic replacement of DHSS building. Site M- no objection to enhancement of this part of Glades building if it reinforces the garden character and does not require additional building/ hard standing in Queens

Gardens or lead to loss of trees/ landscape features. Site N- welcome principle of town square and improved environment- consideration should be given to microclimate: central library causes wind tunnel which makes forecourt unpleasant on windy days. Would wish to see Ravensfell House on High Street retained along with some of neighbours that make a positive contribution. Unwilling to see loss of any trees or landscaping in Church House Gardens to accommodate development. Greenery should extend to High Street. Consideration should be given to making area around the theatre/ High Street safer and more vibrant in the evening. Council could lead way by introducing a new arts centre or cultural facility into shop units below library tower. Site P- aspirations of AAP could lead to over-development. Semi-rural character of College Slip should be preserved and enhanced. New development should retain the public art panels on Sainsburys and respond to historic context behind High Street and address access yard on West Street. Rear views of historic buildings and trees make a positive contribution to conservation area and setting of listed building. Housing on west Street adjoining site must be protected.

RPO81 Highways Agency

Supports proposals to focus employment and retail development in town centre and high density mixed use development which should reduce need to travel but concerned about scale of retail development and proposed mitigation measures. Supports Objective 2 to extend range and quality of facilities and services: this will reduce need to travel by car by location of community facilities in locations with high levels of public transport accessibility. Recommended that Objective 8 should also seek to reduce dependence on the car for town centre residents and visitors. This would encourage transport strategy to focus on improvements to sustainable modes of transport. HA is concerned that despite identified impacts, the AAP is still proposing a very high level of retail development supported by widening of A21 and sustainable transport initiatives put forward by the Transport Strategy. The HA is concerned that widening of the A21 could increase car trip generation associated with town centre and traffic impact on the SRN. Focus of the Transport Strategy should be on capacity enhancements. LDF should incorporate policy mechanisms to minimise demand at source and seek to encourage a modal shift. HA would support bus priority measures on A21 south of Bromley. Presumption should be to give preference to solutions other than new road capacity to accommodate new development. Transport Strategy should seek to implement a full range of sustainable transport initiatives in preference to widening of A21. If the Borough pursues the widening of the A21 further modelling may be required to assess the potential impact of increased impact on the SRN (M25 Junction 4). Such

Comments noted. A comprehensive transport strategy has been prepared to support the AAP.

AAP includes policies on transport and implementation of comprehensive programme of measures to accommodate proposed development.

modelling would help to ensure that the plan meets with PPS12 Test of Soundness. Concerned that consideration has not been given to the wider traffic impacts of development in the town centre. Objective 3 should be updated to state: ‘ to not significantly increase in the overall level of traffic that needs to be accommodated on the highway network within the town centre and on the wider Strategic Road Network’. Supports inclusion of suite of soft measures including workplace and school travel plans, personalised travel planning and car clubs. Recommends that all developments should be required to produce a travel plan to ensure that combined impacts are adequately mitigated. Clear guidance should be given as to when travel plan required and expected content- could be in AAP or Planning Obligations SPD providing the SPD adopted alongside the AAP. Content should be based on latest government guidance. Supports town centre wide travel plan including existing and new businesses. Supports proposals to improve public transport and interchanges- improved bus links to Bromley North and Bromley South Stations will increase viability of public transport. HA supports improvements to walking and cycling. Supports use of parking policies to promote sustainable transport choices- increased parking charges including levy on business parking permits, car free and low car housing and establishment of Controlled Parking Zones. AAP should include maps of proposed extensions for increasing coverage of CPZs.

HA recommends that whilst maximum standards should be set for private parking (based on London Plan) policy statements should clarify that opportunities to reduce parking below these levels should be sought. Existing businesses should be encouraged to reduce dependence on car as part of town-centre wide transport plan. HA would expect a robust assessment to be carried out to identify the deliverability of park and ride sites should the Council wish to push forward this policy. Transport modelling may be necessary within the LDF process. This would be required in support of the inclusion of these sites in the site-specific allocations- would expect a reduction in town centre parking to support the strategy. Strategic Delivery Plan- who is responsible for funding/ delivery of strategy and how public transport improvements will be phased should be brought forward as part of emerging AAP. Development should not take place at a faster rate than provision of related sustainable transport initiatives to ensure maximum uptake of sustainable transport alternatives. Plan policies may be dependent on key infrastructure being delivered. HA would be supportive of early guidance to developers at pre-application stage to allow required infrastructure to be implemented within an appropriate timeframe. In order to ensure that traffic impacts of AAp and success of transport strategy are adequately monitored, HA would request that following indicators are monitored through SA or Strategy Delivery Plan:

• Level of growth of traffic on key routes • Proportion of new development which is meeting

travel plan objectives Targets should be set to provide benchmarks that Plan will aim to achieve. Travel plans will be a way of monitoring development transport impacts. Town centre wide Travel Plan could form basis for monitoring new and existing developments.

RPO82 Turley Associates on behalf of Sainsbury’s Supermarkets Ltd

Pleased that Sainsburys Store identified as Site P to allow for reconfiguration of store and car park. Request following changes:

• Development Options for Site P should refer to a replacement or extension to the food retail.

• Development Principles should refer to: Creation of active frontage to the store on West Street, where practical.

• In terms of the proposed residential element, the Council should remove reference to the number of units, as it is too prescriptive. The number of units on the site will need to be considered as part of the detailed design process, and the Council will have the opportunity to consider proposals as part of the application process.

• Given the importance of the Sainsbury’s store in providing a foodstore anchor for the Town Centre, the Secondary Frontage should be extended along the west side of West Street and take in the existing frontage of the Sainsbury’s Store (fronting the store car park ).

Comments noted. It is necessary to indicate likely capacity of site for residential development to understand cumulative impacts of development. The figures are however indicative and will be subject to determination at planning application stage.

AAP provides guidance on development of Site P and recognises importance of site within Bromley North and contribution to overall retail offer.

RPO83 Graham Snewin, Northpoint Residents

Residents of Northpoint and other residential blocks in area have not been directly consulted with on AAP. Ward’s Safer Neighbourhoods Panel was not included in consultation exercise- an important omission given importance of urban design in crime prevention and fear of crime. Brief should include reference to need for any development proposals to incorporate and fund appropriate crime prevention measures. Any proposals should be subject of full consultation with Safer Neighbourhoods Panel and Police. Council should be more inclusive in consultation processes and ensure all relevant bodies and residents receive direct communication. . Welcome general regeneration proposals for the area, particularly around Bromley North station. But reserve position on any specific proposals when these come forward fro planning consent. Northpoint residents oppose the prospect of Bromley North station having a vehicular access onto Sherman Road- will result in increased traffic and would be unacceptable on highway safety grounds. Vehicular access to station should be from west side of station.

Details of site access will take into account impact on the local environment and other crucial aspects such as safety. Council is committed to full consultation. All planning applications for sites identified in the AAP will be subject to full consultation.

Guidance provided on development of Site A but details are not fixed in AAP.

RPO84 Mark Wiltshire, Bromley Christian Centre

Requested that the removal of Bromley Christian Centre and St Marks School from Site L be re-examined given Church’s stated intention to redevelop site and uncertainty about school buildings. School should be designated as an opportunity site- would offer scope for comprehensive development.

Due to safeguarding for highway improvements, Council has reconsidered boundary of Site L to ensure it is of sufficient size for suitable redevelopment. School is a listed building and Council does not consider it provides opportunity for redevelopment. Future use of the building will be subject to planning policies.

Boundary of Site L amended to include Bromley Christian Centre.

RPO85 Miss Spratt & Mr Lidsey

Development of Site K must not be any higher than the existing car park and should be decreased to improve views from gardens and that it must not encroach any further on the surrounding housing ie: no closer or higher than existing car park. Development should be visually appealing with the opportunity to develop landmark buildings in keeping with local heritage/ unique. There should be no increase in noise pollution or traffic to Newbury Road and no overlooking the residents of Newbury Road from the new development. Developing Site K could be attractive but concerned about possible height, encroachment and visual impact.

Comments noted. Council will seek a high standard of design and to minimise impacts of development on existing residential amenity.

AAP provides guidance on development of Site L and policies on design and height of buildings.

RPO86 Simon Robbins, Bromley PCT

Proposed options and proposals include residential developments of 1600 units, which will increase demand for primary and community health services in the area. Current primary and community health services are at or close to full capacity, and would therefore be unable to meet the needs of additional residents from their current premises. Estimated that an additional 2-3 whole time GPs would be required together with associated primary and community healthcare. PCT are committed to ensuring that health services are delivered from modern, fit for purpose premises, and need to work with LBB to ensure that this can be achieved as part of the AAP.

Council will seek to secure provision for necessary community infrastructure. Sites identified for future provision and Developers will be required to make an appropriate contribution to provision of facilities.

AAP includes policy requirement to make provision for additional and suitable social and community infrastructure to meet needs of increasing town centre population

RPO87 David Hammond, Natural England

Welcomes reference to protection and enhancement of environmental value of area (para 1.8). Broadly supports strategic objectives Key issues identified in para 3.2 make no specific mention of green/ open spaces- should be identified as a key issues and linked to objectives. AAP should highlight opportunity to improve open space surrounding Bromley College as a public open space. Lack of accessibility, poor animation and fragmentation of open spaces together with lack of linkages to each other is a key issue to be highlighted in AAP. Soft measures in para 6.16 are welcomed and broadly supported in context of transport initiatives. Welcomes any initiatives to promote and increase take up of public transport. De-culverting of River Ravensbourne and potential for biodiversity enhancement is encouraged. Site M- should give consideration to enhancing and improving ecological value of area not just economic/ amenity value. This would link in with overall feeling that area’s green spaces are fragmented, under utilised and lack animation. Improvements to overall variety and condition of sites could provide animation and help increase biodiversity potential. Implementation and delivery- support indicator relating to contribution to enhancement of biodiversity (para 8.15) PPS9- Biodiversity needs to be more explicitly referenced in

Council seeks improvement of green / open spaces, as well as promotion of linkages and accessibility throughout the town centre.

AAP makes reference to protection, promotion, enhancement and active promotion of green / open spaces including potential to enhance the open space surrounding Bromley College. Vision for the town centre revised to emphasise the environmental aspects of improvements and enhancements. Reference to need to consider de-culverting the Ravensbourne where feasible in Monitoring and Mitigation section of the SA. Site M- reference included to enhancing and improving the ecological value of the area as well as it’s economic value. Need to repair fragmentation between the town centre’s green / open spaces reinforced. Policies to promote sustainable development including improved green / open space and linkages between. Policy to address poor accessibility throughout the town centre and encourage softer measures such as car clubs and travel plans as part of comprehensive Transport Strategy..

Action Plan- need to state that improvements to green/open spaces need to include environmental enhancement as well as amenity and economic value. Action Plan an ideal opportunity to address fragmentation of open spaces and lack of animation. Sustainability Appraisal- support reference to green roofs and Sustainable Urban drainage Systems- Council should also give consideration to brown roofs and green walls to link with PPS9. Need to consult Greenspace Information for London (GIGL) for records of biodiversity data including statutory and non-statutory sites and habitat locations.

RPO88 Capital Shopping Centres

AAP must address failure of town centre to deliver significant new retail space since The Glades opened. AAP must identify how amount, range and quality of retail offer can be secured to maintain its competitiveness. Support extension of Glades and relocation of leisure centre to accommodate new retail floorspace. Object to deletion of extension to the car park at Bromley Civic as result of traffic modelling. Increased retail floorspace will give rise to increased usage and pressure on existing parking. Support public transport improvements but this needs to be complemented by an ample supply of parking to ensure that high levels of parking do not impede accessibility into town centre. Supports timescale for extension of The Glades. Extension of car parking should be reinstated in Site F. Supports use of Queens Gardens for open space and public realm improvements but need more flexibility for The Glades to respond to changing retail and commercial needs. Allocation should recognise that there may be justification for incursion into public space subject to mitigation eg: replacement open space or enhancement of existing areas.

A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision and restraining parking where appropriate. A Parking Plan will be looking at both off-street and on-street parking provision. It would be inappropriate to have a major expansion of car parking due to the traffic impacts. A balanced approach is being adopted as part a comprehensive transport strategy.

Development of Site E moved to Phase 3 to secure relocation of leisure centre and to ensure transport impacts can be accommodated as part of comprehensive strategy.

Development must be phased in relation to retail needs- failure to do this may result in less favourable sites coming forward for development in advance of those that best satisfy policy requirements. Welcome identification of Site E in Phase 1- can meet retail needs to 2012.

RPO89 Daniel Meades

Town centre is too linear and lacks a heart. Unclear from the proposals what the plan is for the North End of Market Square. Need to remove heavy traffic and address dangerous vehicle access to Church Road and Glassmill Lane. Need more choice in small independent shops. Support for public art to reflect Bromley’s past literary and historic culture and a good modern public building eg: a sports centre resulting from a competition. Early improvements to Bromley South Station and relocated post office are early priorities. Need to address poor quality environment and improved quality of retail offer.

Objective 8 of the AAP states, ‘Improving transport and accessibility and encouraging use of more sustainable modes of transport’. The AAP seeks to improve pedestrian safety and accessibility within the town centre and detailed proposals. Council places importance on improvement to public transport facilities and will work with Network Rail to secure improvements to Bromley North and South Stations.

Inclusion of policies on transport and accessibility, range of retail, incorporation of public art and high design quality. AAP seeks to secure improvements to station interchanges and provides guidance on this.

RPO90 Mick Lane, Crime Prevention design Advisor, Metropolitan Police

AAP should include a policy around security with designing out crime with respect to new developments and those which may be altered. All new development should be designed to meet the requirements of the Secure By Design scheme. Should a large development be proposed including associated car parking, car parks should be designed to meet a Safer Parking accreditation. This will achieve a consistency in safe, secure and sustainable design and build rather than relying on individual design statements. Highlight importance of anti-terrorism measures, e.g. bollard

Council is committed to secure by design principles.

Requirements to meet Secure by Design included in policy.

installation and CCTV installation. RPO91 Major Andy Cox, Salvation Army

Wish to stay within Site G as part of development proposals- have been established on site for 68 years, easy access makes site convenient for people to use facilities, have recently invested over £200,000 in refurbishment of on-site café and shop. Need to be in heart of community. Request that as development of Site G takes place, developers will relocate the centre within area so as to retain high profile.

Comments noted Reference to requirement for re-provision of existing faith groups in development of Site G strengthened

RPO92 Richard T Marks, MSE Property

Expressed concern that the addition of 500,000 sq ft of retail space will have a detrimental impact on the secondary and fringe locations. Businesses on upper High St north of Market square are struggling and additional retail space (particularly A3) will exacerbate this).

Bromley has capacity for increased retail floorspace and the Council is required to demonstrate how this can be accommodated. A range of retail space is proposed.

Polices included for improvements to North Village and promotion of independent traders

RPO93 Chris Price, Network Rail

Residential potential of Site A is greater than 250 units. London plan density matrix suggests site could achieve density of 240-435 units/ ha in this location. Need to increase number of units to ensure viability and delivery of benefits identified in AAP. Reference to replacement public car parking on Site A should also include the replacement of station car parking. Site A area does not reflect the full extent of the land that may be required for a comprehensive development and that properties fronting onto Sherman Road should be incorporated into the site area. This will assist in providing station interchange facilities Support reference to creating a comprehensive scheme and the potential use of compulsory purchase powers, however the statement should also state that a phased approach to the comprehensive development is acceptable in the interests of flexibility of development. Commented that Network Rail believe that Site A should be developed within the next 5-10 years (Phase 2).

Comments noted. Council will work with Network Rail and developers to secure redevelopment of Site A including improvements to station. The transport impacts of increased residential units on Site A will be considered as part of a detailed transport assessment.

Reference included to requirement for comprehensive approach to development of Site A to secure comprehensive redevelopment and transport improvements. Reference to the replacement of public car parking includes the replacement of station car parking. Timescale for development of Site A brought forward to Phases 1/ 2. Mixed use development over railway removed from Site J due to uncertainty regarding viability and delivery.

Area included in Site J does not reflect the full development potential of the site (could include land shown in Site H). Support reference to creating a comprehensive scheme that comes forward in a phased manner. Welcome reference to the Town Centre Improvement Initiative and pooling of planning obligations eg: public transport. Hoped that Town Centre Improvement Initiative can help contribute to improvements to Bromley South and North Stations which will have significant benefits. AAP should make clear that proposals which directly provide public benefits at substantial cost to development will have these costs taken into account during Section 106 negotiations and will not be subject to normal requirements.

RPO94 Government Office for London

Queried whether key diagram would be included in AAP. Para 1.10 which states that policies in UDP can be saved for 3 years until 2009 -LPA can apply for extension of UDP policies after that time Cross reference to density location and parking matrix in UDP to avoid duplication (can exclude Table 2.1) Information in Table 2.21 incorrect- all UDP policies saved for 3 years from date of adoption. Welcome reference to sustainable Community Strategy. Welcome inclusion of ‘Context and Issues’- background information will provide more meaningful responses to consultation Question whether Strategic Flood Risk assessment be completed in time for findings to be taken into account prior to submitting AAP to Secretary of State.

Comments noted. The findings and recommendations of the final SFRA will be incorporated in the SA and AAP. Collaborative workshops, presentations and meetings were carried out at the Issues and Options Consultation stage. Proposals have been subject to discussion with TfL and other stakeholders. It is proposed that further discussion will take place to assist the revision of the document in preparation for the final draft of the AAP. Only non prescriptive references will be made for taller buildings as their specific heights will relate to the quality of the specific development. Each development will have to adhere to strict environmental assessments, including views analysis.

AAP text and tables amended to reflect comments. Vision for the Town Centre includes cross reference to SA and Sustainable Community Strategy References to taller buildings clarified in guidance on Sites G, K and A. Clarification of engagement of stakeholders including businesses and land owners. AAP includes risk assessment. Mixed use development in Site J deleted due to uncertainty about viability and delivery

Vision for Town Centre- should be cross referenced to Sustainability Appraisal and Sustainable Community Strategy. Has exploration of scenarios with stakeholders included initial Issues and Options Consultation stage. Would be helpful to cross reference preliminary Scenarios to sustainability Appraisal Transport Strategy- have proposals for network/ junction improvements and freight distribution been discussed with TfL in relation to feasibility and funding? Will there be any implications for taking forward AAP if any transport proposals do not go ahead? Need to clarify what Code for Sustainable Homes means. The potential for taller buildings is identified on Site G and Site J. Will there be a maximum height and what environmental considerations will they be subject to? Welcome inclusion of Table 7.1- would be useful to cross reference to Table 8.1 in relation to implementation and phasing. Need to clarify what work has been undertaken with local and key stakeholders and businesses in preparing AAP including Local Strategic partnership. Question whether the Council has cooperation of all local owner/ occupiers to take forward proposals. If not, will this prevent the regeneration of sites if CPO powers cannot be used. Would preferred options be flexible enough to cope with this and could alternative uses be provided? This relates to Tests of Soundness.

The process of producing the AAP has involved public engagement from the very earliest stages in accordance with the SCI. Consultation with a range of stakeholders occurred between May to September 2005. Further public consultation was held on the Preferred Options over a six week period commencing 13 January and ending 24 February 2006. Through workshops with key stakeholders and public consultation on the initial Preferred Options early in 2006 the Council has sought to hear the views of those with an interest in the town. The draft AAP will be accompanied by a report outlining details of the whole public consultation and engagement process which was undertaken during the preparation of the plan. The Council will undertake a feasibility study on future accommodation prior to proposals for redevelopment of Site F.

Site F highlights action to undertake feasibility Study to assess current and future requirements for civic accommodation, potential relocation of leisure facility and extent to which surplus land can be made available for low density residential development. Will this be completed before submission of AAP? Question how work is progressing with network Rail, landowners and developers to promote phased comprehensive scheme for Site J Welcome the inclusion of assessment of proposals against tests of soundness.

RP095 Mr G Faratro Capisano Restaurant Mr Hasip Surtex Textiles Care Centre

Strong objection to redevelopment of Westmoreland Road Car Park. Owners of family businesses in Simpsons Road which will be threatened with closure if site redeveloped. Council has advised that leases will not be renewed. Would like to be considered for possible relocation in mixed use redevelopment of site

Comments noted. Replacement of car park required as it is in poor state of repair. Redevelopment of site is required to take forward vision for town centre and to secure new facilities and regeneration. Proposed uses for Site G include cafes and restaurants. These premises would be available to the market.

No change

RPO96 Mr & Mrs Winter

Need to resist proposals to reduce or damage open spaces or affect public access- in particular the Civic Centre grounds and Bishop’s Palace. Bishops Palace should be developed as the Bromley Museum with surrounding gardens. Civic Centre grounds should not be developed for housing.

The vision of the AAP is to promote a distinctive centre with high quality public spaces. Improvements and enhancements to the public realm are proposed which will benefit the town centre.

References strengthened to protection and enhancement of open spaces

RP097 Religious Society of Friends

Welcomes provision for religious needs of faith community. Questions availability of sufficient car parking to meet needs of groups.

Public parking will be available for town centre uses as part of comprehensive transport strategy. Use of public transport will also be encouraged.

No change

RP098, Bromley Little Theatre

Planned development of theatre will add to contribution to achieving aims of AAP- should be explicitly recognised in AAP. Seek designation of Bromley Little Theatre as a theatre on the grounds that it has been a theatre for 70 years and forms part of town’s heritage. Will ensure a diverse range of activities and cultural and leisure facilities for planned population increase; management of evening economy to attract a wider range of visitors including families with children; extend range and quality of leisure and entertainment facilities; protect and enhance the heritage and distinctive character of the town centre, particularly North Village. Propose physical development of site to provide improved facilities: adding a studio to provide a third live theatre venue in town centre; training facilities; doubling of capacity and a community facility for arts and culture. Also propose to develop community arts and cultural programmes and to work with council to deliver Borough-wide initiatives such as arts festivals.

Comments noted. Council welcomes proposals to improve facilities and recognises important role played by Bromley Little Theatre in cultural and community life.

AAP includes policy relating to cultural and entertainment facilities and need to protect and enhance existing facilities. Specific reference included to importance of Bromley Little Theatre.

RP099 Friends of Bromley Towns and Gardens

Welcome value placed on historic environment and parks and gardens- however, heritage issues not addressed in any meaningful way. Economic strategy is at odds with Council’s statutory duty to preserve elements that contribute to character and appearance of town centre conservation area. AAP must address past damage caused by development. AAP is unbalanced and biased towards development and visitors- no concern for heritage and will result in loss of historic character of the town. Object to proposals for Site F- Proposals to sell off heritage sites such as Bishops Palace and park for housing to raise revenue and relocate the pavilion is unacceptable. Propose reinstatement of Listed palace building as central feature in restored parkland; cultural and leisure use and park status with full public access; visitor attraction. Object to proposals for Site B- will be harmful to setting of town centre conservation area and views of grade I Listed Bromley College. Wish to see green setting of Bromley College and building as landmark gateway to Bromley rather than a block of flats; landscaping of site to preserve open aspect into College Grounds; open up views of college facing Tweedy road; consider low scale development such as a nursery school- making use of open areas for play and allowing views to be preserved and enhanced. Object to Site G- any buildings on site taller than roof heights of houses in Ethelbert Close will be harmful to character and appearance of Library Gardens, Church House Gardens, Martins Hill and Queens mead and the High Street. Development will contravene Council’s statutory duty to preserve or enhance character or appearance of conservation area. Propose that historic open views from parks and gardens within conservation area should be

Comments noted. The vision of the AAP is to promote a distinctive centre with high quality public spaces. Improvements and enhancements to the public realm are proposed which will benefit the town centre. Open spaces will be protected and enhanced. Discussion taking place with Environment regarding culvert. No loss of existing parkland will be permitted in redevelopment of Site F and parkland will be available to public access. New developments will be required to contribute to open space and play provision and enhancements of existing facilities.

Guidelines for Sites B, F and G strengthened to highlight importance of protection and enhancement of open spaces, conservation area and setting of listed buildings.

retained with skyline of trees rather than urban development. Site M- no objection in principle to café/restaurant provision provided it does not encroach on garden with any permanent or semi-permanent structure. Opposed to any loss of green space. Any café use should be restricted to Glades terrace. Queens garden is a drinking control area- sale of alcohol must be prevented or restricted. Site E- design of building must complement the Garden and be of a height no greater than the pavilion to protect what remains of open aspect of garden. Bromley Oak must be preserved. Preservation of open aspect and sunlight on south side of garden must be preserved as part of essential character of conservation area. Site D-,opposed to further urbanisation of upper margin of Martins Hill- will result in loss of character and appearance. Site N- generally welcome proposals if they offer enhancement of Library gardens and no part of Gardens paved over and Ravensfell House retained to give heritage status to enlarged space Would like to see firm proposals for integration of town parks into social and commercial life of Bromley without detriment to their essential character and appearance and improved leisure facilities. Would like to see firm proposals for green linkages between town and parks including palace grounds with signage and landscaping. AAP should include recognition of value of restoring River Ravensbourne to a natural amenity

RP100 Sonia Whitaker

Concern about traffic congestion- many routes already subject to delays before new developments take place. Need to give traffic problems high priority.

Comments noted. The Council has prepared a comprehensive transport strategy which addresses issues of congestion and impacts of new development

AAP includes proposals for transport improvements to address congestion.

RPO101 Rob Cundy, Bromley Town Business Forum

General support but raised following concerns: • progress of the AAP should be made available to

the forum group, businesses and public. • Car parking is an issue- if new retailers are to be

introduced into the area there will be a significant increase in the number of staff and customers into the area. Need to increase number of car parking spaces including cheaper and more convenient park and ride facilities for staff thus freeing up spaces for customers

• Temporary/ interim car parking facilities should be made available before Westmoreland Road car park is demolished to ensure sufficient capacity is maintained.

• Ongoing work needed to encourage improvements to street scene, pavements and shop frontages, business and people needs to be constantly addressed, including street scene, pavements and shop fronts.

A managed approach to parking will be adopted for the AAP, including making the best use of existing car parking provision. The Parking Plan considers both off-street and on-street parking provision and future park and ride initiatives. Temporary facilities will be provided during redevelopment of Westmoreland Road Car Park. Council is promoting improvements to street scene to create a more attractive business and retail environment. Consultation undertaken with local businesses

AAP includes proposals for transport improvements and comprehensive parking strategy

RPO104 A Sheppeck

Commented that the roads in and out of Bromley cannot cope with the current high-level of traffic, and will be far worse once redevelopment begins. Commented that Bromley is lacking some essential shops such as a drapers, hardware shop and butchers. Suggested that a commuter car park over the platforms at Bromley South would alleviate current parking problems.

The AAP is looking at transport provision in the town centre and how this can be taken forward in a holistic way through a transport strategy and parking plan. The AAP supports the use of sustainable modes of transport to encourage travel into the town centre by modes other than the car. A range of retail will be supported including independent traders.

AAP includes proposals for transport improvements and parking strategy Bromley North designated as Improvement Area to enhance environment for smaller retailers

RPO105 Rob Bristow

Concerned about mixed use proposals for Bromley North- may conflict with residential character of surrounding area. Plan needs to be more specific about location of uses and acknowledge the importance of safeguarding existing residents’ amenities. Commercial uses should be located adjacent to station. Questions need for more parking. Plan should specify that residential is preferred use. Should allow for residential on northern part of site to proceed in advance of southern part- not interdependent.

Comments noted Development guidelines included for Site A to ensure appropriate distribution of land uses and interface with adjoining residential areas. Residential mixed use development is proposed

RPO106 J R Goodman Property Consultants

Object to development of Site G: • Traffic congestion, parking and lack of space cause grid-

locking • Pollution and disturbance to residents during construction • Reduction in property value • Department stores extending down Ethelbert Road will be

too close to residents and cut in to the conservation area. • Delivery vehicles will cause disturbance to residents. • Proposals are over-ambitious • Lack of consultation

Comments noted. There has been widespread consultation on the preferred options and revised options. Comprehensive redevelopment of Site G considered to be necessary to accommodate retail requirements and to achieve regeneration of town centre. This could not be achieved by piecemeal development schemes

Development guidelines for Site G seek to protect residential amenity and set out requirements for transport improvements and other mitigation measures to minimise impacts

RPO107 Tamara Galloway, Green St Green Village Society

Expressed concern that the Civic Centre site may be sold off for residential development. Commented that the current Pavilion leisure centre should stay where it is. Commented that enlarging the Glades may have a detrimental impact on the rest of the High Street. Commented that a café or coffee house in the Queens Garden should be within the Glades building to avoiding eating up any of the garden space.

Redevelopment of Civic Centre site could include small element of lower density residential development. This will not be main use of site. There is a need to accommodate additional retail demand in town centre. Council seeks to enhance leisure facilities. New leisure centre would provide opportunity to meet current needs and would be as accessible as The Glades. No loss of garden will be permitted in Queens Garden

AAP includes guidelines for Opportunity Sites to address issues of leisure provision and protection of open space

RPO108 Simon Taylor, AtisReal

Welcome the amendments to Site L and exclusion of adjacent sites. No objection to indicative development areas for the purposes of calculating housing supply in the borough. Would oppose any restriction on development density on Site L which would be contrary to other policies in the UDP and AAP. Currently looking at scheme for 124 residential units and 90 bed hotel on grounds of design and viability. Opening the culvert of the River Ravensbourne would be inappropriate as it would sterilise parts of the town centre for future development. Expressed concern that there is a lack of clarity regarding necessary junction improvements and Section 106 contributions and would stress that every attempt should be made to prevent delays in development whilst necessary junction improvements are made.

Comments noted. The boundary of Site L has been amended due to need to accommodate transport safeguarding line. This has required inclusion of adjacent site to achieve suitable development area. The capacities shown in the AAP are indicative figures and will be subject to determination of planning application.

AAP includes proposals for transport improvements and developer contributions. Guidelines for development of Site L including need for FRA.

RPO109 Mrs Brodie

Expressed concern that the roads around Bromley will come to a standstill if all the AAP proposals go ahead. Commented that the town centre is too contained to allow for a new road system. Expressed concern that the local schools, hospitals and

Extensive traffic modelling has been undertaken for Bromley town centre to understand the impact of development on the town centre traffic flows.

AAP includes proposals for transport improvements and parking strategy

to demonstrate significant regard for historic environment assets impacted upon by the development. All listed buildings and their settings are expected to be protected and enhanced. The archaeological implications of any application will need to be fully assessed at pre-application stage and further archaeological advice sought from the Greater London Archaeological Service (GLAAS) at English Heritage.

• Include need for archaeological assessment at pre-application stage in proposed mitigation column

• Recommend adding Buildings at Risk to indicator column in Table 8.4.

Comments on AAP: • Refer to nationally and locally listed buildings. Concept of

historical development section would be better developed as a mini-characterisation of area. Need to provide greater sense of Bromley’s identity.

• Welcome historic assets map- but should include archaeological priority areas and scheduled monuments

• Include reference to need for full archaeological assessment at pre-application stage for sites involving historic assets

• Bromley North- include reference to need to avoid compromising legibility of listed building: benefits include protection and enhancement of historic environment (also Sites B and F)

• Protection and enhancement of historic environment should be a principle underpinning AAP

• Early consultation with English Heritage should form part of Actions column in table 8.1 for sites of historic importance (especially Sites A, B and F). Include reference to need for full archaeological assessment at pre-application stage

• Need to include PPG16 Archaeology in Appendix 2 • Welcome heritage statements under Design and

doctor’s surgeries would not be able to cope with the proposals. Commented that the junction at Hayes Lane/ Westmoreland Road is a dangerous area.

Council has prepared a comprehensive transport strategy including measures to address congestion.

RPO110 Claire Craig, English Heritage

Welcomes proposals to regenerate town centre- congratulates Borough on demonstrating a high level of awareness of need to protect and enhance historic environment. Specific points need strengthening in SA: • Historic environment objective in SA to be strengthened

by substituting ‘valued’ with ‘the’ • Adjust heading in SA from Design to Heritage and Design • Need to ensure consistency between SA and AAP

objectives- need to consider impact on cultural heritage as distinct from other aspects of built environment

• Does not concur with view on p29 that heritage protection and enhancement can conflict with principles for a vibrant centre- preservation of historic environment is a fundamental requirement for a vibrant centre- text should be amended

• Welcome recognition of heritage significance of North Village- would like to see same acknowledgement of heritage elements of Northern gateway site

• Would like to see heritage requirements specified at Bromley North station and Bromley Civic Centre

• Welcomes recognition of importance of setting of Bromley College and design considerations for Site B.

• Heritage considerations pivotal for Sites A,B, and F • Incorporation of Listed Station Building in site A will need

to avoid compromising its legibility. • Archaeology needs greater inclusion. Archaeological

implications need full assessment at pre-application stage and further advice can be given by Greater London Archaeological advisory Service at English Heritage. Particularly important for Sites B and F

• Revise para 8.1.8 Planning applications will be expected

Comments noted. SA strengthened to reflect comments. AAP policy and Guidelines for Opportunity Sites highlight need to protect and enhance historic environment and need for early consultation with English Heritage.

Conservation objectives but request that historic elements of public realm and environment be included in Appendix 4

RPO112 Tom Sharland, SUSTRANDS

Queried whether the proposals include any provisions for improving cycle facilities- in particular safe routes and parking. This would fit in with leisure objectives.

Council has prepared a comprehensive transport strategy including provision for cyclists.

AAP includes proposals for transport improvements including facilities for cycling

RPO113 Dennis Barkway

Need to give consideration to phasing and timescale for development. Need implementation plan to identify aspects in council’s control, those that require consent of others and those that are dependent on 3rd party investment. Council must commit itself to doing things that will help to achieve inward investment eg: park and ride. Need statement on when Council is prepared to use CPO powers Interesting debate to be had on location of new leisure centre and whether a town centre location is essential or Stockwell Close the best or adequate location

Park and ride has been put forward as an option within the transport strategy. The A21 has been included in the strategy as a priority for consideration. These issues will be considered in further detail in implementation of AAP

AAP includes policies on implementation and phasing.

RP114 Trustees of Bromley and Sheppards College

Object to Site B on grounds of impacts on Colleges. Segment of site on junction of Tweedy Road/ London road should be excluded- college enhances entry to town and development would close off views. Concerned about density- proposals should be considered on merits particularly where heritage sites are concerned. AAP should not specify number of units or density. Range should be 60-100 applying the SDS formula- would be lower if area reduced Density range is based on flatted development only- should be 25-100 units Concerned that AAP is being driven by Broomleigh proposals- should not defer to a particular developer. Shift in density supports concern that AAP is being tailored to suit

Comments noted. The number of units and density is indicative and will be determined at the planning application stage.

AAP includes development guidance for Site B to protect setting of historic buildings. A high quality design and development will be required.

specific development RP115 Mayor of London

Raises key issues to be addressed prior to submission: • Deliverability- clarification sought about how realistic it

will be to expect sites to be delivered within prescribed timescales especially with regard to amount of housing (specifically family housing). A number of sites have not been identified in the 2004 Housing Capacity Study and the evidence base for proposals must be substantiated more fully;

• Residential development- expected that any applications will meet Mayor’s target for affordable housing in levels of provision and tenure split. Questions raised about how children’s play space and other amenity space needed to support family housing will be accommodated in high density development.

Broad planning objectives heading towards conformity with London Plan but if issues not addressed this may lead to an opinion of non-conformity at submission stage. Supports intention to promote significant change and development in town centre in order for it to realise its full potential and provide a more attractive place to shop, work, live and visit. Promotion of variety of uses is welcomed. However, AAP still needs to demonstrate in more detail that the town centre has capacity to accommodate proposed uses. Should justify scale of increased retail floorspace proposed and any significant increases should be based on comprehensive assessment of retail need and capacity and tested sub-regionally through Sub-Regional Development Framework which has set a limit between 35,000- 51,000 sq m. Evidence base must show how much additional new floorspace is proposed and why the tested limit in SRDF should be exceeded.

Comments noted. The Council has addressed issues of deliverability in modifications to the preferred options. Comprehensive transport strategy seeks to address issues of congestion and promote public transport. Evidence base for retail development consistent with SRDF. Council concerned about protecting character of Bromley Town Centre with emphasis on maximising development potential of sites. Density of development must reflect character of surrounding area.

Policies included on housing mix and play provision. Sites which may be suitable for delivery of larger units suitable for family occupation identified. Policy included on improving use of energy in line with London Plan. Reference to local training included in potential Section 106 contributions.

Inclusion of a policy approach that seeks to maximise development potential of sites consistent with London Plan Policy 4B.3 would be welcomed. Key policy area relates to improving use of energy (London Plan Policy 4A.7). AAP will need to include policies that support relevant London Plan policies and require applications for major developments to include energy assessments as set out in London Plan Policy 4A.9. AAP will need to require major developments to provide for renewable energy (London Plan Policy 4A.10). LDA requests inclusion of employment and training for local people and creation of opportunities for local businesses especially SMEs and those owned by BAMEs to be included in list of potential Section 106 contributions. Tacking high levels of traffic congestion and improving image, accessibility and reliability of public transport is a fundamental issue. Supports partnership working with TfL and others.


APPENDIX 4.1

REVISED PREFERRED OPTIONS (NOVEMBER 2007-JANUARY 2008): REPORT TO COMMITTEE

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Report No. E&LS08017


PART 1 - PUBLIC

Agenda Item No.

Decision Maker: DEVELOPMENT CONTROL COMMITTEE

Date: 12TH February 2008

Decision Type: Non-Urgent Non-Executive Non-Key

TITLE: BROMLEY TOWN CENTRE: Responses to the Revised Preferred Options Consultation

Contact Officer: Rita Westlotorn, Manager Town Centre Development Team Tel: 020 8313 4582 E-mail: [email protected]

Chief Officer: Paul Dale Acting Director of Renewal and Recreation

Ward: Bromley Town

1. Reason for report

To update Members on the responses received following the recent consultation on the Revised Preferred Options and the revision to the AAP timetable given the need to assess some responses in more detail.

________________________________________________________________________________

2. RECOMMENDATION(S)

Members note the report.

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Corporate Policy Existing policy: ________________________________________________________________________________ Financial 1. N/A The cost will be calculated when the process is complete 2. Non-recurring cost 3. Budget head 4. Total budget for this head £ ________________________________________________________________________________ Staff 1. Number of staff (current and additional) – no additional staff 2. If from existing staff resources, number of staff hours – cannot be estimated ________________________________________________________________________________ Legal 1. Non-statutory - Government guidance: 2. Call-in is not applicable: ________________________________________________________________________________ Customer Impact Estimated number of users/beneficiaries (current and projected) - cannot be estimated

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3. COMMENTARY

The Revised Preferred Options for Bromley Town Centre underwent a six week consultation period commencing 31st October to 11th December 2007. In all 115 responses were received either by letter or via email. Some of the responses were extremely detailed and it is clear that additional work will be required in order to fully assess some of these representations to determine whether any significant changes will need to be made to the draft plan prior to submission.

This will inevitably mean that the draft AAP will not be available in March as previously anticipated. Unfortunately the current planning legislation does not suggest any further consultation between that carried out on the Preferred Options and the consultation on the submitted draft AAP. However, it is considered that in order to ensure the submitted AAP is complainant with the ‘Tests of Soundness’ requirements which will be considered by the Inspector at the Examination in Public, any significant changes to that previously in the public domain should be consulted on. This would not require such detailed consultation as carried out on the Options, but would include specific consultation with those most affected by the proposals.

The revised timetable is now as follows:

AAP Revised Timetable Date

Consideration of the extended consultation document end April/May 2008

Consultation on the extended consultation document May/ June 2008

Recommendation on additional revisions to Options to DCC & Executive June/July 2008

Consideration of Draft AAP by DCC & Executive

Approval of Draft AAP by full Council Special meeting July or September 2008

Submission of Draft AAP to Secretary of State September/October 2008

Pre-examination meeting* January 2009

Examination in Public* April 2009

Receipt of Inspector’s report* October 2009

Adoption of AAP* December 2009

* Dates subject to Secretary of State programming

Responses received

The Government Office for London (GoL) raised mainly procedural issues in order to ensure the draft plans compliancy with the ‘Test of Soundness’ as well as requiring calcification on particular statements.

The Greater London Assembly (GLA) have, amongst other issues, commented on the need to maximise site development as well as the need for the Plan to be in conformity with The London Plan. To address these comments it is considered that the site allocations may have to be reviewed in order to ensure the Mayor of London does not raise objections to the draft AAP.

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There are also two responses which suggest major impacts to individual Opportunity Sites. These will need to be assessed not only in relation to possible site alterations but in order to assess the impact of such a development on the other identified Opportunity sites and overall objectives for the town.

Site A: Bromley North. Much of the site is in the ownership of Network Rail although the Council does have some limited land interests. The representation suggests higher residential density and parking allocations plus the boundary should be extended to include properties in Sherman Road and a small office development in Station Road. Network Rail who are keen to bring a suitable development forward consider higher residential densities should be included in accordance with London Plan standards and that the phasing of the site should be brought forward into Phase 1. The issue of re-phasing may in turn have implications for traffic management within the town.

Site G: West of High Street. This is from a developer interested in bringing forward a comprehensive development which would include commercial, residential and additional parking. The amount of residential and parking identified, as well as the size of the site suggested vary significantly from that in the consultation document. The representation suggests that in order to revive and modernise the town centre with an updated retail offer, a scheme, that would also provide a new department store, cannot be delivered unless development values are substantiality increased above that identified in the Revised Options.

One large site is suggested which would include within its boundary Site G, Site H: corner of Ravensbourne Road/High Street and part of Site N: the terrace outside of the Churchill Theatre/library. The current building occupied by Habitat is also included and the whole of the site is in multiple ownership. A key component is the site of the annex to the old Army and Navy store which currently benefits from a planning permission for residential units (163). The Revised Options currently shows 450 residential units on Site G and 50 units on Site H whereas the developer believes a figure of approximately 1200 units would be required over both sites. This amounts to approximately 700 additional units over and above those already identified.

The regeneration of the town is a Council priority and specifically there are aspirations for a new department store. Therefore given the extent of the scheme suggested it would seem logical to explore this significant opportunity in more detail.

Other comments

Further comments received vary from specific issues regarding site allocations, transport implications, the impact of growth on existing services such as health and school places to better provision for cyclists and for arts and community facilities. One area of concern is the need to ensure new development is accessible by all, specifically those with any disability.

English Heritage welcomes and supports the Borough in its intention for regeneration and in particular strongly support Objective 5 regarding the protection and enhancement of the Borough’s heritage as well as the historic and heritage statements. However, they consider that reference to the listed buildings on Site A – Bromley North and Site F – Civic Centre should be expanded. Whilst supporting the recognition of the importance of the Grade 1 listed building to Site B – Tweedy Road, they believe more emphasis should be given regarding archaeological implications on this and other sites and some specific points warrant strengthening. Other responses also raised concerned about the impact of development on heritage buildings and the Conservation Area generally and felt that the statements regarding such issues were not explicit enough. All AAP documentation published to date has endeavoured to make clear that whilst the regeneration of the town to ensure future economic viability is crucial there is a balance to be made in that the town’s heritage is important, however, given the comments received matters relating to the historic environment will be reviewed.

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A number of comments were received regarding the phasing of a new leisure facility if the existing Pavilion were to be re-developed. Local residents are concerned that they would be left for some time with out such a facility.

The Environment Agency raised some issues that will be dealt with under the Strategic Flood Risk Assessment that is currently being progressed. Responses, amongst others, were also received from the London Fire & Emergency Planning Authority, the Metropolitan Police, English Nature, Thames Water, TfL and The Highways Agency.

Many of the other issues raised can be dealt with via new AAP policies, by re-assessing the development principles suggested for each site or by the consideration that the comment does not warrant any change to the plan. The report on any recommended alterations to the Options will also detail the Council’s responses to all comments received.


APPENDIX 5

CONSULTATION DRAFT AAP (NOVEMBER 2008- JANUARY 2009): RESPONSES TO CONSULTATION

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BROMLEY TOWN CENTRE DRAFT AAP CONSULTATION RESPONSES 2008-2009 Ref No

Name & Org Date Received Summary of Representation LBB Comments / Response

DAAPO1 Babbacombe Rd Residents Association (1)

20/11/2008 • Commented that a bullet point on pg 209 of the AAP regarding the potential for taller buildings refers to an existing 15 storey tower east of the Opportunity Site. At present there are just 2 buildings at 10 and 7 storeys therefore needed clarification.

There was a drafting error in assessing the site and the design guidance will be amended.

DAAP02 Bonnie Merralls

18/11/2008 • Queries on whether her property is likely to be compulsorily purchased as a result of the plans and if so, when this was likely to be.

The property is within Site G, however, no CPO has as yet been issued and probably would not be affected by blight issues until at least the end of 2009 when the AAP is formally adopted.

DAAP03 Beckenham Liberal Democrats

15/12/2008 • Welcomes the plans to improve access to Bromley South Station

Support welcomed

DAAP04 Patricia Watson

29/11/08 • Commented on access to Bromley South Station Bromley south station has been identified by the DfT for improvement under the Access for All programme. Funding is currently being sought by Network Rail

DAAP05 Bromley Friends Forum

18/12/08 • Against the proposed development of tall buildings adjacent to Library Gardens which would alter the historic skyline.

The design principles for each opportunity site that are set out in Appendix 4 scale and massing be assessed with particular regard to views from the gardens. The skyline of the town as viewed from Library Gardens has been affected by more recent developments including the Churchill Theatre/Library building.

• Against plans to develop housing on Site K The town centre and immediate environs are sustainable locations for housing given their access to public transport, shops, services and jobs. Residential development is considered a vital element in the regeneration of the town. It will ensure that the town is populated in the evening and night-time, making it busier and safer. With careful planning and design potential issues of disturbance and nuisance, noise and light pollution can be avoided.

• Against housing in the town centre considering the implications on congestion and pollution

• Against any increase in the height of the Glades building and the number of commercial spaces available would have a negative effect on pollution and congestion.

The Retail Capacity Study, which is being updated, and the GLA have both indicated that the retail floorspace should be increased to meet future needs. The Transport Strategy will address highway concerns

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• Commented that the Council is trying to adopt measures that are in conflict with their aims of improving the environment and safeguarding wildlife.

The Plan encourages retention of existing green spaces and is in accordance with the ‘Aims of Building a Better Bromley’. Developments will be required to ensure the protection and safeguarding of nature conservation interests within and beyond the town centre boundaries

DAAP06 Director Transport & Travel Research Ltd and Co-ordinator South London Freight Quality Partnership,

22/12/2008 • Welcomed the fact that freight transport and the emerging role of Delivery and Servicing Plans (DSPs) was recognised as one of the four key projects within the London Freight Plan and explicitly mentioned in the Area Action Plan

Support welcomed

• CLPs may also be considered relevant to Policy BTC 8 Sustainable Development and Construction as existing construction codes of practice do not commonly include the full logistics chain as part of their terms of reference.

Agreed. The following wording to be added to Policy BTC8: In respect of major new developments, developers will be required to submit Construction Logistics Plans for approval prior to commencement of construction. Add new paragraph: 4.6.x For major new developments, the Council will expect developers to demonstrate that sustainable logistics practice will be applied through the submission and approval of Construction Logistics Plans.

• Off-road servicing’ should be promoted as it provided more flexibility.

Agreed. Amend Policy BTC29 and paragraph 4.8.51 to refer to off road servicing rather than rear servicing.

• Need to refer to Construction Logistics Plans (CLPs) within Policy BTC29 Freight and paragraph 4.8.53 - that the submission of CLPs should be a minimum requirement for all major new developments that are forthcoming as part of the Area Action Plan.

Amendments proposed to Policy BTC8 and supporting text (see above).

• Re-wording of part of paragraph 4.8.51 - ‘although the Council recognises that deliveries at night….can potentially be more disruptive to residents’ be turned to a positive phraseology such as ‘and the Council recognises the potential benefits of out-of-hours deliveries (including activity at night) where appropriate measures and management techniques are introduced to reduce potential disruption to residents’.

Disagree. It is important to ensure a balance between the need for out-of-hours servicing and residential amenity.

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DAAP07 Tony Anderson 06/01/2009 • Commented on the lack of linked services and sports provision at affordable rates for young people.

One of the aims of the AAP is to bring about more inclusive development and opportunities for all age groups. The AAP is a Spatial Plan i.e. a planning policy framework , so the finer details of individual schemes would need to be discussed as planning applications are progressed • Expressed concern that areas for young people to

meet and use are important as they need to be engaged in constructive agenda free schemes to develop positive views of the Council and Society in general.

• Commented that Council provision was costly and is hoping that greater age related inclusion as part of every scheme to improve or alter the local community environment.

DAAP08 Frank Whiting

13/01/2009 • the DAAP may be controversial due to the scale of development proposed, the unprecedented level of retail closures in the town stressed the need for Bromley to have the type of units and retail environment that will attracts new high class tenants when the economic climate starts to improve.

Support welcomed. BTC is not fairing well in relation to other like centres as it does not have the types of units modern retailers require so the comparison element in the town is not as strong as it should be therefore shoppers are going elsewhere. This impacts on job opportunities and the local economy generally.

• A resident population will encourage leisure outlets that cater for a wider public.

• Bromley’s major competition is Croydon and Bluewater and that it was possible for Bromley to overtake Croydon in terms of rental values

• Approval of the Draft AAP and adoption by the Secretary of State, a real opportunity will arise for a major retail scheme to emerge on the western side of the High Street, providing additional top class units required by major retailers as market conditions improve.

• Vital that Bromley has a top class multi screen cinema, well known restaurants and leisure outlets to attract families into the town in the evenings and at weekends.

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DAAP09 Babbacombe Road Residents Association (2)

14/01/2009 Commented on Site A • That the proposed increase in dwelling units from

the previous limit of 250 to 400 would swamp the community and having an adverse impact on the local environment.

The overall massing of development which would result from the 400 unit scheme would be difficult to integrate with the surrounding area and is likely to result in a significant change in local character and impact on residential amenity. It is considered that the smaller scheme could be integrated more successfully with the surrounding area with a reduction in height towards the western boundary and interface with residential properties. Further detailed design development would be required to demonstrate that a higher density development could be accommodated without adverse impact on the character of the surrounding area. The Draft AAP states that the number of units should be in general conformity with the AAP and the developer will be required to demonstrate that the proposed development will not result in unacceptable impacts.

• That the proposal of high-rise buildings of up to 10 storeys would dwarf the surrounding community having adverse implications outweighing the any commercial benefits.

• Objections to point 4.3.4 - that higher density development in the Town Centre will help to protect the suburban character of the rest of the Borough meant that communities surrounding the development sites could be sacrificed to benefit residents who live elsewhere in the Borough.

• That there would be an adverse impact on water and sewage resources for the community.

An SFRA has been undertaken in the town centre and PPS25 ensures that flood risk is taken into account at all stages in the planning process. This is to avoid inappropriate development in areas at risk of flooding, and to direct development away from areas at highest risk. New development will only be allowed in areas of high flood risk in exceptional circumstances and needs to be made safe without increasing flood risk elsewhere and where possible, reducing flood risk overall. Sustainable Urban Drainage Systems will be expected in all new developments.

DAAP10 The Bromley Children Project, Children & Young Peoples

16/01/2009 • Querying the number of cafes

A café culture is an important element in the town centre experience

• Querying Bromley’s need for a hotel The hotel industry/market intelligence has informed us that BTC is a favoured location The Council is committed to the continual improvement of facilities as well as promoting sustainable tourism

• Questioned what investment would be made towards the infrastructure to support the new developments and what the knock-on effect on schools, doctors which are already over-subscribed.

All major developments will be expected to contribute to the provision of services, facilities and infrastructure within the area in order to deliver the environmental, social, community, education and health capacity needed to respond to increasing pressure generated by the development. Infrastructure requirements are

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included in Policies BTC 31 & 32. These elements will be assessed as schemes progress.

• Queried the location of a children’s centre.

No requirement for a children’s centre has ever been raised during past consultation. That is not to say if could not come forward at a later stage

DAAP11 Kim Robinson 17/01/2009 • Supports a high quality department store to keep up with Bluewater and Croydon.

Support welcomed

DAAP12 Jenny Manchester

18/01/2009 Comments on Site F – • Commented that the transport impact on site F and

a lack of suggested public transport mechanisms

Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP sets traffic targets that see no overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three. The AAP’s supporting Transport Strategy proposes an approach that promotes a wide range of travel choices, including public transport. Enforcement of speeding traffic is a matter for the police, whether with new development or not. If traffic speed is likely to be an issue for a particular development, this should be addressed within the transport assessment supporting the planning application. The Transport Strategy sets out how parking will be managed in the town, both for new development and in the round (whether on or off street). A more detailed Parking Plan is to be developed.

• Expressed concern about speeding in the area and the parking issues that will arise out of development proposals.

• Questioned how the increased traffic flow and pedestrian conflict created buy the development will be managed.

DAAP13 Shire Consulting on behalf of Barclays Bank

15/01/2009 The Draft AAP does not meet the test of soundness due to:

• a retail study that was carried out about 5

years ago and that this study cannot be used to justify the definition of primary shopping frontages

The Retail Capacity Study – in relation to BTC is being updated and its findings will be included in the pre-submission AAP.

• The UDP which the Council states that the consultation draft is consistent with, itself needs to be reviewed.

Consideration is currently being given to ‘Saved policies’ from the UDP by GoL. All indications are that they are content with the approach.

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• As the Core Strategy had not been brought forward by the Council he expressed concern that before proceeding towards the submission to the Secretary of State further work must be done regarding its evidence base and on progressing with the Core Strategy.

Although the AAP is running ahead of the Core Strategy GoL believe there is a strong argument to be made regarding the fact that the AAP is required on urgency grounds in order to facilitate growth and address development proposals comprehensively.

DAAP14 Gladys Edmonds

25/01/09 • Commented on the importance of Bromley remaining a market town and expressed a view against any new taller building dominating the skyline and obscuring Keston Ridge.

BTC is a regional centre and has been for a number of years. The ‘market town’ element remains around market Square and there are no plans to re-develop this area rather to improve the ambiance of its setting. Retail -led regeneration brings economic benefits which can be substantial, relating to job opportunities and social inclusion.

• Against the development proposals of sites B and P as they would obstruct the view of Bromley college.

There are no views of Bromley College at ground level from either Sites B or P only from College Green which will remain as existing.

• The proposed high density residences in G and H was unacceptable – too high, small flats and having an unbearable strain on the infrastructure.

A wide range of household types, including families with children, the elderly and those with disabilities will help to achieve a more cohesive community. This will only be possible if entrances to homes and their internal layout and space standards are designed in a way that accommodates the needs of these households. In order to achieve this, the AAP will encourage new housing to be built to Lifetime Homes standards.

• Against concrete buildings in Site N in favour of retaining green spaces.

There are no plans for development on Site N merely to create a ‘town square’ on the existing paved area.

• against the idea of cafes and restaurants in Site M Use would be made of the existing hard standing subject to sufficient space for safety vehicles

• against residential dwellings in Site F. This development option has been included in all previous publications and the number of units have been reduced.

• The proposal of the high-rise building on Site L unacceptable as it meant the destruction of a listed building (a school) and obscure of the view of Keston Ridge.

St Marks School is not part of Opportunity Site L

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DAAP15 Roger Dawe

26/01/2009 • Commented that it was a good idea to have an overall plan for development of the Town Centre however:

Support welcomed

• Objections about site L, as the proposal to include tall building was not sensitive to the surrounding areas as well as obscuring the view of Keston Ridge from the High Street

Comment appears to relate to submitted planning application for the Site. Design criteria in the AAP clearly states that development should be sensitive to the surroundings and views

• Expressed concern about the increased traffic flow along Mason’s Hill, Westmoreland Road and the A21 as a result of the increase in residential, retailing and entertainment units and felt that careful analysis was needed including that parking considerations.

Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP sets traffic targets that see no overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three. Traffic impacts of individual developments must be addressed through transport assessments, which must accompany planning applications. The Transport Strategy sets out how parking will be managed in the town, both for new development and in the round (whether on or off street). A more detailed Parking Plan is to be developed.

• Commented that the plans did not make any reference to the High Street North of the Market Square.

These areas are included within Bromley North Village Improvement Area

DAAP16 Graham and Mary Jensen

26/01/2009 • Commented the Council was ignoring its own conservation area and that all the developments will leave Bromley devoid of character.

The AAP has always recognised that the town’s heritage is important. One of the underlying development principles of the Bromley Area Action Plan is to preserve and enhance all the features that make Bromley distinctive and to continue to provide the community with its sense of place and history

• Instead of competing with Bluewater and Croydon, Bromley should retain Market Town image to differentiate form the competition.

BTC is a regional centre and has been for a number of years. Bromley has been and continues to be subject to a significant amount of development pressure from the commercial sector

• In favour of ensuring that only low rise developments take place in the Town Centre.

Bromley has been and continues to be subject to a significant amount of development pressure within a relatively small area, any development will however be the subject of design criteria in order to mitigate impact on the area

• Also commented that existing sight lines should be retained and green spaces should be retained.

No changes are being considered to sight lines except where they can be improved – similarly green spaces

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DAAP17 Carol Thomas 27/01/2009 • Site B regarding the design of the proposed development

These scheme is now part of the Appeal process

DAAP18 Thames Water Property Services

27/01/2009 • Recommended that there should be a provision of a stand alone water and sewage policy and proposed a rewording with additional supporting text.

Comments noted and document to be amended as recommended

• Recommended that in relation to water efficiency, residential development should be required to meet code for Sustainable Homes Level 3.

• Commented that Policy BTC9 – Flood Risk and Policy BTC11 – Drainage need to be widened to cover issues of sewer flooding and foul drainage in addition to fluvial flooding and surface water drainage.

• Also commented that Policy BTC17 – Public Realm that trees/shrubs should not be planted over the route of sewers ort water pipes and that street furniture should not impede access to vehicles in event of emergency works.

DAAP19 Mr DA & Mrs

AL Morgan

29/01/2009 • Commented on parking issues and that the development would lead to increased parking problems and traffic congestion to an already overloaded area.

The Transport Strategy sets out how parking will be managed in the town, both for new development and in the round (whether on or off street). A more detailed Parking Plan is to be developed.

• Concerned about the increase in level of pollution and drainage problems highlighting Sandford Road and that recent drainage problems have necessitated long hours of emergency work.

SFRA has been undertaken and policy included in response to findings. Developers will be expected to address necessary requirements. PPS25 ensures that flood risk is taken into account at all stages in the planning process. This is to avoid inappropriate development in areas at risk of flooding, and to direct development away from areas at highest risk. New development will only be allowed in areas of high flood risk in exceptional circumstances and needs to be made safe without increasing flood risk elsewhere and where possible, reducing flood risk overall

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DAAP20 Andy Condon 29/01/2009 • Questioned where funding for these development would come from and whether it would lead to a rise in council taxes.

It has already been made clear in all documentation that the Council is not funding any of the schemes.

• Developments will spoil the look of the town, cause too much traffic congestion.

The look of the town is subjective and the accompanying Transport Strategy deals with issues regarding congestion

• New development would place an increased need for schools whose places are already in shortage.

This matter is being addressed through infrastructure requirements as noted in Appendix 5

DAAP21 Barbara Del Mar

29/01/2009 & 01/02/2009

• Commented in general on the need for good quality shops in Bromley since the departure of Alders and Army and Navy.

Noted, this was the basis for beginning the AAP process

• Commented that the additional households will also put pressure on local schools, doctors, dentists. Also concerned as to whether water supply and sewer systems could cope.

These matters are being addressed through infrastructure requirements. Education requirements are contained in Appendix 5 of the document

• Site A: Against high rise development. The height of development would be matters which would be determined at the planning application stage in accordance with the design principles set out in the AAP which will state that development needs to address surroundings and be sensitive to the adjacent residential housing

• Site B: Commented on the loss of trees and dwarfing the college buildings by the new development

Comment appears to relate to submitted planning application for the Site. However the revised AAP makes it clear that a sensitive and high quality design is essential to minimise the impact of development on the setting of the adjacent listed buildings.

• Sites C & F: Felt that the Council should continue to use these buildings as offices instead of acquiring other accommodation.

Site F will be re-configured for future demand but the old town halls are not suitable for modern office requirements.

• Site D & K: Sees no need for a new cinema and would rather see the Empire refurbished as it would give life to that end of the high street and remove the need for a cinema at site K making the development there less tall.

The Empire was refurbished only a few years ago when owned by the Odeon group. The town is losing visitors to other centres as they prefer what Multi-plex cinemas can offer.

• Site E: Would like to see the Pavilion left as existing

The Pavilion is not faring well but by re-phasing possible re-development to phase 3 allows for Mytime to make some improvements in the short -term

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• Site G & H: would rather a new department store be part of site G or H. but opposed to the height and density of the proposed development as well as the demolition of existing accommodation. Felt that a new shopping development could be constructed without a wholesale demolition of the area. Concerned that the density of residential accommodation would put pressure on parking in the area.

There is a question of viability and residential will be required to help fund any new department store or other retail. New residents will not be entitled to parking permits

• Site L: Commented that the 8 storey building would dwarf St Mark’s Church and ruin the view of the high street through to Keston. Felt that development should be height limited to 2 or 3 storeys.

Comment appears to relate to submitted planning application for the Site.

• Site N: Suggested that instead of site N a town square would be more suited at the current market square with the addition of trees bench etc and the removal of funfairs, sky vans etc.

By moving the town square south will allow for a more balanced town

DAAP22 Bromley Friends of the Earth

02/02/2009 • Development of the town centre will add to noise and pollution already suffered in the central area.

Bromley is already a regional centre and is capable of growth to meet future requirements Developers will expected to show how resilience new development is to noise and air pollution and the way in which it contributes to an overall reduction in levels of noise and air pollution

• that all planning permissions include a requirement that building constructed are eco friendly

The government have initiated a ‘low carbon building programme’ (LCBP) which gives grants towards renewable technology when building. This grant is currently available to Housing Associations. Policies BTC8 & BTC12 already cover much of these and other sustainable construction requirements for all new development. All major developments will be required to show how heating, cooling and power systems will minimise Carbon Dioxide (CO2) emissions and then reduce CO2 emissions by at least 20% from on site renewable energy generation (including decentralised renewable energy) where such options are viable and feasible). The feasibility for Combined Heat and Power (CHP) and private wire should be considered for all major schemes. Looking to the future, Bromley’s character will continue to develop leading the way for rest of the Borough on issues of sustainable design and construction.

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• that public transport improvements should be in place before major re-developments

Policy BTC26 (Phasing of Transport Improvements) sets out the requirement that the transport measures needed by new development should be in place first.

• that any redevelopment of the central area should go hand in hand with plans to assist other shopping centre like Beckenham, Orpington, West Wickham, Petts Wood, Chislehurst and Biggin Hill

Bromley is the major comparison centre in the borough. The other towns function as convenience centres, Orpington is already under investigation and the other towns will follow as resources allow.

• That the impact of high buildings on the visual environment should be considered in that Bromley should retain its market town ambience.

Bromley has not been functioning as a market town for some years. See response to DAAP14

• That any development should increase rather than decrease the current pedestrian area.

Ways to improve the pedestrian areas will be investigated

• That green spaces should be protected. Enhancement is included in the plan

• That office jobs should be moved out of the area It would not be sustainable to move job opportunities out of the town which has high PTAL levels

• That a heritage survey be conducted to ensure older buildings of character protected.

Diagrame2.1 on page 24 of the AAP shows the historic context of the town centre and indicates listed buildings that are protected as well as older buildings of character

• That plans should protect the existence of the current farmers market.

As part of Opportunity site development it may be possible to provide a permanent site for the Bromley’s Farmers Market as an integral part of the town centre in order to enhance choice within the town centre and provide vitality

• That a firm commitment be made to improve leisure facilities, especially for the young.

The Plan seeks to improve access to leisure for all. The Council is committed to continual improvement of facilities.

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DAAP23 Peter Bates 03/02/09 • SITE A : housing not compatible with major transport interchanges.

• That there should be a new car park and market

building and small business workshops should be introduced.

• That any development should not exceed height

of 2/3 storeys. • Agreed with Community provision, station upgrade

and improvement of public space outside but hopes for a relocation of bus stops.

• That road access into Kentish Way should be

improved.

Site A is a very sustainable location and any commercial elements could certainly include small business units. Any re-development would have to be viable an taller buildings would only be permitted where the impact on local residents is minimised. Access improvements will be necessary, though TfL will need to be consulted about any proposal for direct access onto the A21 Tweedy Road [Kentish Way]. New car parking is envisaged as part of the development, along with improvements to the station (Policy OSA refers). The bus stands would either need to be retained or else equivalent replacement facilities found elsewhere.

• SITE B: site should remain a public open space and that its narrow for development which would mean undesirable single aspect flats. That the status of the grade 1 & 2 listed college buildings will be preserved.

Access is proposed via Gordon Way. It is unlikely that TfL would support direct access onto A21 Tweedy Road [Kentish Way].

• That vehicular access from Kentish Way is undesirable as it is the town's by-pass.

• SITE C: Agreed to the proposal but felt that new buildings should not exceed height of existing heritage buildings and the fire station.

Noted and this point is already made clear in the Design Appendix

• SITE D: Agreed with proposals but looked for a greater indication that more thought had been put into "enhancing heritage appearance".

A masterplan for the Bromley North area is currently being drawn up following previous research.

• SITE E: Agreed with proposals but only if a new site will be found for a replacement Leisure Centre before any redevelopment begins

Site F is the location for a new leisure centre

• SITE F: Disagreed with the possible loss of parkland due to redevelopment and questioned if

Any development will take place on existing ‘brownfield’ land and if residential is considered appropriate in the listed building

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listed buildings are capable of conversion to residential.

developers would have to take account of any perceived difficulties.

• SITE G/H: That any redevelopment should be limited to the height of the existing buildings in that part of the High Street. Felt that there were too many flats proposed and that car parking spaces resulting in an over dense development will spoil the environment

It will be important for new retail to make successful linkages with the surrounding environs and should improve the built environment through well designed buildings. However deliverability through viable schemes is important and some taller buildings may be justified.

• SITE J: Agreed with proposals although renewed efforts should be made to interest Network Rail in a comprehensive redevelopment.

Any re-development would be high rise given the cost of rafting over railway lines as it would be very expensive.

• SITE K: Generally agreed with proposals but other local amenities should not suffer

Noted

• SITE L: Any redevelopment should respect the existing school building and not be higher than the building to be replaced.

The Design Criteria clearly states that account needs to be taken of the surrounding area and views.

• SITE M: No encroachment should be allowed into the gardens.

None is proposed and there is already a planning permission for the extension to the existing restaurant.

• Generally felt that the proposals were not comprehensive enough and that the quality of designs should be taken into account

Not sure how much more comprehensive the plan could be given the above comments. Design quality is paramount to any re-development proposals. High quality design and the way in which new development enhances the character of the area and respects the local context is particularly important in the town centre

DAAP24 David Smart

03/02/09 • Objected to Site L on grounds that it spoils the views of Keston Ridge, causes congestion and is too close to St.Marks Church, a listed Building.


DAAP25 Ann Garrett 31/01/2009 • Supported a new department store but felt that all new buildings should be low rise. Opposed to any high buildings adjacent to the library gardens. Against Ethelbert Close being demolished

Retail-led regeneration is an important element in revitalising town centres. The proposals for Site G will included maintaining the High street as an important focus for shopping but also allowing for residential opportunities and improved health and faith facilities. With any such major scheme some demolition will be inevitable.

• The Empire Cinema should be retained and converted into an arts centre

This is certainly a possibility and would be an opportunity to preserve the building. Text to be amended similar to that for Bromley Little Theatre

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• no high rise buildings on site A or L.

Accommodating growth and promoting regeneration presents real challenges and whilst developments need to be viable they also need to take account of surroundings. Design Principles in the AAP (Appendix 4) are there to guide potential developers

• Present green sites should be preserved especially around the Civic Centre Site and any buildings there should be low rise and sensitively designed.

Agreed and noted

• Opposed to the plans for Site B

Comments relates to planning application

DAAP26 Surrey County Council

26/01/2009 • Impact on Surrey’s Town Centres is likely to be acceptable.

Noted

DAAP27 Mr D Powell and Mrs. B Powell

26/01/2009 • Site A: Development of tall buildings a mistake

Accommodating growth and promoting regeneration presents real challenges and whilst developments need to be viable they also need to take account of surroundings. Design Principles in the AAP are there to guide potential developers

• Site B: Agreed with refusal of recent plans for the site and felt that only low density residential development with plenty of landscaping should be allowed.

the revised AAP makes it clear that a sensitive and high quality design is essential to minimise the impact of development on the setting of the adjacent listed buildings.

• Site C: Civic Centre to be moved back into the former town halls

The office accommodation in the old town halls is not suitable for current requirements and a sympathetic refurbishment would be more viable. Listed Building status would limit the capacity of the buildings and it is the Council’s objective to reduce maintenance expenditure and reduce energy and carbon footprint. Development on Site F would be expected to improve the setting of the Grade II Listed Building

• Site F: demolish 1960s blocks

• Site G: Against demolition from the library down to Bromley South and tall buildings and would prefer to see the building from the Library up to ‘Primark’ demolished instead.

• Commented on a need for a site for a post office

and a relocating the theatre as difficulties with parking.

Mr Powell attended earlier workshops and has been included in all previous consultation and this idea has never been put forward before. It would, however, be unlikely to receive support given the status of the ‘Primark’ building and other buildings of interest. Moving the Post office would be a commercial decision by Royal Mail. Site G will provide parking close to the existing theatre and there has been no constructive idea as to where to move the theatre which is a very popular facility.

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• Site K & L: against major developments on either site

The Area Action Plan encourages new town centre development, which will serve existing and new communities well, offering them a variety of goods and services, maximising the advantages of its distinctive setting, and providing a centre that people are proud of and enjoy visiting.

• Site G, M: Against any encroachment of the library gardens, Queens Gardens and cafes in the parks except a ‘small’ one.

There is no encroachment shown for Library Gardens and a small café is what is envisaged for Site M

• Site P: against over-development Key design principles detail what any new development/ refurbishment would need to consider.

DAAP28 Mr & Mrs L. De Silva

02/02/2009 • Opposed to any additional retail space as there are many unoccupied outlets

The units that are vacant are, we are ensured, not want the retailing market require

• Against high rise housing developments in town centre and additional parking opportunities provided in new developments

Town centres are the most sustainable location for certain types of dwellings and is how towns developed in the past prior to suburbia being developed

• Opposed to additional office spaces due to number of vacant offices currently

Current office vacancies do not meet modern requirements however there is a need to ensure future aspirations for the town are not diminished by not providing employment opportunities. Whilst the priority is to regenerate the town centre to provide for retail, social and community activities it is recognised that uses such as residential and business uses are likely to be important to the overall viability of the proposals.

• Infrastructure unable to cope with demand for public services

All major developments will be expected to contribute to the provision of services, facilities and infrastructure within the area in order to deliver the environmental, social, community, education and health capacity needed to respond to increasing pressure generated by the development.

• Against hotel and cafes in the town Bromley is a regional centre and cafes are popular in any town. The hotel market is keen to be represented in the town. The Council is committed to continual improvement of facilities as well as promoting sustainable tourism

DAAP29 Cathedral Group

06/02/09 • Supports overall objectives on the AAP proposals Noted.

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• Questions why residential is not included on Site C and suggests a feasibility study is undertaken Bromley Fire Station should be included in site boundary

In order to ensure viability of a scheme for this site a limited number of residential units will be included in the development options. Whilst it is acknowledged that the LFEPA wish to have new operational facilities it is not considered that a feasible scheme could come forward given the impact on setting of the adjacent listed town halls

• an hotel should be included in mix of uses on Site K in order to increase economic benefits. Text should be expanded regarding the possibility of taller buildings

Noted. It is considered appropriate to include either wholly residential units or a mix of residential and hotel use as an acceptable element of any future mixed use cinema led development

• Policies BTC31/32An contributions should be assessed on a site by site assessment

All major developments will be expected to contribute to the provision of services, facilities and infrastructure within the area

DAAP30 Kate Fowler 06/02/09 • Queried percentage of social housing Percentage will be as per adopted UDP policy

• Impact on water supply Sustainable Urban Drainage Systems will be expected in all new developments. PPS25 ensures that flood risk is taken into account at all stages in the planning process and subject to minor drafting Thames Water support the AAP Developers will be required to demonstrate that there is adequate water supply and wastewater infrastructure capacity, both on and off site to serve the development and that it would not lead to problems for existing or new users.

• Commented on traffic and parking problems Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP sets traffic targets that see no overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three. Traffic impacts of individual developments must be addressed through transport assessments, which must accompany planning applications. The Transport Strategy sets out how parking will be managed in the town, both for new development and in the round (whether on or off street). A more detailed Parking Plan is to be developed.

• Shortage of schools Infrastructure requirements including education are included in Plan. Developers will be expected to consider the infrastructure

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and service implications for the local area and, where appropriate, make provision of new infrastructure to ensure that new development can be accommodated.

DAAP31 Bromley Little Theatre

04/02/09 • Welcomed the recognition of the current and future role of Bromley Little Theatre in the draft AAP

Support welcomed

• Pleased that the role of the site and building of Bromley Little Theatre was noted in the plan to protect and enhance the historic character of Bromley

DAAP32 Mrs A Lee 04/02/09 • Commented that Site B development will overshadow and not be sensitive toward listed buildings of Bromley and Shepherds Colleges.


• Concerned that Site G and H involved the demolishing of all the shops and some houses, including Listed Buildings, from the Library down as far as Bromley South Station.

The way in which new uses and buildings integrate with, and enhance the town centre as a whole, providing good links and relationships with existing uses and buildings High quality design and the way in which new development enhances the character of the area and respects the local context is particularly important in the town centre • Against taller buildings in favour of low-rise

accommodation

• Queried how much consideration had been given to infrastructure

All major developments will be expected to contribute to the provision of services, facilities and infrastructure

• Town needs regeneration but not more shops and cafes

The key aim of Planning Policy Statement 6 is to promote the vitality and viability of town centres. New development should be focussed in existing centres in order to strengthen and regenerate them, taking account of the overall retail hierarchy and the role of the town centre within this hierarchy.

• Concerned that the hard standing for fire services access will need to be increased thereby meaning less green space in the Queens Gardens

Any development would have to take this issue into account.

• Impact of proposals on local residents One of the underlying development principles of the Bromley Area Action Plan is to preserve and enhance all the features that make Bromley distinctive and to continue to provide the community with its sense of place and history

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DAAP33 Glenis Ruston 04/02/09 • The town centre should noted for more than just shops and there should be adequate provision of culture, art and sport facilities

Noted, whilst retailing is important so are future employment opportunities in other commercial sectors and accessing leisure facilities

DAAP34 Hayes Village Association

04/02/09 • Commented that the south part of the High Street has no redeeming feature, that the pavement is not wide enough and obstructed by two bus stops.

Improvements to the street scene are envisaged in both the AAP and the supporting Transport Strategy. Safeguarded land at Site L is intended for public transport and public realm improvements

• Suggested that Bromley could have a competition to get ideas to improve the High Street

Good idea but we are now 4 years into the AAP process already having identified Opportunity Sites and undertaken consultation. It may be a possibility for other areas of the town such as Bromley North.

• Commented that a new train station could be built to replace the present one

Network Rail is to improve the existing station buildings to provide improved accessibility

DAAP35 Ms. Fiona Howalth

04/02/09 • Commented about the increase in residential housing on site G putting a strain on the infrastructure

PPS 1 states that “Growth needs to be accommodated by more efficient use of land and buildings within existing centres … and densities can be increased where appropriate” and all major development will be expected to contribute towards infrastructure requirements.

• Requested information on the exact height and ground plan of the tower building

Exact heights would be the subject of any future planning application

• Concerned on the lack of parking spaces for local residents

The amount of on street parking space is a function of local car ownership. It is intended to increase the size of the town’s Controlled Parking Zone (CPZ) to offer protection to even more local residents from increased parking demand by non-residents.

• Queries what will become of the medical practice at 13 Ravensbourne Road

A replacement facility is included in Policy OSG relating to the principle of development on this site.

DAAP36 Bromley Borough Local History Society

04/02/09 • Concerned about the emphasis on the lower end of the high street and the neglect of the northern end.

A Masterplanning exercise for Bromley North Village is currently being undertaken in order to improve the environment.

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• Site B – that the proposed development on Tweedy Road will dominate the latter building.

Comment appears to relate to submitted planning application for the Site. the revised AAP makes it clear that a sensitive and high quality design is essential to minimise the impact of development on the setting of the adjacent listed buildings.

• Site P – College slip and the 18th century house on the north side should be preserved as a right of way maintaining a real divide between an historical and industrial/commercial area

The pathway is not included in the site boundary

• Site C –, the two Grade II listed buildings should be protected from re-development

Agreed, there is no question that they should be demolished merely sensitively refurbished

• Site F: Bishops Palace should be retained for Civic Use

Noted

• Site L – St. Marks School and Church should not be dominated by adjacent, much taller ones.

The Design principles clearly state that development on Site L should be sensitive to the location

• Site G –Against the demolition of housing Major changes have taken place with regards to national and regional planning policy. There is much greater emphasis on the need to deliver sustainable development and tackle climate change. These are local issues as much as they are global. In order to deliver the required retail floorspace there will be the need for some demolition of existing property.

• Site M & N –concern about impact of development on Queens Garden and the Town square might encroach on Church House Gardens

It is important that any development on Site M is sensitive to the environment and Church House Gardens are not included in Site G or N

DAAP37 Richard Brown • Site B - Needs to be developed with great sensitivity to maintain the character of the College grounds and buildings and 70 units may be seen as over-development.

the revised AAP makes it clear that a sensitive and high quality design is essential to minimise the impact of development on the setting of the adjacent listed buildings.

• Site P – Does not see how the frontage of West Street will benefit from development behind houses which front the street.

Again any development proposals will need to mitigate any impact

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• Site E – Commented that the leisure centre is being overlooked as there are numerous medium to large retail units ready for redevelopment at less capital expenditure than the cost of relocation.

The Area Action Plan encourages new town centre development, which will serve existing and new communities well, offering them a variety of goods and services, maximising the advantages of its distinctive setting, and providing a centre that people are proud of and enjoy visiting.

• Also commented on traffic congestion on Bromley South and Masons Hill

Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP’s supporting Transport Strategy proposes an approach that promotes a wide range of travel choices. The AAP sets traffic targets that see no overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three. In support of improved public transport accessibility to the town, the AAP also includes land safeguarding to provide better public transport priority on the southern approach into the town via Masons Hill.

DAAP38 Mr & Mrs Baldwin

• Against high rise buildings

Site K is considered the most sustainable location for a new cinema. Leisure uses in the early evening, in particular, can help to extend the ‘working day’ of the town centre and make it a much more inviting place to visit at less busy times. It would be expected that the ‘Empire’ to be re-used/refurbished In the absence of a major transport initiative a number of smaller improvements with the potential to have a significant cumulative effect on congestion and accessibility will be delivered in the area Given the town centre location and the relatively good public transport accessibility of the site, restrictive parking for new residents is considered acceptable.

• Concerned that parking will become an issue with the addition of a cinema at site K

• Felt that the area of site K is too small for a development of that size and that it will lead to increased litter and noise

• Commented that closure of Empire cinema will reduce character of the surrounding area.

• Also commented that Increase in traffic will lead to concerns for safety and a negating of property values in the area.

DAAP39 Network Rail • Supported the proposals to site A regarding increased density and development opportunity.

The primary purpose of the preliminary site capacity and massing study undertaken by EDAW has been to inform the development appraisals. However, given the level of concern expressed by local

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• Commented that an additional tall building could be accommodated on the other side of the tracks, in the centre of the site.

residents about the potential impacts of the increase in the number of residential units on local amenity, an analysis has been undertaken of the likely massing of development which would result from the proposed scale of development. Whilst this is a very preliminary study and further design development would clearly allow for scheme refinement, it assists in our understanding of the potential impacts of increasing the number of residential units and the density of development. Taking into account potential for value growth over the plan period along with the various points that we have outlined above, we do not consider it unreasonable to expect that a viable scheme can be arrived at for the development based on an indicative capacity of 250 residential units for the site.

• Objected to the substantial downsizing of site J as it is not clear why the Council believe the scheme is undeliverable.

Letter from Network Rail dated 30 June 2008 stated that any development of station would not be undertaken in the foreseeable future. Opportunity Sites identified in any AAP need to be shown that they are deliverable.

DAAP40 DPP on behalf of HMCS

• Requested that the document acknowledges the expressed need by HMCS for a new County Court facility in Bromley Centre

The development of a new facility has not been previously identified, however such a new facility could be built outside of the AAP once the HMCS have identified a suitable location.

• Requested that Policy OSB acknowledges the need for the redevelopment of Site B to respect the County Court's operational requirements as well as the Court building in design terms.

Noted

• Requested that Policy IA2 is amended to note the need for redevelopment schemes in the BIA to respect the ongoing operational requirements of the existing sensitive uses, such as the Magistrates' Court.

Noted

DAAP41 Hyde HA • Lifetime Homes should be defined. Lifetime homes would be identified through the planning application procedure and the standards are shown in Appendix 2

• Commented that parking spaces for the wheelchair units (which will comprise 70 dwellings based on the 35% requirement for affordable housing) might be difficult to achieve.

Again this issue would be the subject of the detailed planning application

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• Commented on lack of reference to parking for the new residential accommodation.

Parking ratios would be within London Plan requirements

• Concerned that the financial climate might deter development due to cost implications.

This is a 15 year plan and we need to plan for the future

• Commented that consideration should be given to a sensitive lettings plan reflective of the borough.

This would be a matter for the housing division rather than a spatial plan

DAAP42 Housing and Residential Services. LBB

05/02/09 Fully in support of the approach subject to minor amendments. • more explicit reference be given to the Councils

preferred RSL development partners. • a definition of affordable housing be included in

the glossary in accordance with the DCLG definition.

Noted. Developers will be required to work in partnership with the Council and preferred Registered Social Landlord development partners in developing proposals for affordable housing provision.

DAAP43 Theatres Trust • Commented in support the Bromley Town Centre Area Action Plan in respect of Policy BTC7 as it contains all the elements required for a thoughtful and forward looking framework for the future cultural needs of the Borough

Support welcomed

DAAP44 A2Dominion Group

• welcome the recognition to provide a balance of tenures of accommodation and the emphasis placed on provision of mixed-use development including affordable housing that will also incorporate where possible suitable and necessary wheelchair accommodation. The Town Centre is high in private rented accommodation and that other boroughs in London have found that a balanced combination of general needs rent and intermediate accommodation has helped to achieve their aims.

Support welcomed

DAAP45 Keith and Adrianne Laidlow

• Commented that the present application, reference 04190, is not sensitive to the two storey houses in Pinewood Road and Sandford Road, and has no respect for the old, listed, building of

Comment appears to relate to submitted planning application for the Site. Bromley South is an ideal location for an hotel given the proximity

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St Marks School. • Queried whether a hotel in 24/7 use is acceptable

in this residential location.

to the town’s main commercial area and the railway station.

DAAP46 Anna Littler • Suggests preserving some of the old attractive buildings on Bromley High Street

• Oppose to proposals for the three/four storey

blocks and especially the five-storey block on Tweedy Rd/London Road

• Concerned about the proximity to the Alms

houses and the whole of Bromley and Sheppards College

• Commented on the unattractive modern design

and the oppressive colour. • Also commented on the affect on the wildlife and

trees in the area the removal of more ‘Green spaces’

• Felt that insufficient parking for number of flats will

have an impact on the area

Comments appears to relate to submitted planning application for the Site that is the subject of an Appeal against refusal by the LBB

DAAP47 Jan Vince 06/02/09 • the level of development on Site A identified would lead to overdevelopment resulting in a detrimental impact on the character, appearance and infrastructure of the area.

The overall massing of development which would result from the 400 unit scheme would be difficult to integrate with the surrounding area and is likely to result in a significant change in local character and impact on residential amenity. It is considered that the smaller scheme could be integrated more successfully with the surrounding area with a reduction in height towards the western boundary and interface with residential properties. Further detailed design development would be required to demonstrate that a higher density development could be accommodated without adverse impact on the character of the surrounding area. The Draft AAP states that the number of units should be in general conformity with the AAP and the developer will be required to demonstrate that the proposed development will

• Against tall buildings, small units and high building ratios across the plot. Commented that there should be no allowance for tall buildings on site A, given the presence of the existing 15 storey residential development and office block of circa 6 storey

• Stated concerns over the proposed inclusion of Class A3/A5 uses within Opportunity Site A possibly leading to increased noise and nuisance for residents.

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• Suggested that there should be a wider policy objective not to deliver biomass boilers within new developments.

not result in unacceptable impacts. Policy BTC12 Combined heat and Power identifies the need to look at renewal energy initiatives.

• Commented that there should be no lessening in parking provision for those residents as a result of any proposals for the area.

It is proposed that on street parking by local residents is protected by extension of the CPZ and by not allowing residents in new development to obtain parking permits for those roads.

• Supported the provision for decked car parking however ‘Edges that front public spaces...should be ‘wrapped’ so that active land uses (and not car or cycle parking) conceals blank edges’.

Noted

• Commented that Bromley town centre should not be seen as a one stop solution to delivering Bromley’s required housing numbers

The Annual Monitoring Report for 2008 shows that the Council does not rely on town centre development to meet its housing requirement t. It is envisaged that there will continue to be a significant contribution to the Borough’s housing requirements coming from sites other than those in the Bromley Town Centre.

DAAP48 Turley Associates on behalf of Sainsburys

• Commented that the document should consistently refer to a replacement or extension to the food retail

Agreed, text to be amended

• Commented that the proposed residential element, the reference to the number of units i.e. “around 20” should be removed throughout the document

Removal of the number of residential units would not meet guidelines set out for AAP’s. The Council is committed to making the best use of previously developed land to promote local area regeneration and deliver wider benefits.

• Recommended that the Secondary frontage should be extended along the western edge of West Street and take in the existing frontage of the Sainsbury’s Store.

Agreed. Secondary frontage to be amended

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DAAP49 Bromley Civic Society

Supports the principle of BTC being reinvigorated but: Consider the AAP conflicts with UDP policy such as important views settings of listed buildings etc

The design guidance is clear on what is expected from developers with regards views and important buildings.

• Site A: No objection in principle subject to proper consideration of the Charter Market, listed building and surrounding residential character

Noted

• Site B Against the scheme that is currently subject to the appeal process and dislike the way the application was dealt with by officers

Noted, however the proposal was thoroughly and appropriately assessed by officers and Members clearly have the right to refuse as they see fit.

• Site C Believe the LFEPA wish to demolish the locally listed fire station and consider the old town halls should be re-used as Civic offices

The existing fire station is not within the site boundary and any demolition would be dealt with under the adopted UDP policy. The town halls are considered unviable for any long term re-use by the Council given the need to manage energy and maintenance budgets

• Site D Welcome omission of the site but consider the cinema building to be of local importance.

The current cinema is not well used, except during school holidays. The building could therefore be put to better use.

• Site E Concern about loss of leisure centre and design of any new build

MyTime are undertaking a brief re-furbishment as the centre has not borne up well and needs updating. They require better facilities if they are to serve the public in the future. Any redevelopment of the site would need to take account of the design principles in Appendix 4

• Site F Strongly resist loss of parkland and concern about impact of any new development on the Listed Buildings.

Currently the setting of the grade II listed Bishops Palace is compromised by the adjoining civic buildings. The Design Principles for Site F set out in Appendix 4, ensure that new development will respect and enhance the scale, architecture and landscape of the Palace such that its setting will be improved

• Site G & H Object to loss of housing in Ethelbert Close and shops along high street frontage and impact of development on views and residential amenity including air quality.

The height of development would be matters which would be determined at the planning application stage in accordance with the design principles set out in the AAP which will state that development needs to address surroundings and be sensitive to the adjacent residential housing The skyline of the town as viewed from Library Gardens has been affected by more recent developments including the Churchill Theatre/Library building.

• Site K Object to the increase of residential and the impact of

Again Appendix 4 details design Guidance and the draft results from the recent Householder survey shows that most people prefer to go to Bluewater for cinemas. By developing a cinema in

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taller buildings, and traffic movements, also impact of a new cinema on the one in Bromley North

the town that people what to visit means expenditure will not be lost out of the borough. A positive response to the local context does not always need to be a replication of existing building styles and this site is considered suitable for a mixed use scheme.

• Site L Object to planning application submitted for the site. Loss of views and impact on St marks school.

The design principles for the site is set out in Appendix 4 scale and massing be assessed with particular regard to views and the listed building. The planning application recently submitted fails to take account of this guidance. Contemporary design can enrich a place through contrast of styles and design of the highest quality may provide the architectural gems of tomorrow

• Site M Object to loss of hardstanding for safety vehicles as well as nay loss of green space and the Opportunity site is contrary to UDP policy regarding Urban Open Space.

As well as serving the surrounding residential communities, Queens Gardens has the potential to contribute to the vitality of the town centre. It offers scope for linked trips to the park and the shops, particularly for families with young children, A café facility could add to this enjoyment. In their response to the AAP (DAAP105) the LFEPA have not identified the loss of hard standing as an issue

• Site N Object to a new town square if it means the loss of Ravensfell House (the roof can be seen above 98 High Street) also resist any further encroachment into the gardens.

Tree planting and other landscape design will be encouraged in order to enhance and enliven the new town square and pedestrian route into Library Gardens. It will be for the developers to provide a scheme that meets design guidance criteria and provides a realistic opportunity to improve the town’s well being

• Site P Concern regarding overdevelopment and impact on listed building, housing in West Street and conservation area generally. Public art currently on the façade of Sainsbury’s should be retained.

The importance of the town’s historic built heritage and the need to provide an appropriate setting for it is stressed in the Plan,

• Believe many people visit Bromley because of its character.

The Householder survey carried out as part of the Retail Study update has shown that whilst BTC is still popular with shoppers they are not concerned about the town’s environment as they would rather have more diversity in the choice of shops including the provision of a new department store.

• The perception of the evening economy is off-putting

They is why the AAP aims to expand the facilities in the town to make it more attractive to other age groups

• Want housing in west street and North street made subject to an Article 4 Direction

•

An Article 4 Direction removes permitted development rights, thereby necessitating that a planning application is made for all development A Conservation Area Appraisal and Management Plan which will be drawn up as part of the work on the LDF should consider this option.

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• Loss of leisure floorspace

It is intended that the new leisure floorspace will actually meet the requirements of users in an improved format. Mytime are keen to bring forward improve leisure opportunities for all age groups.

• AAP should integrate more with the aims of Building a Better Bromley

One of the objectives of the BBB is to support ‘thriving town centres’ the AAP is one vehicle that seeks to meet that aim.

• Generally believe the AAP should promote a more balanced approach

The Plan identifies a number of sites for redevelopment and over the lifetime of the plan other sites may come forward. This presents opportunities to improve parts of the town centre which do not function well or are not attractive.

• Believes that the Council has failed to promote the AAP effectively

Since work commenced in 2005 there has been extensive consultation with exhibitions, talks to specific groups, wide news coverage, letters and 30000 leaflets distributed

• Felt that there was a conflict of interest in the council being a land owner, master planner and local planning authority

AAPs are encouraged by government as the best way to provide an holistic plan for specific areas. It is a planning document and property issues have been dealt with by the property section. Opportunity sites have to be deliverable not like Proposal sites in UDP’s

• Of the view that the Council is/ has been in negotiations with developers on AAP sites and that public opinion has been generally been dismissed or ignored in favour of the developer.

Whilst talks have been undertaken this is an essential ingredient of AAP’s to ensure sites are deliverable and is a normal part of the process – consultation will be expected to be undertaken with local residents by a developer on any major development prior to the submission of a planning application.

• Concerned that the latest draft AAP has been amended to meet the demands of developers made during the previous consultation

The Options and the AAP has been amended over the extended consultation period by comments received from developers and those made by the general public, Site D is an example. All Opportunity Sites have to have a realistic chance of coming to fruition and it would be inadvisable not to take into account market analysis.

• Developers should assess noise implications Para. 6.6.19 states this and Policy BTC15: Noise covers the issue.

• Raise conformity issues with the UDP regarding tall buildings and protected views.

Reference to UDP policy to be added to Policy BTC16 & 19.

• The specification of unit numbers / floor areas should be omitted and greater focus placed on site constraints / site specific development briefs and development control policies.

Such a move would not be in accordance with government guidance

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• Concerned that no proper characterisation of the town centre has been prepared and no Conservation Area Appraisal has been undertaken since 2005 and take issue with the title of the conservation area.

The AAP has defined the Bromley North Village Improvement Area as a character area. It is still acknowledged that it forms part of the Bromley Town Centre Conservation Area. The character areas have been assessed during the baseline process and a heritage appraisal of Bromley North Village which forms part of the Bromley Conservation Area is being undertaken. A full Conservation Area Appraisal will form part of the Core Strategy process. UDP policy for conservation areas remain as is.

• Correct wording relating to statutory protection and use the wording to ‘preserve or enhance’

Noted.

• Also concerned that the retail capacity study done by DTZ in 2004 is out of date given the current economic conditions and that it is premature to adopt the Draft AAP until revised work has been undertaken.

This is currently being updated however preliminary data indicates that BTC has slipped down the ranking, now 33rd out of 2000 centres, a drop of 4 places. Croydon is ranked 24th up seven places over the same period (2008) Whilst there has been a decline in retailer requirements this coincides with the economic downturn but investors still want to invest in the town.

• Specific groups be included in section 6.2 regarding partnership working and specific mention be made of CABE etc.

Local organisations and amenity groups are mentioned generally, but not by name. As this is a 15 year plan and it would be amiss of the Council to omit reference to any particular group especially one that may come forward during the life of the plan. Appropriate reference to CABE and English heritage appear throughout the document

• Concerned that development may be permitted prior to an upturn in the economy

With the current economic climate no developer will undertake speculative development without the proper funding. Once there is a more positive climate the Council will be well placed if they have made plans for the future.

• Concerns about A21 road widening. The safeguarding line for the A21 has been in place for a significant number of years and all developments have been set back and built according to the line. It can be seen that this land is well maintained by the current owners and there is no reason to suspect that they will not continue to look after this land until it is required for the road widening.

DAAP50 Lennon Planning on behalf of Linden Homes

• Generally welcomed the changes proposed by the AAP in respect of the Bromley North site. The increase in the proposed homes to be provided on the site will not only provide much needed new housing but will result in the most efficient and effective use of the site, in line with objectives set

There were no substantive objections to the scheme as noted in the Revised Preferred Options which included 250 residential units. Following the representations to the RPO the number of units was increased to 400. The Council is committed to making the best use of previously developed land to promote local area regeneration and deliver wider benefits and public transport improvements are

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out in PPS1 and PPS3 • Linden Homes however considers that there are

no significant barriers to the delivery of the site and that redevelopment can take place within phases 1 and 2 (0-10 years) as set out within the AAP. As such Linden Homes conclude that the identification of the Bromley North site as an opportunity area is deliverable.

• The likely retention of Northside House, retention

of the listed Station Building and possible safeguarding of an area adjacent to the station, together with improved public realm area to the front of the station will make the provision of a strong built edge along Tweedy Road difficult to achieve.

• considers that the Council should adopt flexibility

when assessing the merits of a detailed proposal and in this respect should allow for the replacement of Northside House if the overall scheme still results in the proposals meeting the key principles

• Requested that a minimum of two further tall

building icons be placed on the site of Northside House and centrally within the site, which will provide a high density, mixed use development with excellent public transport accessibility.

• Pointed out errata in Paragraph 5.1.3 of the AAP

refers readers to more detailed guidance being provided in Appendix 2. We believe this should be amended to Appendix 4. Policy OSA refers to safeguarding suitable land shown on Diagram 4.8 to protect land between Tweedy Road and the Network Rail track but this diagram is not included within the AAP

central to the vision set out in the AAP. However, in response to the specific issues raised in responses to the Draft AAP and in the absence of a higher density development and how these would be mitigated the number of residential units is amended to an indicative figure of 250 units as previously shown in the Revised Preferred Options The Council consider that the appropriate scale of development on this site needs be influenced by its mixed use nature, scale and the local context, reinforcing local distinctiveness, as well as in securing a high quality environment. Whilst the town centre’s spatial characteristics provide constraints and opportunities it is also important to continue to provide the local community with its sense of place. Sites identified in the AAP need to be deliverable. This includes ensuring development viability and receiving planning approval, and there would clearly be a need for further assessment and careful masterplanning to develop an acceptable design for the site which would deliver the benefits sought by the AAP in terms of improvements to the station and transport facilities. At this stage however, no detailed masterplanning has been undertaken to demonstrate that an appropriate form of development can be achieved at the higher density proposed in the revised Draft AAP The Pre-submission Draft AAP states that the number of units should be in general conformity with the AAP and the developer will be required to demonstrate that the proposed development will not result in unacceptable impacts. These are matters which would be fully addressed at the planning application stage and it will be important that any development proposals demonstrate how the design complements the existing area and the opportunities available for improving the character and quality of the local context. Mis-print noted.

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DAAP51 John Street,

03/02/09 Babbacombe Road pre-printer Pro Forma for Site A • Object to Site A, commenting that they feel there

is insufficient clarity and explanation as to how and where the proposed uses can be accommodated

• Commented that 400 units is wholly

disproportionate to the size of the site, and would give the ‘green light’ to future development which would overwhelm surrounding roads

• Concerned over proposed height of new buildings • Questioned how the site would be accessed by

new residents • Noted that the site has been brought forward into

phase 1 & 2, from phase 3 in the Revised Preferred Options in 2007; feel that this follows pressure by the Council and Network Rail who are landowners on the site

• Suggested that the AAP provide more clarity and

that commercial uses on the site including car parking be positioned near to Tweedy Road, and the station, with residential positioned further north abutting Babbacombe Road given that this is already residential in character

• Suggested that the number of proposed units be

reduced and the modest scale of development in adjacent roads be taken into account

• Suggested that lower maximum heights be stated,

and that taller buildings be limited to the area immediately adjacent to the station and Tweedy

Detailed access to Site A will be a matter for further site-specific design guidance. Any proposal for direct access to/from A21 Tweedy Road will require the approval of TfL. The development options for this site have been reassessed and it is considered that the overall massing of development which would result from the 400 unit scheme would be difficult to integrate with the surrounding area and is likely to result in a significant change in local character and impact on residential amenity. It is, however, considered that the smaller scheme could be integrated more successfully with the surrounding area with a reduction in height towards the western boundary and interface with residential properties. Further detailed design development would be required to demonstrate that a higher density development could be accommodated without adverse impact on the character of the surrounding area. The Draft AAP states that the number of units should be in general conformity with the AAP and the developer will be required to demonstrate that the proposed development will not result in unacceptable impacts.

DAAP52 Mr. KM Tonner 03/02/09

DAAP53 Mr Steve Hancock

03/02/09

DAAP54 CCR Best 03/02/09

DAAP55 Mr & Mrs Duggan

05/02/09

DAAP56 Mr & Mrs G Ricci

06/02/09

DAAP57 Mr C.J. Barretto,

31/01/2009

DAAP58 Macey Mitchell 31/01/2009

DAAP58B Resident, Babbacombe Road

31/01/09

DAAP58C Mr & Mrs MJ Corner

04/02/09

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DAAP59 Victoria & Gary Fentiman

06/02/09 Road • Suggested that the plan make clear that all

access/exit to/from the site be from Tweedy Road DAAP60 Dawn Wilkes 05/02/09 • Commented on problems with parking with regard to

Site G The amount of parking proposed at Site G has been determined at a level that balances the needs of town centre living, outer London accessibility and potential future retail parking demand. Where necessary, the CPZ will be extended to protect more local residents. Residents of new development will not be issued with parking permits for local roads

• Against high rise building on Site K Site K already includes buildings of significant bulk and scale and further taller buildings could be located without comprising surrounding buildings, spaces and views.

• Wants assurance that a new recreation centre will be built if the Pavilion is demolished

The most appropriate place for leisure is in town centres the AAP states that the Council will work with developers to secure the relocation of the facility. Site F has already been identified

• Objects to redevelopment of the Queens gardens There are no plans to redevelop Queens Gardens merely to provide a café facility. All AAP work to date has recognised the value of the Gardens as a public amenity space.

DAAP61 Jackie Palmer 06/02/09 • Commented on inadequate parking provisions

Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP sets traffic targets that see no overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three. Traffic impacts of individual developments must be addressed through transport assessments, which must accompany planning applications. Parking proposals in the AAP are seen as consistent with this overall approach. The Transport Strategy sets out how parking will be managed in the town, both for new development and in the round (whether on or off street). A more detailed Parking Plan is to be developed.

• Concerned about traffic congestion

• Commented that plans will cause residents nuisance and compromise road safety

DAAP62 Bromley Scope 03/02/09 • Suggested hydrotherapy pools added to leisure centre

In the short term this would best be directed towards MyTime for consideration prior to any refurbishment of the Pavilion. In the long term it would again be for Mytime to consider.

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DAAP63 GOL 06/09/09 • Would expect to see greater local distinctiveness in the vision, in terms of how projects/developments will achieve the aims of the AAP along with an indication of timescales and a quantum of development. Felt that this is particularly relevant as the AAP is being brought forward ahead of the Core Strategy

Noted. The text of distinctiveness to be moved to earlier on in the document

• Whether results of a feasibility study into relocating The Pavilion and relocating onto Site F will be available in time to have input into the AAP before formal consultation

The relocation of the Pavilion to the Civic centre site has been assessed and is feasible subject to appropriate funds.

• Whether any alternative sites have been identified for the proposed retail provision should The Pavilion not be able to be relocated, as this forms over 50% of the total retail floor provision in the AAP

No alternative sites have been identified as CSC remain keen to bring forward a retailing extension to The Glades. Site F has been identified as the location for a new leisure facility.

• Questions how residential parking will be dealt with given the number of residential units proposed

Aspirations for low car, town centre living with the town’s outer London location and needs will be in accordance with adopted local and regional policy.

• Enquired as to what the implications would be should Site E, F and G be delayed or not occur

There needs to be flexibility in the Plan to allow for such eventualities

• How, in preparing the AAP, LBB has considered the current economic situation, and how it will be preparing for any upturn specifically regarding Site K

It is anticipated that delivery of the AAP proposals will occur through a number of economic cycles.

• Query complications of bringing forward 50% of housing targets and where certain types of housing will be located

The AAP is a 15 year plan and will therefore extend past the life of the current targets set for the Borough

• Infrastructure requirements need clarification

Policies BTC 31 & 32 to be combined and any small scale developments not identified in the AAP would still be subject to UDP policy and the current government circular on S.106 payments

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• Suggests: Making diagrams clearer/address duplication/correct

table nos/annex some of the information/questions links to SA/ character areas should be brought forward in document/ delete some policies and move to text only.

Noted

DAAP64 Michelle & David Paul

31/01/09 • Against the developments of Site B and L Comments relate to planning applications

• Against tall buildings destroying the view at Church House Gardens and the encroachment of the green area at Queens Gardens and Palace Gardens.

The plan suggests taller buildings and no encroachment are envisaged in Queens garden and minimal on the Site F

• Against the increase in housing provision People need somewhere to live and there are housing targets that LBB need to meet. Town Centres are ideal and sustainable locations for many people

• Commented on traffic congestion and potential parking problems opposite Bromley South Station.

Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP sets traffic targets that see no overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three. Traffic impacts of individual developments must be addressed through transport assessments, which must accompany planning applications. Parking proposals in the AAP are seen as consistent with this overall approach. The Transport Strategy sets out how parking will be managed in the town, both for new development and in the round (whether on or off street). A more detailed Parking Plan is to be developed.

• Queried the high proportion of Council property being redeveloped

Accommodating growth and promoting regeneration presents real challenges. By identify sites the Council are able to start the renewal programme and any development on Council owned sites are still subject to normal planning procedures

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DAAP65 Access & Inclusion Dept LBB

• Commented on shortage of primary school places and the requirement of either the expansion of existing schools or creating new schools

• Recommended clarification in the AAP as to how

provision for additional primary places might be made

Any further work on projections will need to involve assumptions about dwelling size. The current economic climate may lead to families unable to move, over occupying accommodation.

DAAP66 Parks and Greenspace Division

• green transport should be encouraged

Noted. This is a key aspect of the Transport Strategy. An integral part of regenerating the town centre is to manage access and movement to, through and within the centre.

• Church House Gardens needs a purpose built toilet block with a recycled rainwater capture system, and that Church House Lodge also needs a rainwater capture system

• the need for a purpose built skate park area at Church House Gardens

• Suggested that the ex-boating pool would make a superb water feature, and that the playground itself needs to be upgraded with the latest equipment and a picnic area

• Church House and Library Gardens must be preserved, but that there is manoeuvrability in these landscapes to accommodate a wider range of outdoor activities

• Suggested that a new visitor centre is required to become a centrepiece for the town and to encourage residents to be more environmentally responsible

• a tree planting programme throughout all parks, solar panelled lighting in parks and streets and rainfall harvesting to provide irrigation for parks and town centre vegetation

These matters would be part of any planning application and could be discussed at pre-application level. Other issues are outside of the spatial plan but could become part of a Parks Strategy in the future to compliment the AAP

• unculverting the River Ravensbourne at Queensmead & Whitehall recreation ground will provide flood defence measures for town centre development, and bring the countryside into the town providing a community and educational asset

Referred to in AAP. The restoration of the River Ravensbourne is included policy BTC10

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• Encouraged LBB to work closely with the relevant ‘Friends of’ groups to ensure support from the local community

Noted

• new signage in the town needs a strong identity and be audio and tactile to add interest for various user groups, routes of interest be included through the various green spaces, cycle routes and cycle bike parks be included, and outdoor activities delivered through MyTime

Noted. This could become part of a future public realm strategy

DAAP67 The Salvation Army, Bromley

05/02/09 • Standing by previous submissions made on the Preferred Options (2006) and the Revised Preferred Options (2007) – namely their desire to stay within Site G and they believe they have an important role in the community

Faith provision will be part of any re-development propels

DAAP68 CGMS Consulting on behalf of the Metropolitan Police Authority

06/02/09 • Commented that Policy BTC32 which outlines specific developer contributions as part of the planning application process does not list policing, which is contrary to London Plan Policies

Agreed text to be amended

• Recommended that Policy BTC32 provide clarification that where the AAP refers to the provision of community facilities, it will include policing facilities

DAAP69 Town & Country Housing

• Suggested that actual targets for the provision of ECH special needs projects be mentioned in the AAP

Noted

• under supply of hotel accommodation which could be a catalyst for a multi-tenure project.

Agreed two sites identified for hotel use. Supporting the provision of high quality facilities will increase the attraction of Bromley as a place to live and will encourage people to visit local attractions, supporting their ongoing viability and contributing to the local economy.

• Recommended that homebuy/shared ownership be mentioned

This is an issue for Housing Division not for a spatial plan

• Recommended zero parking provision as it is standard in other Town Centres

An average parking provision of 0.5 spaces is proposed, which is within London Plan guidelines

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• Recommended that sustainable code requirements be extended to private sale development and commercial development in line with affordable housing.

This issue will be addressed as work on the Core Strategy progresses

• More detailed description of recycling storage required

Policy ER3 of the adopted UDP. This policy and supplementary planning guidance also promotes appropriate design and layout for ease of separation and collection, and the use of recycled construction materials.

• Recommended that the current planning requirement that commercial ex-sites be marketed for 18 months before going to residential use be scrapped.

This issue will be considered as part on the on-going work related to the Core strategy

• Commented on the provision of a sports facility The Pavilion if moved will be replaced and apart from Church House Gardens little opportunity to provide any other outside activities.

• Commented that Council owned sites should consider to bid for direct grant from the HCA and should be used for affordable housing and remain council owned to obtain an income stream

The HCA will be approached as part of the on-going partnership approach.

• Recommended that CPOs should used to acquire dilapidated properties in the town centre.

CPO’s need to be linked to a planning proposal. If would be for Chief Officers to advise whether the Council monies should be used to purchase properties prior to any CPO and PPS6 states that Area Action Plans and Compulsory Purchase Orders should be used to deliver town centre growth and manage change.

DAAP70 Mrs G Hall 03/02/09 • Site A - Commented that development should reinforce the Victorian character of the area and not towers.

Development on Site A will need to show that it could be accommodated without adverse impact on the character of the surrounding area and the developer will be required to demonstrate that the proposed development will not result in unacceptable impacts.

• Site B – Against any development as it will lead to a loss of greenery and impede the historic site of Bromley College

Site B has been identified for development since 1994 UDP. The site cannot be removed form the AAP as it is already contained in the current adopted UDP 2006. The revised AAP makes it clear that a sensitive and high quality design is essential to minimise the impact of development on the setting of the adjacent listed buildings.

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• Site C – In favour of it being retained an returned to it’s original purpose

The office accommodation in the old town halls is not suitable for current requirements and a sympathetic refurbishment would be more viable. Listed Building status would limit the capacity of the buildings and it is the Council’s objective to reduce maintenance expenditure and reduce energy and carbon footprint.

• Site E & F –re-development should be kept in line other historic buildings in Bromley

Noted

• Site G & Site H – Recommended that historic buildings be maintained and new development kept in line with them to retain market town environment. Also commented on shortage of parking provision for new residential properties.

High quality design and the way in which new development enhances the character of the area and respects the local context is particularly important in the town centre. However development on this site will also have to be viable in order to bring about the required new retail floorspace and improved offer to visitors. New residents will be unable to purchase residential parking permits.

• Site J – Commented that hotel should be situated here and that the site should be developed to cope with increased commuter load and residential developments.

An hotel would require rafting over the railway lines which is very expensive. Hotel development has therefore been identified elsewhere.

• Site K – Against overcrowding of the area, increased parking provision for new residents and development should be kept in line with architecture of the area.

Supporting the provision of high quality facilities will increase the attraction of Bromley as a place to live and visit, thereby supporting the town’s ongoing viability and contributing to the local economy. Developers will be expected to show the way in which new uses and buildings integrate with, and enhance the town centre as a whole, providing good links and relationships with existing uses and buildings

• Site M – Recommended that development not encroach on the green spaces

There is no intention of taking any soft landscaped areas and the protection of existing spaces are highlighted in the plan.

• Site N – Recommended that amount of greenery for the area be increased and not decreased

The intention is to improve the current hardstanding by opening the area up with appropriate landscaping

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• Site P – Commented that greenery be retained and the possibility that development might destroy a historic site.

The historic building is untouched by the site P’s boundary which relates to the current site occupied by the food store and car park

DAAP71 Affinity Sutton 04/02/09 • Recommended that the affordable housing 50% level for the London Plan be incorporated.

Current UDP policy on Affordable Housing is the overriding policy. The work on the Core Strategy will look at this in more detail once the London Plan has been revised

• That the affordable housing should be a mix of tenures, social rent, intermediate rent and shared ownership

Noted

• Commented that social rented flats of 2/ 3 bed flats should be for families and 1 bed flats be resisted Also commented that for shared ownership only 1 and 2 bed flats be considered

• Stated that all homes should be developed in

accordance with the code of sustainable homes with a minimum standard level 3 and secured by design.

• Recommended that the council should not

consider payment in lieu of affordable housing DAAP72 John Street,

Bromley Green Party

03/02/09 • Queried the increase in air and noise pollution in central Bromley

There is much greater emphasis on the need to deliver sustainable development and tackle climate change, air and noise pollution will be monitored. The Transport Strategy takes account of all anticipated developments in the area and makes recommendations with regards to managing traffic and promoting sustainable movement. Policy BTC15 relates to Noise specifically. Major changes have taken place with regards to national and regional planning policy and here is much greater emphasis on the need to deliver sustainable development and tackle climate change. These are local issues as much as they are global.

• Commented that there should be a requirement that all buildings be constructed to a high level of eco-friendliness

Noted, Policy BTC8 relates to sustainable design and construction.

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• there needs to be public transport improvements before major re-developments burden the town centre.

Policy BTC26 (Phasing of Transport Improvements) sets out the requirement that the transport measures needed by new development should be in place first.

• there should be consideration of other town centres in the borough

Bromley is the major comparison centre in the borough. The other towns function as convenience centres, Orpington is already under investigation and the other towns will follow as resources allow

• Against tall buildings and dense development Design Principles for each of Opportunity Areas are set out in Appendix 4. these identifies scope for taller buildings and dense development that can be accommodated without compromising views or local amenity.

• Suggested an increase in the pedestrianised area

An integral part of regenerating the town centre is to manage access and movement to, through and within the centre

• Commented that green spaces should be protected in the plan

Green spaces are very important and is one of the town’s strengths and this is clearly identified in the plan

• Also commented that older buildings of character and heritage be protected

No listed buildings are at risk by the end of the Plan period. High quality design and the way in which new development enhances the character of the area and respects the local context is particularly important in the town centre

• Recommended that there be greater improvement of leisure activities

Noted. The Council is committed to continual improvement of facilities

DAAP73 Sheila Campbell

31/01/09 • Site J - Commented that Network rail should make it DDA compliant

Bromley south station has been identified by the DfT for improvement under the Access for All programme. Funding is currently being sought by Network Rail

• Recommended that the council should not consider payment in lieu of affordable housing

Noted

• Site E – Against moving the Pavilion. The Council have to identify space for additional retail floorspace given the need for an updated leisure centre a new facility would meet Mytime requirements.

• Site F – Against the development as it would spoil the Heritage site of the Bishops Palace

Currently the setting of the grade II listed Bishops Palace is compromised by the adjoining civic buildings. The Design Principles for Site F set out in Appendix 4, ensure that new development will respect and enhance the scale, architecture and landscape of the Palace such that its setting will be improved.

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• Site B – Object to this development as inappropriate

Statement appears to relate to current planning application and the revised AAP makes it clear that a sensitive and high quality design is essential to minimise the impact of development on the setting of the adjacent listed buildings.

• Site L – Supports the development of a hotel Support welcomed

DAAP74 House of Fraser

30/01/09 • Commented that Retail capacity study is 5 years out of date

Currently being updated

• Commented that only one scheme should be brought forward at a time to ensure that there is no confusion about which will be delivered first and ensure that it does not fail in competition with another scheme.

Site G and Site E are in differing Phases. All retail studies predict that BTC requires additional retail floorspace in order to sustain competitiveness. The phasing of development on this large site is critical in achieving the full benefits of the scheme for the town centre.

• Commented that there should only be one further department store within Bromley

• Also commented that the High Street needs to be

pedestrianised as a whole to ensure good pedestrian links to the southern section.

If a department store is located on Site G any proposals would have to ensure good linkages with the High Street generally.

DAAP75 Bromley Adult Education College

29/01/09 • Commented on increased demand for social, cultural and work related training activities.

• Recommended provision of a designated training / education centre within the redevelopment.

• Proposed several of the sites to possibly incorporate educational / training facilities – Sites A, F or G.

Community facilities are identified on a number of sites and these could certainly include educational/training facilities

DAAP76 Bromley Mytime

22/01/09 • Welcomed the revision to the Plan that commits the Council to retain the pavilion at its current location for at least 10-15 years. Given the deterioration of the Pavilion looking forward to the improvement scheme that is under discussion with the Council.

Support welcomed

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DAAP77 Rev AR Marshall & Rev. GK Marshall

22/01/09 • Requested to know the number of residents consulted and number of meetings held and publicity involved.

There has been widespread publicity since 2005 including exhibitions and talks to residents. Over 30000 leaflets have been produced and circulated during the process and numerous articles in the local papers.

• Against the increase in parking spaces on Site B and development plans were not sensitive to the adjacent heritage buildings

Statement appears to relate to current planning application and the revised AAP makes it clear that a sensitive and high quality design is essential to minimise the impact of development on the setting of the adjacent listed buildings.

• Against taller buildings

Bromley has been and continues to be subject to a significant amount of development pressure within a relatively small area. There is already planning permission for an 11 storey residential block on the old A&N annex in Ringers Road which forms part of Site G

• Against the increase of flatted development Wherever possible, growth needs to be accommodated by more efficient use of land and buildings within existing centres. Densities may be increased where appropriate and sites should be identified for redevelopment or conversion in order to meet the scale and type of need identified of which housing is one

• Queried the strain on the infrastructure

All major developments in the town centre will be expected to contribute to the provision of services, facilities and infrastructure within the area in order to deliver the environmental, social, community, education and health capacity needed to respond to increasing pressure generated by the development.

DAAP78 The Churchill Theatre

26/01/09 • Commented on the lack of reference to coach parking

The need for facilities for coaches to support new development has been highlighted on a site-by-site basis. In accordance with the Transport Strategy, the need for other additional coach parking will be kept under review.

• Welcomed increase in town centre residential accommodation

• Also welcomed improvement in Site N • in favour of new hotel in Site L but developments

should be sympathetic to local residents.

Support welcomed

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• DDA needs of Bromley South Station need to be addressed urgently.

Noted, Network Rail are working on an Access for All programme

DAAP79 FR. DV Cossar, Bromley College

26/01/09 • Against the development of Site B as it should be retained as a green space and give a view of the college buildings.

The college buildings cannot be seen from ground level in Tweedy Road and the site has been fenced off for many years.

• Commented that Site P developments should not be allowed to overshadow the colleges’ southern side.

Noted, any development on this site will need to take such issues into account as detailed in the design guidance in the AAP as well as Policy OSL.

DAAP80 Turley Associates on behalf of TRW Pensions Trust Limited

03/02/09 • Client supports plans to improve BTC but considers that the demolition of 44 High Street which is a landmark building or townscape value, is not necessary to ensure comprehensive re-development.

• Considers late amendments to site boundaries on

Site G unjustified.

PPS1 indicates that policies should promote mixed use developments for locations that allow the creation of linkages between different uses and thereby create more vibrant places. New development can also contribute to regeneration by attracting businesses and generating inward investment. It is necessary to bring forward a comprehensive development that provides the required floorspace and an enlarged Site G allows for such a scheme to go forward. The Draft AAP was published to elicit public response prior to finalisation of the pre-submission document so the comment regarding late amendment to the site boundary is unjustified.

DAAP81 Turley Associates on Behalf of ESN (Scotland) Limited (Scottish Power Pension Scheme)

04/02/09 • Considers 78-84 High Street, which is within the conservation area, make a positive contribution to the conservation area and so should be preserved as there is no preferred developer/or specific proposals to justify demolition.

This site has been included within the original Site G in each of the preferred options consultation documents having been identified in through the initial stages of the AAP. In order to achieve the required increase in retail floorspace Site G was identified as the most appropriate location given the other constraints for the town to expand. Any re-development within a conservation area would be expected to further enhance the area and therefore design would be a critical factor. UDP policy states that in cases of demolition within conservation areas “there will be substantial planning benefits for the community from redevelopment which would decisively outweigh loss from the resulting demolition”. It can be argued that the expansion of retail floorspace will enable the town centre to regain its prominent position in the retailing hierarchy as well as provide opportunities for providing residential units to meet new homes targets

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DAAP82 Trustees of Bromley and Sheppard’s Colleges

02/02/09 • Ask that Site B is restricted to the area shown in the UDP

• Suggested that the wording for Site B be changed to

make it clear that only modest scale, low density development only would be acceptable, possibly semi-detached housing as originally on site.

• It the above is not feasible then the site should be

landscaped into a public space

Agreed – Site Boundary as shown in the AAP to be amended. Any changes to the development option for the site will need to wait for the inspectors decision The site has been identified for residential since housing was demolished to build the relief road. It is a proposal site in the adopted UDP and was also identified for the same purpose in the 1994 UDP

• That developments on Site P should respect and enhance the conservation area of the colleges and against building to the edge of College Slip

Agreed, the design guidance and Policy text to be amended

DAAP83 GLA and TfL 06/02/09 • Would wish to see the renewable energy strategy widen to an energy strategy which would also include feasibility work into town-centre wide district heating network.

The Council will work with partners in undertaking feasibility work into a town centre wide energy strategy that contributes to the London Plan objectives on decentralised energy and provide a sound evidence base for proposing carbon reduction targets.

• Policy BTC12 should be strengthen to reflect London Plan policy 4A.5

Agreed. Text amended Policy now BTC13

• Policy BTC8 should refer to all new development reducing its CO2 emissions. Plus reference should be made to the up-coming government Code for Sustainable Buildings for Non-domestic buildings.

The Council will define the broad parameters and requirements of future strategic energy infrastructure. New development will be required to reduce its Carbon emissions through energy efficiency measures such as improvements to the building fabric and energy efficient services within buildings • Consideration be given to setting higher code levels

or CO2 reduction targets. • Policy BTC2 should be amended to accord with the

Secretary of State’s statement – made in 2006 – that density/locations in Bromley should accord with the London Plan density matrix ( table 3A.2). Suggest text ‘assessed against’ should be changed to ‘should accord with’

Agreed. Text amended but with a reference to site characteristics. Development proposals should accord with the Density Matrix in the London Plan (Table 3A.2) taking into account site characteristics and the surrounding character of the town centre and adjoining residential areas

• Further discussions need to take place on the affordable housing percentage.

This would be a matter for the Core Strategy.

• Text additional to Policy BTC3 regarding housing mix. ‘all should be added before ‘new Housing’ as all new housing should be built to lifetime homes standards.

Agreed

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• Refer to the Mayor’s recently review of the London wide housing capacity Study in paragraph 4.3.2 as targets may change.

Noted

• TfL Extensive comments Response attached as an appendix. DAAP84 Religious

Society of Friends

06/02/09 • Commented on the increase of noise and air pollution levels with increased vehicles in the area due to the developments

Town centre locations where expansion is sustainable. Pollution and noise will be monitored Policy BTC16 relates to noise issues

• Also commented on the shortage of parking spaces with 1200 flats built.

Parking proposals are seen as consistent with the overall approach to transport set out both in the AAP and the supporting Transport Strategy. The Transport Strategy sets out how parking will be managed in the town, both for new development and in the round (whether on or off street). A more detailed Parking Plan is to be developed.

DAAP85 Mrs Margaret Craig

04/02/09 • Commented on loss of shops and cafes due to high rents and rates

Many retailers are still interested in coming to Bromley but there has been some loss of retailers due to outside influences beyond the Council’s control. A good reason to take an holistic approach to improving the town. The Council do not set the rent levels or receive business rate monies merely it collects them on behalf of the Government.

• Against the development at Site K due to it being a wind tunnel.

Potential developers are fully aware of previous problems in the area, however, good design can easily overcome such problems

DAAP86 Ms Kathleen Craig

04/02/09 • Objected to tall buildings on Site L, G and A

The development of Sites L, G & A is controlled by the design principles set out in Appendix 4 of the AAP. These ensure that the scale and massing of proposed buildings will be assessed with particular regard for their impact on views and residential areas.

• Should not compete with other centres or towns If BTC does not strive to compete there will be an exodus of retailers and other businesses which will create loss of jobs for local residents. The town is a metropolitan comparison town centre and not a convenience centre for locals. One of the underlying development principles of the Bromley Area Action Plan is to preserve and enhance all the features that make Bromley distinctive and to continue to provide the community with its sense of place and history

• only low density , low level housing would be suitable for Site B or keep as an open space.

It has always been the intention of the Council to replace the housing lost on site when the ring road was built and this site has been in the UDP since 1994.

• Against the development of a multi-storey supermarket and car park on site P as it does not respect the conservation area.

With careful, sensitive design such issues can be overcome especially within a conservation area and the design principles provides developers with guidance. One of the underlying

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development principles of the Bromley Area Action Plan is to preserve and enhance all the features that make Bromley distinctive and to continue to provide the community with its sense of place and history

• Against the wholesale destruction of residential properties at Site G smaller scale development should be encouraged.

If the town is to expand there is little space to do so given that residential surrounds the towns boundary. Any development has to be achievable and viable and without a more expansive scheme there would be no chance to bring back the House of Fraser.

• Commented that there should not be encroachment of green spaces at Site N

Active frontages facing the park will provide greater overlooking and sense of security than at present. Improved landscaping would assist in the full potential of linked trips between the park and shopping could be developed further by a more attractive, safer and more visible route between the gardens and the High Street.

DAAP87 Northpoint (Bromley) Management Co Ltd

06/02/09 • Broad support for objectives for the town

Support welcomed

• Commented on the need to include specific measures to improve traffic flow, ensure no new dedicated parking spaces, reducing on street parking and the acceleration of a permanent Park and Ride Scheme as well as improving public transport network and facilities.

• The impact of the additional residential units on

traffic volumes should be addressed

Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP sets traffic targets that see no overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three. Traffic impacts of individual developments must be addressed through transport assessments, which must accompany planning applications. Parking proposals in the AAP are seen as consistent with this overall approach. The Transport Strategy sets out how parking will be managed in the town, both for new development and in the round (whether on or off street). A more detailed Parking Plan is to be developed. Park & Ride proposals will be taken forward subject to further investigation. The AAP is not dependant on delivery of Park & Ride.

• The Plan should demonstrate how additional residential units meet the Boroughs housing needs and that they can be accommodated within the existing infrastructure.

Page 63 para 4.3 of the AAP details the reasoning behind promoting town centre living and assist in the provision of new homes and which currently amounts to only 3.35% of all the borough’s hosing stock. All major developments in the town centre will be expected to contribute to the identified infrastructure requirements

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• Commented that public safety considerations should be feature of the new developments and should be included in the Area Action Plan and especially at Bromley North and Shortlands stations

Such issues will be part of any infrastructure planning however this is a spatial plan and the Council, whilst they can request improvements, have no authority as to how the train operators run their stations

• the provision of community facilities should be detailed and further consultation with the community was needed on this.

The community aspect of the development options would form part of any planning application and be consulted on in the normal way.

• the Council should apply any capital receipts received to the town centre area covered by the plan

This issue is not within the remit of the AAP and would be dealt with at Member level.

DAAP88 Natural England

06/02/09 • Paras 2.1.15 to 2.1.20 make no reference to the environmental and recreation uses of green open spaces Also commented that there seems to be very little mention of green / open spaces

• the AAP should be more proactive in support of its

reference to the protection and enhancement of the environment

Noted. Text to be amended where appropriate however, Policy BTC33 will be updated and strengthen to reflect comments made

• Public Realm should not just relate to hard standing areas in relation to improving access for business and retail opportunities.

Noted

• the Council need to ensure that environmental, ecological and biodiversity issues of Bromley are also considered

• Support for Policies BTC 10, 11, 14 but want a

more explicit reference to PPS 9. in fact there should be a stronger link to PPS 9 in the entire document

Noted. Text to be amended

• Welcomed the comprehensive Transport Strategy. Policies BTC 21, 22, 24 and 28 relating to transport schemes encouraging sustainable travel choice were welcomed as well as the Sustainability Appraisal, subject to strengthening reference to PPS9

Support welcomed

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DAAP89 English Heritage

04/02/09 • Welcomed that the Plan included protecting and enhancing the historic environment and promoting high quality design

Support welcomed

• Commented that there was not a lack of distinctive landmark building in Bromley but merely a question of issue and maintenance

Noted

• Concerned about the possible locations of some of the tall buildings and the impact on tall buildings on listed buildings the Bromley Town Conservation Area and the impact on Keston Ridge.

Appendix 4 of the draft AAP contains the design principles to be followed as proposals come forward for each of the Opportunity Sites. Possible locations for tall buildings have been identified on Sites A, G, K and L. In each case the potential for high buildings is assessed in relation to existing development on adjoining sites and to the potential affect on views towards the site from elsewhere. Design criteria governing scale and massing and impact of views are then established that will be used to control future development on those sites. In this way the impacts on listed buildings, on the conservation area and views to the Keston Ridge are taken into account.

• Commented that objective 5 regarding enhancing character and heritage of Bromley has got no reference as to it’s implementation

Objective 5 refers to enhancing the character and heritage of the town centre whilst ensuring that new development adds to its distinctiveness. This objective will be implemented by means of determining planning application for all developments against the new Policy BTC16 on Design Quality. An appropriate indicator for Objective 5 could be ‘Numbers of determinations of planning applications’ (table 8.1.1 on p. 171) - the qualitative assessment of which will bring about the improvements to appearance of the town centre and heritage buildings.

• commented that as there is no policy on the historic environment Recommend that Policy BTC16 be expanded to include “an appropriate enhancement of the historic environment”

Agreed, Policy to be amended

• Welcomed the specific reference to the historic environment in BTC32 on developer contributions that might be sought

Support welcomed

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DAAP90 Ross & Christine Jones

06/02/09 • Supported proposals to reverse the decline of Bromley as an important shopping centre and an improvement of its role as a high quality entertainment/business/leisure/business location and transport interchange

Support welcomed

• Objects to the scale of the residential development in the town centre

Schemes need to be shown as deliverable and town centre living is an ideal, and sustainable location for many. Whilst the priority is to regenerate the town centre to provide for retail, social and community activities it is recognised that uses such as residential and business uses are likely to be important to the overall viability of the proposals.

• Commented on the conflict with conservation area objectives

Preserve and enhance are certainly important but equally important is to ensure BTC remains an attractive and viable town centre. High quality design and the way in which new development enhances the character of the area and respects the local context is particularly important in the town centre

DAAP91 Philip and Mary Finely

06/02/09 Comments on Site A • Policy on site A seems too ambitious as it is a

relatively small site subject to the constraints of an existing listed building.

• building up to 400 residential units would constitute

over development and queried whether the current flats in the area would be demolished

• seeking 2000 sq m of B1 office development

seemed unrealistic and queried whether Northside House would be retained.

• Queried the amount of proposed mixed development

of the Site. • Questioned if the current existing health facility on

the site would be retained. • Commented on the feasibility of on site provision for

residential parking • the location of an improved market facility at the site

The Council considers the on site parking provision envisaged is feasible to be provided on site in decked parking. Residents of the new development would not be issued with parking permits for nearby residential streets. Access improvements will be necessary, though TfL will need to be consulted about any proposal for direct access onto the A21 Tweedy Road. The development options for this site have been reassessed and it is considered that the overall massing of development which would result from the 400 unit scheme would be difficult to integrate with the surrounding area and is likely to result in a significant change in local character and impact on residential amenity. It is, however, considered that the smaller scheme could be integrated more successfully with the surrounding area with a reduction in height towards the western boundary and interface with residential properties. Further detailed design development would be required to demonstrate that a higher density development could be accommodated without adverse impact on the character of the surrounding area.

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might further constrain it’s capacity. • Queried the need to build more in Bromley in the

light of current economic conditions • Requires clarification on access to the site

The Draft AAP states that the number of units should be in general conformity with the AAP and the developer will be required to demonstrate that the proposed development will not result in unacceptable impacts. At this stage there are no plans to demolish Northside House, however if this ultimately was suggested as part of any detailed planning application there would be a requirement to re-provide the office space in order to protect future employment opportunities. The Bromley Health PCT would also be party to any health requirement they consider necessary and as such the development options identify replacement facilities.

DAAP92 Robert Gregory

05/02/09 • Commented that there should be a department created to identify and resolve AAP problems

There is already a Town Centre Development Team that is overseeing the AAP process and other initiatives in other town centres in the Borough.

• Concerned about the possible disruption developments will cause on existing businesses

If investors are attracted into the town this will help all businesses

DAAP93 Robert Bristow 06/02/09 • Concerned over lack of clarity as to future uses within site A

• Concerned over decked car parking • Suggests that development be scaled down to

acknowledge the modest scale of existing development that abuts the site

• Concerned that number of proposed units has gone

from 250 to 400 • Feels that the residential development will provide

sub-standard housing • Concerned over the height of proposed tall buildings • Concerned over added traffic and pressure on

infrastructure

Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP sets traffic targets that see no overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three. Traffic impacts of individual developments must be addressed through transport assessments, which must accompany planning applications. The development options for this site have been reassessed and it is considered that the overall massing of development which would result from the 400 unit scheme would be difficult to integrate with the surrounding area and is likely to result in a significant change in local character and impact on residential amenity. It is, however, considered that the smaller scheme could be integrated more successfully with the surrounding area with a reduction in height towards the western boundary and interface with residential properties.

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Further detailed design development would be required to demonstrate that a higher density development could be accommodated without adverse impact on the character of the surrounding area. The Draft AAP states that the number of units should be in general conformity with the AAP and the developer will be required to demonstrate that the proposed development will not result in unacceptable impacts.

DAAP94 Friends of Bromley Town Parks & Gardens

• Pleased that the restoration of the River Ravensbourne is now integrated into policy BTC10

Noted

• Recognise the principle for the long term plan for the town but do not agree with the context of the AAP

Friends of Bromley Town parks Gardens have been included in all the consultation processes and have attended many workshops and presentations and knows the history of the background to the AAP process. No constructive alternative suggestions for expansion were ever put forward regarding where to accommodate the required level of retail floorspace. No change is not an option if jobs and investment in the local economy is to be secured for future generations.

• Feel that development on sites G & H will have an adverse effect on key vistas and views

• Concerned over the view from Queensmead toward sites G & H

• Concerned over the view from Church House Gardens towards Site G & H

• Concerned over the view of the skyline from the amphitheatre in Church House Gardens

• Concerned over the view south east from the terrace of Church House towards sites G & H

• Concerned over views south out of Library Gardens

There is already a permission for a taller building on the site of the A&N Annex in Ringers Road. The town is a regional centre and as such an ideal place for expansion however design principles will be important as to not create a continuing span of development. The design principles that will be used to govern development on Site G ensure that the scale and massing of development is assessed with particular regard to views towards the site from the surrounding area. The view of the skyline is already dominated by the Churchill Theatre/library.

• Concerned over impact of development on Site L on the view of Keston Ridge

Appears comments relate to current planning application. The site boundary was altered in the draft AAP to ensure development was at an acceptable height and included community uses i.e. the Bromley Christian Centre.

• Concerned over the impact of development on Site B on the view of Bromley College and its grounds

Site B has been identified for development since 1994 UDP. The site cannot be removed form the AAP as it is already contained in the current adopted UDP 2006

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• Concerns over the construction of cafes/bars (sites E & M)

Policy OSM: states cafes/restaurants not bars. There is already a valid planning permission for an extension to the existing restaurant fronting the gardens.

• Concerns over impact of development at Site E on Queens Gardens

The Design Guidelines to be expanded in order to guide future development especially impact on the adjacent park

• Concerned over the impact of development at the Civic Centre (Site F)

There was no intention to destroy any historic structures and the site plan was revised accordingly.

• Site N – would support the aspiration of widening the frontage, suitably landscaped to present a more inviting entrance

Support welcomed

• Seek clarification as to how tall ‘taller’ is This would depend largely on location. Some sites could accommodate some taller buildings subject to amenity issues etc

DAAP95 Environment Agency

06/02/09 • Supported the vision fully. Welcomed the inclusion of a flood risk policy

Support welcomed The AAP recognises the contribution the design and construction of development makes to delivering a town centre that is sustainable, and resilient to the potential impacts that climate change may have upon Bromley over the next 100 years in light of the possible increases in flood risk.

• Pleased that appropriate sequential tests has been undertaken and this has been informed by a Strategic Flood Risk Assessment. (Policy BTC9)

• Pleased that their advice on surface water flooding has been incorporated into the BTC11

• Suggested that Green Roofs be more prominent

in the AAP Noted

• Highlighted that large areas of Bromley Town Centre are located with groundwater source protection zones and that special pollution prevention measures must be taken into account for development in this area and requested that Policy BTC34 is updated to reflect this.

Agreed text to be amended

DAAP96 Moat Housing 06/02/09 • Supported the view that provision of additional housing will create a better balance of uses in the Town Centre

• Fully supports the views on Lifetime Homes. Proposals give an opportunity to provide housing

Support welcomed

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of all tenures for people with disabilities • Supported requirements for inclusive design, car

clubs and S106 developer contributions • adequate provision of affordable housing is

absolutely critical in helping to provide mixed, sustainable communities that people want to live in

Noted

• Commented that there is a need for a significant increase in larger homes that are suitable for families

Noted. Developers will be expected to provide a range of units to help meet demand.

• Concerned that the aspiration to reach zero carbon by 2016 with additional costs involved could adversely affect the amount of new development in the borough

See Para 5.6.5 of Draft AAP and to re-iterate; all residential developments should achieve a sustainability rating of at least Level 3 as set out in the Government’s Code for Sustainable Homes or equivalent. Major regeneration schemes should achieve the highest possible level of the Code, including provision of ‘zero carbon’ homes (Level 6).

DAAP97 Nathaniel Lichfield and Partners on behalf of Capital Shopping Centres

As a major stakeholder and investor in the town centre agrees with the AAP that there is a need to attract new retailers to the town and supports the vision (para 3.1.3), and whilst supporting the underlying principles of the Spatial Strategy have suggested some textual changes

Page 25 – additional text: The retail sector plays an important role in maintaining a healthy local economy and is a major contributor to the local employment market. The promotion of retail development on identified Opportunity Sites will assist in strengthening the range and type of jobs available in the retail sector.

Agreed. Whilst the priority is to regenerate the town centre to provide for retail and other facilities it is recognised that all business uses are likely to be important to the overall viability of the proposals and provide employment opportunities in the future.

Page 30: The potential to create distinctive zones of activity including leisure/ culture which will add diversity and create new destinations within the town centre. The relocation of The Pavilion Leisure centre to the Civic Centre site provides an opportunity to significantly enhance the leisure and cultural offer in the town centre.

Already commented on in plan

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Page 31: Well planned and designed commercial uses such as restaurants and cafes can make a positive contribution to the improvement and appeal of the public realm and will be encouraged in appropriate locations.

Agreed

Page 59 – Policy BTC1, new paragraph: The figures identified above, in Table 4.2 and elsewhere in the AAP are intended to guide the likely future levels of development and are not intended to be prescriptive.

Agreed ‘The figures are intended to guide future levels of development on the Opportunity Sites’.

Page 67 Policy BTC4: The Council will work with the private sector to provide up to approximately 42,000 sq m (gross) additional retail floorspace… Retail development will be required to provide for prime retail floorspace and a range of unit sizes. Subject to demand this could include including smaller units suitable for independent traders to complement and be fully integrated and well connected with existing retail facilities.

Agreed. Text to be changed to ‘approximately’

Page 116 Policy OSE The site is identified as being suitable proposed for an extension to The Glades Shopping Centre to provide approximately a net additional 22,000 sq m of (gross) retail floorspace. The Council will work with developers to secure the relocation of the existing leisure centre within the shortest possible timescales.

Not agreed to include “within the shortest possible timescales” the Opportunity Sites have been phased in over the 15 year timescale to ensure the necessary infrastructure is capable of supporting the changes. Site G is for retail led mixed use town centre development is key to the successful regeneration of the whole of the Action Plan Area and will need to be brought forward prior to other new retail development. If the leisure centre is not re-located onto site F there will be a need to undertake a sequential test as to the possibility of other sites being available.

Page 130 table 5.1 Site E Phase 3 2/3 Earlier relocation of the leisure centre should not be discounted if it is demonstrated to be feasible within these timescales.

• Retail- approximately 22,000 sq m (gross) of net additional retail floorspace

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• No additional parking Page 130 table 5 Site F: Add Earlier relocation should not be discounted if it is demonstrated to be feasible within these timescales. Page 138 para 6.4.2 additional paragraph If it is demonstrated to be acceptable and assists the Council in achieving the vision for the town centre as set out in the AAP the development of Opportunity Sites may be progressed in advance of the indicative phasing

Page 140 table 6.1 Site E: Phase 3 2/3 The phasing of development will be dependent on the development of Site F. Including Site E in Phase 3 will allow time for the leisure centre to be relocated. Site F: If a decision is taken not to relocate the Pavilion Leisure Centre on Sit F, Site G could come forward to ensure Bromley increases its retail offer and its ability to compete with nearby centres, and to maintain its position in the shopping hierarchy whilst alternative sites are considered. Phasing allows for coordination of development across sites F and E. Add:

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If a decision is taken not to re-locate The Pavilion Leisure Centre to Site F an assessment of suitable alternative sites will be undertaken. The failure to secure an extension to The Glades and the relocation of a leisure facility will seriously undermined the AAP’s vision for the town centre and its competitiveness in the sub-region. Page 219 key Design principles: The redevelopment of the site to provide prime retail floorspace a quality department store will increase the retail offer in the town centre.

Agreed – text to be amended

• Agrees that there is a need to improve the management and provision of public parking

• • Supports public transport improvements and

encourages the town centre to be accessible by a range of different modes of transport (BTC21, BTC22, BTC23, BTC24) so long as this does not bring about a net loss of capacity at existing car parks

Support welcomed. It is not the intention for there to be a net loss in overall car parking in the town.

• Considers that any relocation of facilities at the Pavilion should be identified as a priority. Will continue working with the Council to promote development at Site E & F and that the relocation of The Pavilion to Site F is fundamental to achieving the vision but Strongly object to the relocation of The Pavilion being in Phase 3 – feel this is vital to creating the vision

Site F has been identified as the most suitable location for the leisure centre. However the redevelopment of Site G for a retail led mixed use town centre development is key to the successful regeneration of the whole of the Action Plan Area and that relates to the phasing of this and site E.

• Supports in principle the requirement for around 42,000 sq m of additional retail floor space as set out in BTC1

Support welcomed

• Supports the redevelopment of The Pavilion for retail use as identified in policy BTC6

Support welcomed

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• Agrees with the principles in the draft AAP regarding enhancing public realm at Site M

Support welcomed

DAAP98 Susan Pussey 06/02/09 • Opposed to development of Site B as it is adjacent to heritage buildings

This site has been earmarked for development since adopted in the 1994 UDP. One of the underlying development principles of the Bromley Area Action Plan is to preserve and enhance all the features that make Bromley distinctive and to continue to provide the community with its sense of place and history

• Considers any development over 3 levels on Site P is inappropriate

The site is in a conservation area with two storey dwellings adjacent naturally any design would have to take account of these issues.

• Commented that any hotel development on Site L would have to be restricted to 3 levels to avoid impeding the view

Comments relate to planning application

• Commented that there was no mention in the plans of the provision or improvement of a leisure facility for the benefits adults on benefit or pensioners

The AAP looks at access for all rather than individual age groups. The Area Action Plan encourages new town centre development, which will serve existing and new communities well, offering them a variety of goods and services including access to leisure facilities, maximising the advantages of its distinctive setting, and providing a centre that people are proud of and enjoy visiting.

DAAP99 James Trimming

06/02/09 • Objects to 400 units on Site A • Felt development of Site A would be detrimental to

the area and create ‘rat runs’ • Commented that little thought had been put into the

development of the site as there will be nowhere for buses to park

• Understands the need for some redevelopment of the site but strongly opposes the increase from 250 to 400 units and the creation of a multi-storey car park.

The Site is included in the adopted UDP (2006) and has therefore been identified as an Opportunity Site in the AAP Retention of the existing bus stands (or adequate replacement) is set out in Policy OSA. Further detailed design development would be required to demonstrate that a higher density development could be accommodated without adverse impact on the character of the surrounding area. The Draft AAP states that the number of units should be in general conformity with the AAP and the developer will be required to demonstrate that the proposed development will not result in unacceptable impacts however the pre-submission AAP will show development options to include 250 residential units as shown in the Revised Preferred Options

DAAP100 Carolyn Elliott 06/02/09 • Concerns over density of Site G, height and pressure on local schools and services

The correct level of infrastructure requirements such as health and educational facilities are crucial to the success on the plan. Policy BTC32 regards developer contributions.

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The redevelopment of this site for retail led mixed use town centre development is key to the successful regeneration of the whole of the Action Plan Area • Concern with extra traffic around site G

• development on Site L would block the view of Keston Ridge and overshadow St Marks School

Accommodating growth and promoting regeneration presents real challenges and whilst developments need to be viable they also need to take account of surroundings. Design Principles in the AAP are there to guide potential developers

• Felt that the development of Site B would obscure the view of Bromley and Shepherds College

As previously noted Bromley College cannot be seen from ground level in Tweedy Road and the current planning application does not obscure views of Sheppard’s College.

DAAP101 Atisreal on behalf of Land Securities Trillium

04/02/09 Commented on Site L • The proposed road safeguarding area represents

a significant land take from Proposal Site L and this approach is not acceptable to Land Securities Trillium as it has not been adequately explored and justified by the Council.

The Council considers the land safeguarded at Site L to be justified to support necessary public transport priority improvements.

• The allocation of the safeguarding area will blight the development potential of the site and will prevent the site from making a positive contribution to the town centre.

• The extension of the proposal site boundary to include the Bromley Christian Centre creates complications in relation to the delivery of land uses under the allocation and uncertainty that may hinder the site coming forward in the short term.

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DAAP102 Highways Agency

06/02/09 Area Action Plan:

• M25 Junctions 3-5 is presently heavily congested throughout the peak hour periods and any increase in traffic on this part of the Strategic Road Network (SRN) would be a concern to the HA.

Noted

• Reinstate reference to the promotion of public transport in Objective 8

The Council considers that promotion of public transport is encompassed within the overarching term “encouraging use of more sustainable forms of transport”. Promotion of public transport is included within the AAP’s supporting Transport Strategy (Objective 5)

• Agreed that road widening on the A21 is necessary to support later stages of the AAP and this is supported by regional policy

This is welcomed.

• Rewording of Policy BTC26 “Planning permission for …. is assured prior to occupation. Provision may be phased…”

Agreed. Policy BTC26 to change to: Planning permission for development will only be granted where the transport measures required by the proposed development (both on and off site) are either already in place or their provision is assured prior to occupation. Provision may be phased, relating to the phasing of development.

TTransport Strategy:

• The transport strategy fails to take potential impacts on the SRN into consideration. This must be fully assessed.

• There is concern that the transport strategy objectives are not consistent with National Policy, specifically Objective 2

Potential traffic impacts on the SRN should be identified in transport assessments, a requirement of AAP Policy BTC34. Transport Strategy Objective 2 is not intended to imply extensive new road building. Change Objective 2 to: To provide a transport network that supports the new development proposed in the AAP. Agreed.

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• A robust assessment of Park & Ride sites should

be carried out • A meeting to discuss the transport evidence base

to support the delivery of the LDF

Further discussion with the HA on the AAP and the emerging Core Strategy would be welcome

aDAAP103 Ray Hewitt 06/02/09 • Concerned about blight issues

The AAP represents a framework document. No formal blight exists.

• Does not believe that Bromley has the necessary infrastructure in place to service the proposals

The correct level of infrastructure requirements such as health and educational facilities are crucial to the success on the plan. Policy BTC32 regards developer contributions.

• Concerned about lack of demand for retail space given the current economic problems

It is anticipated that delivery of the AAP proposals will occur over a number of economic cycles

• Residents and property owners should take precedence over developers

Through the extensive AAP consultation, residents and existing landowners views have been taken into account

• Supports the improvements to Bromley North Village and redevelopment of Site A

Support welcomed

• Against a new leisure centre MyTime are keen to provide users with a more appropriate leisure facility that meets the needs of a wide range of ages.

• Does not support comparisons with other towns The local economy is important to the success of the borough it would be amiss of the Council not to provide the basis for continued success

DAAP104 Mr J Sercombe

09/02/09 • Believes that change is long overdue

Support welcomed

• Against references to tall buildings without indication of height

Heights of buildings will only emerge after detailed designs have been worked up at application stage. The purpose of the AAP is to set out the development principles and content (Table 5.1) and the design principles (Appendix 4) which set the framework for design work to be carried out.

• Concerned about traffic movements from additional parking and residential on Site G

Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP sets traffic targets that see no

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overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three. Traffic impacts of individual developments must be addressed through transport assessments, which must accompany planning applications. The amount of parking proposed at Site G has been determined at a level that balances the needs of town centre living, outer London accessibility and potential future retail parking demand. Where necessary, the CPZ will be extended to protect more local residents. Residents of new development will not be issued with parking permits for local roads.

DAAP105 London Fire Brigade

06/02/09 • The car park on Site C is a good location for a new fire station and is the most suitable option identified

A fire station fronting onto Tweedy Road in this location would present some difficult design problems in relation to the listed Town Hall buildings. Tweedy Road (A21) forms part of the TLRN and direct vehicular access onto this route would require approval from Transport for London and may not be forthcoming. Although direct access onto the A21 could be achieved in engineering terms for emergency vehicles only, careful consideration would be needed given the proximity to the Tweedy Road/East Street/Sherman Road signalised junction which is congested at peak periods. Such a proposal may also impact on pedestrians along the site frontage.

• Wished to see the promotion of the installation of domestic sprinklers in new residential properties

Currently sprinklers are not mandatory in domestic development, however it would be for the developer to assess whether enhanced fire precautions and property protection are viable.

• Prior to and during construction the LFEPA should be more involved with safety issues

It would be for the developer to undertake a risk assessment and involve the LFEPA in any transitional temporary arrangements for means of escape and fire safety during construction

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DAAP106 Ms Jacqueline Palmer

05/02/09 • Commented that parking provisions were inadequate

• Concerned with the amount of traffic and congestion causing nuisance

• Does not believe that the plans will maintain and

enhance the quality of residential environment

Parking proposals are seen as consistent with the overall approach to transport set out both in the AAP and the supporting Transport Strategy. The Transport Strategy sets out how parking will be managed in the town, both for new development and in the round (whether on or off street). A more detailed Parking Plan is to be developed. Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP’s supporting Transport Strategy proposes an approach that promotes a wide range of travel choices. The AAP sets traffic targets that see no overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three.

DAAP107 Resident Hayes Road BR2

• Against demolition of sound and viable buildings

It has been shown that the town needs to expand to take account of the growing catchment area and some demolition is therefore inevitable. Development will need to be managed in a controlled way to avoid impact on residents, workers and visitors a like. The town is a metropolitan centre that needs to attract visitors to help the local economy. Traffic modelling has shown what levels of traffic can be accommodated on the town’s road network in support of the proposed development. The AAP’s supporting Transport Strategy proposes an approach that promotes a wide range of travel choices. The AAP sets traffic targets that see no overall increase in traffic in Phases One and Two, and no more than a 3% increase in Phase Three.

• Concerned about the increase in traffic; that it will be detrimental to the environment and the quality of life for local residents

• Felt that the AAP seems to be balanced in favour

of non-residents and motorists

DAAP108 Lorna MacKenzie

01/02/09 • Against the development of flats at Site B.

Response relates to planning application

• Concerned about loss of shops on the High Street That is why the Council commission work on the AAP

DAAP109 R. Gann 27/01/09 • Against the development of tall buildings in the town centre

Height and design is controlled by the design principles set out in Appendix 4 of the AAP. These ensure that the scale and massing of proposed buildings will be assessed with particular regard for their impact on views and residential areas.

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• advantages of residential development having gardens and linked to retail units.

Noted

DAAP110 Catherine Evans Kent Association for the Blind

11/02/09 • all development in the town centre should be DDA compliant Including Bromley South Station

Agreed

• opposes shared spaces in that it contradicts the Disability Discrimination Act. Would like to see rotating cones , tactile paving and no railings at road junction.

The Council is aware of concerns about shared spaces on the part of groups representing people with visual impairments. The Council is also aware that DDA-related measures that benefit some groups may dis-benefit others and that a balanced view will need to be taken. It is therefore important that there is positive consultation about any such schemes.

DAAP111 Dick Groves Disability Voice Bromley

11/02/09 • concerned about lack of consultation Disability Voice have been included in all consultation on the AAP process including the Equality Assessment document. However it appears the DVB may have concerns regarding other highway schemes and lack of involvement – see below

• Major works have been undertaken with reference to DV.

Having spoken with Mr Groves at a recent presentation these works are clearly highway works that have been carried out either prior to and not part of the AAP process.

• Suggests a Mobility Forum is set up. Noted

DAAP112 Physical Disabilities & Sensory Impairment Partnership Groups

11/02/09 • Lift access to Bromley South Station is very important

• Better locations for disabled parking • Plan fails to identify clearly provision for those with

mobility problems given the older population in Bromley generally

• Need better input into any LBB policy work

Better accessibility at Bromley station is to be brought forward by Network Rail. New development will be expected to comply with the Council’s relevant standards on disabled parking. Other disabled parking within the town will be kept under review. New development will be expected to comply as appropriate with Building Regs requirements (Part M) to provide for people with mobility difficulties of whatever age. Noted.

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Bromley Town Centre Area Action Plan – Analysis of TfL’s Consultation Comments, Feb 2009

AAP Reference London Plan Policy TfL Representation LBB Comment

General 3C.2 It would have been helpful to present different development scenarios (taking account of phasing alongside the transport implications- this would have allowed a more robust assessment of infrastructure (and hence funding) requirements. As presented there appears to be only one development scenario alongside a set of transport improvements derived from the Transport Strategy.

Different development scenarios were considered at the earlier Preferred Options stage. This consultation document relates to the development strategy that the Council has adopted, going forward from that stage.

4.8.11 3C.14 Reference is made to promotion of trams or tram-trains. As the Council is aware, there has only been initial very high level consideration of route options for a potential future extension to Bromley. There are no plans for any extensions to Tramlink in the TfL Business Plan, although TfL is committed to including new proposals for extensions to the tram as part of a future bid to Government. The Network Rail South London Route Utilisation Strategy also refers to long-term potential for Tramlink extensions. The text correctly recognises that delivery would be beyond the timescales of the AAP.

Neither the AAP nor the supporting Transport Strategy has been developed on an assumption that tram services will be introduced that serve Bromley town centre during the plan period. However, the Council supports introduction of tram services after the tram period and wants that aspiration to inform the proposals in the AAP so that this is not precluded.

4.8.15 3C.17 Although targets for traffic levels are set, there is no guarantee that levels of non development traffic will remain unchanged as assumed in the modelling given travel demand growth associated with changes in the wider area beyond the boundary of the AAP. TfL would like to understand whether different assumptions of traffic growth have been sensitivity-tested and if so, what the implications are for the strategy. As a first priority, more attention should be paid to travel demand management measures and encouraging use of sustainable modes of transport. Only when this has been fully explored should mitigation and/or the provision of additional capacity be considered.

The modelling has assumed little or no change in non development traffic, as a worst case sensitivity test. However, the Transport Strategy proposes a range of measures that seek to place more emphasis on a wide range of means of travel, including the car. The “Ten-in-Ten” target and the proposal for a town-wide travel plan, promoting such travel choice are key parts of this. The expectation is therefore that non-development trips starting or finishing in the town centre may well reduce under this initiative. The central themes of the Transport Strategy reflect this.

BTC21 – Transport Schemes

3C.16 TfL supports policy BTC21 which is broadly in accordance with policy 3C.16 (Road scheme proposals) of the London Plan. However, some of the individual site proposals to increase parking capacity may conflict with the aims of policy BTC21.

Over the whole AAP period, there is only a limited net increase proposed in the amount of publicly available non-residential parking in the town centre, especially in comparison to the amount of new development floorspace proposed.

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BTC22 – Public Transport

3C.1, 3C.3, 3C.4

TfL notes and generally supports the list of improvements. Further discussions may be useful to clarify assumptions about timescales and funding for schemes listed in this policy and elsewhere in the document. TfL welcomes the commitment to retain bus stands at Bromley North and at Westmoreland Road. It would be helpful to state that additional land may be required within Bromley town centre to support future expansion of the bus network.

Support welcomed. It is not clear at present what amount of land TfL envisage may be required for further public transport improvements beyond what is already identified and safeguarded in the AAP.

BTC23 – Land safeguarded for transport schemes

3C.4 TfL supports the specific safeguarding for improvements at Bromley South and bus priority/highway improvements at Masons Hill (A21). The policy should also make transport 3C.4 reference to safeguarding of existing transport infrastructure including bus stands and interchange facilities in line with London Plan policy 3C.4.

Support welcomed. Wording to be added to Policy BTC23 to safeguard existing public transport infrastructure and assets: Planning permission will not be granted where development adversely affects existing public transport infrastructure unless such impacts are satisfactorily mitigated.

BTC24 – Walking and Cycling

3C.21; 3C.22 Annex 4

TfL welcomes the emphasis on walking and cycling although the policy wording could be more specific to Bromley town centre. Routes to schools may be a priority in the rest of the borough, but within the AAP area the emphasis should be on direct, attractive and secure links to connect key destinations and activity centres such as transport hubs to the main services and commercial areas, as well as residential areas beyond the AAP. The policy should make explicit a requirement for secure, accessible and preferably weatherproof cycle parking at all new developments, public transport interchanges and key destinations, including the application of minimum standards in line with TfL guidelines. Parking for motorcyclists should also be considered. The potential for a cycle hire scheme and requirements for additional publicly available cycle parking should be considered as part of the proposed town centre Travel Plan. It would be useful for the AAP to acknowledge that TfL is to implement a cycle hire scheme in central London (as set out in 'A Way To Go', Mayor of London, November 2008) and TfL welcomes further discussions on Bromley's proposals.

Noted. Routes to school are of importance for the town centre AAP because of the increased residential development and the need for good non-car access to schools outside the town centre. Much of these points on cycling and motorcycle parking, including a bike hire scheme, are dealt with in the supporting Transport Strategy.

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BTC25 – Parking 3C.23, 3C.24 Annex 4

TfL supports the intention to provide for all non-residential development in the form of publicly available parking. It would be helpful here to make reference to London Plan maximum car parking standards. Car parking standards in line with the London Plan will need to be applied to all new development (both residential and non-residential) in Bromley town centre even where spaces are made available to the public. The car parking policy should also address the needs of disabled motorists as well as considering requirements for drop-off/pick-up facilities for coaches and taxis at interchanges and hotels. The wording of the second paragraph could be clarified to read as follows: ‘The Council will seek a reduction of existing private non-residential parking provision through implementation will be required to contribute to this process and produce site specific Travel Plans to support the overall reduction.' Travel Plans should be produced in accordance with TfL’s guidance on Workplace Travel Planning and Residential Travel Planning (March 2008) and it would be helpful to include a reference to this guidance in the AAP. TfL supports the intention to extend the Controlled Parking Zones. It would be helpful to give explicit support for residential developments that provide reduced or where appropriate zero parking. Any Park and Ride scheme should take account of TfL’s guidelines on strategic park and ride in London.

Support for approach of publicly available parking welcomed. Coach parking and pick-up/set-down is addressed in the context of individual Opportunity Sites where hotel development is proposed. The Transport Strategy refers (para 7.47) to the need to keep under review the potential need for further coach facilities in the town. Support for CPZ extensions welcomed. For the Opportunity Sites, the AAP identifies parking provision at a level that seeks to balance aspirations for low car, town centre living with the town’s outer London location and needs. Aspirations for low car, town centre living with the town’s outer London location and needs in accordance with adopted local and regional policy.

BTC26 – Phasing of Transport Improvements

3C.2, 6A.4, 6A.5

TfL supports the requirement for transport measures to be provided to serve developments and to provide mitigation against any impacts. It would be appropriate to state here that planning obligations and a potential transport tariff or Community Infrastructure Levy will be used to secure contributions where appropriate.

Support welcomed. The key points in this policy are intended to relate to timing and impacts. Policy BTC32 relates to developer contributions and, as stated in 6.5.5, the Council will draw up further guidance on planning obligations as part of a Borough-wide SPD that will set out such mechanisms in more detail.

BTC27 – Traffic Management

3C.17 TfL supports the inclusion of targets for restraining traffic growth although to be consistent with policy 3C.17 of the London Plan the target for the whole period (including phase 3) should be zero growth.

For Phases 1 and 2 of the AAP, it is proposed that the London Plan target of zero growth be met. Phase 3 however includes a significant increase in retail development that may well lead to increases in traffic levels over and above a wide range of measures that will promote other means of travel. It is therefore proposed that the traffic target for AAP Phase 3 allows for a modest increase in traffic growth, recognising particularly the outer London characteristics of the town and its wide catchment area that is not all well served by other means of travel.

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BTC28 – Car Clubs

3C.2 TfL welcomes the inclusion of a policy on car clubs although it could be more clearly worded to ensure that all developments within the AAP area make appropriate Provision for car clubs. The phrase 'to allow for' could be open to interpretation. In some cases physical provision to accommodate car club facilities may be required. For other sites a contribution towards a car club co-ordinated through the town centre Travel Plan would be appropriate and for residential developments subsidized membership should be considered. Although there are references to a proposed town centre Travel Plan and requirements for site specific Travel Plans in the text (and in policy BTC 34), policy BTC 28 could be expanded and renamed to form the basis of a policy which would formalise a requirement for site specific Travel Plans to be developed in the context of the town centre wide Travel Plan. Car clubs would form one important element in this approach.

Agreed. Developer contributions to measures such as car clubs are considered to be encompassed in the 11th bullet point of Policy BTC32 (delivery of Travel Plans and associated transport measures). At this stage, the Council does not consider it appropriate to single out car clubs as a specific measure where all development should contribute; the wording of the policy offers desirable flexibility in this regard. Requirements for travel plans are included in Policy BTC34. The interrelationship between car clubs and travel plans is also envisaged in the Transport Strategy.

BTC29 – Freight 3C.25 TfL welcomes the requirements for Delivery and Servicing Plans and encouragement for existing town centre uses. It would be appropriate to develop a co-ordinated town centre wide servicing strategy through the proposed Travel Plan process. This could consider the viability of establishing a consolidation centre for deliveries as well as measures to minimise the impact of servicing activity. Reference should also be made to requirements for Construction Logistics Plans for new developments to ensure that the impacts of construction transport can be addressed. Again there may be scope for co-ordination through the town centre Travel Plan.

TfL’s suggested approach echoes that already included in the Transport Strategy.

BTC30 – Phasing 3C.2 TfL welcomes the intention to phase development with the provision of infrastructure. However, table 6.1 could be made more consistent by isolating the site specific infrastructure (or service) improvements required to enable a site to come forward from the general requirements that should apply to all sites including Travel Plans and contributions to town centre wide initiatives such as car clubs, provision of information and a potential cycle hire scheme.

This information is set out in Table 6.5, where site-specific and general requirements are differentiated. Site-specific requirements are also set out, site by site, in Section 5.

OSA – Bromley North Station

3C.23, 3C24 Given the site's location adjacent to Bromley North station and close to all town centre facilities this would be an ideal location for a largely car free residential development with parking provided only for essential needs such as a disabled parking, car club vehicles or servicing. TfL supports the intention to restrict residents' ability to buy parking permits.

Noted. For the Opportunity Sites, the AAP identifies parking provision at a level that seeks to balance aspirations for low car, town centre living with the town’s outer London location and needs.

OSB – Corner of Tweedy Road/London Road

3C.23, 3C.24 TfL supports the intention to restrict residents' ability to buy parking permits. Support welcomed

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OSG – West of the High Street

3C.23, 3C.24 Given the site's highly accessible location there may be scope for further reductions in residential parking and the suggested figure should be expressed as a maximum. The provision of 600 public car parking spaces should preferably not add to overall town centre parking capacity and would in any case need to be justified on the basis of an identified shortage and the ability of the road network to absorb car trips to the site. Car parking provision (both residential and public) should be subject to the outcomes of the proposed Town Centre Parking Plan (paragraph 4.8.38) and Transport Assessment for the site and TfL suggests that the text should be expanded to clarify this point.

For the Opportunity Sites, the AAP identifies parking provision at a level that seeks to balance aspirations for low car, town centre living with the town’s outer London location and needs. Provision of 600 public car parking spaces in support of the retail element of the development recognises the significant increase in retail floorspace that this development will provide. Policy BTC34 is clear that a Transport Assessment will be required, that takes into account TfL’s best practice.

OSJ – Bromley South Station and environs

3C.3, 3C.4 TfL supports in principle proposed improvements around Bromley South station and the proposed safeguarding and looks forward to working with the Council and other stakeholders to take this forward. Any bids for funding would be subject to the normal processes for securing funds under the appropriate programmes.

Support welcomed.

OSK – Westmoreland Road car park

3C.23, 3C.24 Any re-provision of public car parking should preferably not add to overall town centre parking capacity and would need to be justified on the basis of an identified shortage and the ability of the road network to absorb car trips to the (new) site. As indicated above re Policy OSG, any car parking provision should be subject to the outcomes of the proposed Town Centre Parking Plan (paragraph 4.8.38) and Transport Assessment for the site. TfL supports the intention to restrict residents' ability to buy parking permits.

For the Opportunity Sites, the AAP identifies parking provision at a level that seeks to balance aspirations for low car, town centre living with the town’s outer London location and needs. In this case, the overall parking provision on the site is likely to be lower than at present.

OSL – DHSS building and adjoining Bromley Christian Centre

3C.4, 3C.23, 3C.24

TfL welcomes the safeguarding for future public transport priority measures and supports the intention to restrict residents' ability to buy parking permits.

Noted.

6.4.7 – 6.4.9 3C.3, 3C.23 TfL generally supports the improvements listed here subject to further discussions on timescales, funding and deliverability. It is hoped that the Travel Plan and Car Club would be fully established in phase 1 and then further strengthened and implemented throughout phases 2 and 3. With reference to the parking impacts identified in the following tables (6.2 - 6.4), the objective should be to ensure that there is no net addition to the total parking stock and that demand management measures are considered first as an alternative to any new provision.

The town-wide travel plan is a key element in delivering the Council’s “Ten-in-Ten” target and is therefore an essential feature of Phase 1 of the AAP. The envisaged roll-out of Car Club operation will work in support of this. Effective use of existing transport assets and promoting travel choice are two key themes of the supporting Transport Strategy. Across the AAP period, a net increase in non-residential parking is envisaged, but this recognises the significant increase in retail floorspace in the town that is being proposed.

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BTC31 Funding/ BTC32 Developer Contributions

3C.3, 3C.23, 6A.4, 6A.5

TfL supports the overall approach to funding and developer contributions, in particular the provision of public transport improvements, enhancement of pedestrian and cycle routes and delivery of Travel Plan measures. However, the concept of 'commuted parking payments' is outlawed in 'PPG 13: Transport' and care should therefore be taken in the use of this term and concept, to avoid undermining use of more sustainable modes of transport. The use of a single funding pot either through a transport tariff or the Community Infrastructure Levy (ClL) is supported in principle although it will be important to achieve consensus on a prioritised list of generic improvements that could be funded through this approach. Site specific contributions will still be required where necessary to support the proposed level of development. Some of the assumptions about funding (including sources) shown in table 6.5 may need to be revised as the AAP is further developed and implemented. Where TfL is identified as a potential source, this will be subject to the normal processes for securing funds under the appropriate funding programmes. The balance between different scheme headings may also need further discussion - in particular there is a large allocation to improved parking being funded through section 106 contributions which may not be appropriate in sustainability terms.

Support welcomed. Reference in BTC32 to commuted payments to be changed. Relevant bullet point now to read: • Contributions towards any off-site parking provision

and extension of CPZ. The Council recognises the need to collaborate with TfL: and other stakeholders to deliver the relevant funding mechanisms and to keep them under review against the AAP’s delivery objectives. The AAP acknowledges that Section 106 contributions will be required in addition to tariff contributions. The majority of funding envisaged for parking is aimed at improving quality, not increasing quantity. The Council recognises that some new parking stock will be needed across the AAP period, but just 12% of the parking element of the AAP transport projects has been identified for that purpose.

BTC34 – Planning applications

3C.2 TfL supports the requirement for Transport Assessments to be submitted in accordance with TfL's best practice guidance document. The reference to Travel Plans should state that these should take account of TfL guidance on workplace and residential travel plans and be developed in the context of the proposed town centre Travel Plan (see comment on policy BTC28).

Support welcomed. Change proposed to last bullet point of Policy BTC34: • Undertake to produce, monitor and maintain a Travel

Plan in line with appropriate TfL guidance and coordinated with the town-wide Travel Plan.

BTC35 – Further guidance

6A.4, 6A.5 TfL looks forward to working closely with the Council and other stakeholders in developing the proposed guidance on section 106/CIL/transport tariff contributions.

This is welcomed.


APPENDIX 5.1

CONSULTATION DRAFT AAP (NOVEMBER 2008- JANUARY 2009): REPORT TO COMMITTEE

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Report No. DRR09/00031


PART 1 - PUBLIC

Agenda Item No.

Decision Maker: Development Control Committee

Executive Date: 30th March 2009

Decision Type: Non-Urgent Executive Key

Title: AREA ACTION PLAN FOR BROMLEY TOWN CENTRE - DRAFT PRE-SUBMISSION DOCUMENT

Contact Officer: Bob McQuillan, Chief Planner Tel: 020 8313 4441, email [email protected] Rita Westlotorn, Head of Town Centre Planning Projects , Tel: 020 8313 4582 E-mail: [email protected] jonathan macdonald, asst director of renewal tel: 020 8313 4847 email: jonathan.macdonald @bromley.gov.uk

Chief Officer: Director of Renewal & Recreation

Ward: Bromley Town


1.1 There is still significant development interest within the town centre, however, the potential for future development will be affected by a range of interlinked factors including transport network capacity, environmental considerations and the need to protect and enhance the towns built and natural heritage. As a result there is a need to actively manage change, rather than to merely react to it.

1.2 Following three years of extensive consultation the stage has now been reached for finalising

the Draft Bromley Town Centre pre-submission Area Action Plan. The Draft AAP underwent a twelve week consultation period between 17th November 2008 and 6th February 2009. In total 112 responses were received, some in support, some suggesting textual changes either to policy or the accompanying text, some wanting little or no change to the town centre and others raising issues that require further consideration prior to finalising the pre-submission AAP. These key considerations are reported in the comments overleaf.

1.3 The Draft pre-submission AAP consultation document contains the planning policy framework

required to guide and promote sustainable development in the town centre ensuring the town evolves into a more vibrant centre and retains its competitive position any textual changes from the consultation Draft AAP are denoted by the text being underlined. A copy of the Draft

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pre-submission AAP and copies of responses received will also be placed in the Members Room.

1.4 Prior to submission to the Secretary of State the Draft pre-submission AAP will undergo further formal consultation. Representations received will form the basis of the examination by an independent Planning Inspector early next year. In order to satisfy the Inspector the Draft AAP must pass a test of ‘soundness’. The plan must be considered to be justified, effective and consistent with national policy. Depending on the timetable of the Planning Inspectorate final Adoption of the Plan would be likely in spring 2010.

________________________________________________________________________________


2.1 Members of Development Control Committee to consider the Draft Pre-Submission AAP and refer their comments to the Executive for consideration.

2.2. The Executive considers the comments from the Development Control Committee [and Executive and Resources PDS} and approves the Draft Pre- Submission AAP to Full Council

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Corporate Policy 1. Policy Status: New policy. The AAP will be the Council’s first Development Plan Document

(DPD) under the new planning system, known as the Local Development Framework (LDF). As the AAP will constitute a DPD it would therefore be subject to independent examination in public as it will introduce new policies. The AAP sets out the vision for the future with objectives, policies and proposals to achieve the vision and provides a spatial framework to guide future development and change.

The work undertaken to date is based on independent and objective professional analysis by experts in the field and will be tested by an Independent Inspector at an Examination in Public (EiP). Proposals for the town centre will have to take account of government policy, especially PPS6 – Planning for Town Centres, as well as other relevant policies. Prior to the adoption of the AAP any new development proposal sites within the town centre that are not currently contained in the adopted UDP are likely to be considered as ‘departures’ from the Plan and may therefore be referable to the Secretary of State.

Improving the Borough’s town centres is one of the Council’s main priorities and given that Bromley Town Centre serves a wide catchment area and offers high levels of employment it was considered crucial that, to ensure future prosperity in face of increasing competition, an action plan should be put in place.

2. BBB Priority: Vibrant Thriving Town Centres. ________________________________________________________________________________ Financial 1. Cost of proposal: N/A The sites identified in the draft AAP present opportunities for private

sector investment of the type that resulted in the development of The Glades. While the Council may incur expenditure in assisting in site assembly it would only do so if it is assured that those costs will ultimately be met by the developer. There is also an opportunity for the Council to obtain capital receipts for the sale of its own land. The Council owns 6 of the 12 opportunity sites

2. Ongoing costs: N/A. 3. Budget head/performance centre: R & R 4. Total current budget for this head: £n/a 5. Source of funding: Consultancy costs have been met from the Planning Development Grant,

Town Centre Improvement Fund and LPSA 1 reward funds and are within the approved budget. ________________________________________________________________________________ Staff 1. Number of staff (current and additional): n/a 2. If from existing staff resources, number of staff hours: n/a ________________________________________________________________________________ Legal 1. Legal Requirement: Statutory requirement. The Town and Country Planning (Local

Development) (England) (Amendment) Regulations 2008 amend the 2004 regulations and prescribe the timescale and process for public consultation. It is an Executive function to approve the draft AAP for consultation. Hoverer by virtue of regulation 4 of the Local Authorities (Functions and Responsibilities) (England) Regulations 2000 as amended approval of the AAP

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for submission to the secretary of state at the close of the consultation process is a matter for full council on the recommendation of the Executive

2. Call-in: Call-in is not applicable. ________________________________________________________________________________ Customer Impact 1. Estimated number of users/beneficiaries (current and projected): borough -wide ________________________________________________________________________________ Ward Councillor Views 1. Have Ward Councillors been asked for comments? Yes. 2. Summary of Ward Councillors comments: ward councillors have been fully engaged in the

consultation process

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3. COMMENTARY

3.1 The objective of the AAP is to create an attractive and successful town centre which will confirm Bromley’s status as one of London’s main metropolitan centres and enhance the quality of life and opportunities for the borough’s residents and businesses. It is essential to strike an acceptable balance between residential and other activities normally found within a town centre creating sustainable communities and a balance of uses. The need to accommodate additional housing within the town is consistent with the increasing emphasis being placed on housing by the government and the Mayor of London not only to meet demand but to also encourage the evening economy and help to prevent anti-social behaviour. A residential element within mixed use development is often also necessary to help to fund other uses that by themselves may not be commercially viable.

3.2 It will be important in order for successful developments to be brought forward and to realise the vision in the Draft AAP that the final document is fully supported by Members so that renewal and economic objectives for the town centre can be fully realised. It is equally important that the Council is seen to be ensuring the long-tern sustainability of the town and accommodating future growth requirements in accordance with national and strategic planning policy guidance providing strategic leadership to potential investors when considering how and where new development can be achieved.

3.3 The scale and mix of the proposed development is considered compatible with the town’s catchment area and role within the regional hierarchy. It is also essential that any other potential projects within the town are not considered in isolation and that they are viewed within the context of the overall vision for the future as detailed in the Draft Pre-Submission AAP.

3.4 The current adopted UDP polices appertaining, for example, to the Conservation Area, its boundary, Listed buildings and Affordable Housing, have not been reviewed as part of the process and they therefore remain the overriding policies regarding such issues. It will be important, therefore, that developers and other interested parties, consider both the policy direction in the AAP as well as relevant policies in the adopted local plan and regional polices in the London Plan. A Transport Strategy has been written to support the AAP. It also provides a framework for wider transport interventions in the town

3.5 The Sustainability Appraisal (SA) assesses the likely social, economic and environmental effects of the Draft Pre-Submission AAP. The SA has been an integral part of the preparation of the Draft Pre-Submission AAP to ensure that necessary mitigation measures are incorporated to minimise the impacts of proposals. The findings of the SA indicates that overall the proposals set out in the Draft Pre-Submission AAP will have positive social and economic benefits and that the environmental impacts can be mitigated through appropriate measures such as the implementation of a comprehensive transport strategy, protection of the historic and natural environment and public realm improvements

3.6 The Bromley Town Centre Area Action Plan has been prepared ahead of the Core Strategy because of the urgency of regenerating the town centre and the need for a planning framework to be in place to determine significant planning proposals which are being progressed. The Plan has the potential to deliver a significant element of the Borough’s housing requirement at an early stage whilst at the same time protecting and enhancing Bromley’s status as a metropolitan centre.

3.7 Both the Greater London Authority (GLA) and the Government Office for London (GoL) have shown support for the approach being taken by the Council. Although the AAP is running ahead of the Core Strategy GoL believe there is a strong argument to be made regarding the fact that the AAP is required on urgency grounds in order to facilitate growth

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and address development proposals comprehensively. GoL have subsequently advised that the Council should ensure sufficient time between the end of the formal six week consultation on the Pre-submission Draft AAP and the submission of the Plan to the Secretary of State to allow for responses to be fully considered before the plan is finalised. Whilst they have suggested a 3 month period this would largely depend on the type and contents of any formal objections received and the nature of any changes to be considered. It is of course important to have the correct evidence base to ensure the Plan is justifiable to the Inspector and until the formal pre-examination meeting it will not be known what issues, if any, the Inspector will want to investigate in more depth.

3.8 Depending on the number and substance of representations outstanding at the end of the 6

week formal consultation on the pre-submission draft, consideration will be given to the time period needed to respond to the comments. It will be important to liaise with GoL at this stage. The Inspector at the pre-examination meeting will need to be satisfied that any outstanding issues have been adequately addressed.

3.9 The Council’s approach has been to promote an enhanced mix of retail, leisure, employment, residential and community uses in the town centre, both to improve the attraction of the town centre and to support the quality of life of the local community. A vibrant town centre providing a range of quality services and facilities will generate a virtuous circle by making it a more attractive location for residential and employment uses. In this way the AAP provides opportunities to link new retail development to the wider community benefits such as the provision of improved health facilities, highway and transportation improvements as well as helping towards meeting housing requirements.

3.10 The public realm in some parts of the town centre is in poor condition which can detract from the environment and to some extent the historic buildings especially in the Conservation Area. The AAP recognises that the public realm, as well as the outdoor space available for public use, has an important role to play in both providing the setting for the town centre’s historic buildings as well as creating spaces that are welcoming and attractive in their own right.

3.11 The 2004 Retail Capacity Study is currently being updated. The results of this study are being finalised and comparisons also are being made with the 2004 study. As part of this study a householder survey has already been carried out within the town centre’s catchment area. This area is divided into ten zones reaching from Lewisham in the north to Sevenoaks in the south and from Warlingham in the west to Willmington to the east. Within this catchment area there are over one million residents. Based on the 1200 responses the survey confirms that Bromley Town Centre is still popular with shoppers but whilst they have little or no comment on the ambience or environment of the town what they would really prefer is more diversity of choice, especially a new department store and as expected Bluewater is the location of choice for cinema visits.

3.12 Bromley has slipped down the ranking, now 33rd out of 2000 centres, a drop of 4 places. Croydon is ranked 24th up seven places over the same period (2008) (Venuescore ranking – which is the industry standard). There has also been a decline in retailer requirements which coincides with the economic downturn but Bromley’s score in terms of requirements has fallen sharper than other like centres. This may coincide with the slippage in ranking that indicates retailers and investors are looking at competing centres which are offering a better quality of choice instead. This shows that BTC still needs to remain competitive in terms of retailing and this is particularly important in the current economic climate.

3.13 Although the broader economic risk has changed since consultation on the AAP commenced, in order to bring forward the comprehensive development of Bromley Town

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Centre, the AAP is phased over 15 years which may cover several economic cycles, as noted in paragraphs 3.9 to 3.12 above. This recession is not deemed to be a material risk.

4 Representations

4.1 It is important that barriers to implementing necessary growth and development options are recognised and considered at this stage in order to alleviate problems that may hinder change at a later date. Throughout the AAP process the Council has sought to explain the reasons for the plan and has undertaken extensive consultation, since 2005, in order to understand public views. Site allocations and boundaries have been amended as the Plan progressed through each stage in response to representations received

4.2 The Draft Pre-Submission AAP has been prepared following wide ranging consultation with key partners, land owners, developers as well as the public on the Preferred Options (January 2006), Revised Preferred Options (October 2007) and the Draft AAP (November 2008). The Draft Pre-Submission AAP has taken into account the responses to all consultation exercises. Each stage of the process has therefore informed the next.

4.3 For Members information Appendix 1 outlines the extent of the consultation undertaken during the recent Draft AAP consultation exercise.

4.4 Some of the responses to the consultation have again raised questions on some Opportunity Sites and Members will need to consider the recommendations below prior to the Plan being finalised for consideration by the Council on 27th April. Some representations have also questioned the matter of blight, however, it is considered premature at this stage of the process to be considering this.

4.5 Both the Bromley Civic Society and Friends of Bromley Town Parks & Gardens have raised similar issues with regards the impact of any re-development on the Opportunity Sites and the protection of the built heritage and public open spaces. These concerns have also been raised by a number of local residents and amenity groups, indeed this and previous consultation revealed that safeguarding and improving the town’s historic assets was very important and was the most important issue for many town centre residents. The AAP recognises that whilst the town centre has a rich heritage reflected in parts of its built environment, there are other areas that need re-defining in order to meet, specifically, modern retailing requirements if the town is to be successful in terms of the local economy in the future.

4.6 Many responses were made with regard to planning application that is the subject of Appeal for Site B: Tweedy Road and the recent planning application for Site L: former DHSS building which has been withdrawn by the applicants.

4.7 The one site that elicited the most replies (approximately 26) was Site A: Bromley North. Whilst it is important to create a high quality gateway into the town centre, encouraging access to the town and providing a range of uses and facilities, appropriate to this well-used transport interchange the scale of development on this site was increased from 250 to around 400 residential units following receipt of representations from Network Rail and a land owner during the last round of consultation. It was considered that the proposed change was acceptable as an indicative number of residential units in order to maximise development opportunities and deliver transport improvements inline with London Plan policy. One of the principal objectives of the recent consultation exercise was, however, to test public reaction to the proposed changes to the plan prior to the finalisation of the pre-submission document and any increase was strongly opposed.

4.8 The Council’s Housing Division have commented that a mix of housing choices in the town centre would ensure a mix of affordable units and provide affordable housing for people with

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physical disabilities, sensory impairments and learning disabilities as well as elderly residents and would welcome residential planning applications that contribute towards the providing larger family units for social rent. The GLA have also stated that all new developments should be built to Lifetime Homes standards and Development proposals should accord with the Density Matrix in the London Plan (Table 3A.2). However whilst the matter of building all units to Lifetime Homes standards is made clear in the text it is also important that when looking at density levels site characteristics and the surrounding character of the town centre and adjoining residential areas are taken into account.

4.9 The schedule of responses to the Draft AAP is attached as Appendix 2. This schedule précis the comments received and the Council’s response.

4.10 The table below sets out the further recommended changes which need to be considered and agreed before the AAP can progress; the changes or recommendations are shown in bold. If no further changes are suggested the development options /or site boundary for the other Opportunity Sites will remain as set out in the Draft AAP.

Site Comment Site A: Bromley North The scale of development on this site was increased from 250 to

around 400 residential units following receipt of representations from Network Rail and a land owner during the last round of consultation. It was considered that the proposed change was acceptable as an indicative number of residential units in order to maximise development opportunities and deliver transport improvements inline with London Plan policy. One of the principal objectives of the consultation exercise was, however, to test public reaction to the proposed changes to the plan prior to the finalisation of the pre-submission document. Representations have been received from both Network Rail and Lennon Planning, on behalf of Linden Homes, supporting the increased density levels and development opportunity to bring forward a comprehensive scheme on a phased basis. However the Council also need to be cognisant of the level of concerns raised by local residents regarding the potential impacts of the increase in the number of residential units, density of the development and the height of any development as shown in the developments options/policy in the Draft AAP. Sites identified in the AAP need to be deliverable. This includes ensuring development viability and receiving planning approval, and there would clearly be a need for further assessment and careful masterplanning to develop an acceptable design for the site which would deliver the benefits sought by the AAP in terms of improvements to the station and transport facilities. At this stage however, no detailed masterplanning has been undertaken to demonstrate that an appropriate form of development can be achieved at the higher density proposed in the revised Draft AAP. It was considered appropriate to re-visit the quantum of residential proposed especially given the two storey suburban housing abutting the site. Whilst the town centre’s spatial characteristics provide constraints and opportunities it is also important to continue to provide the local community with its sense of place. The appropriate scale of development on this site will be influenced by its mixed use nature, scale and the local context, reinforcing local distinctiveness, as well as in securing a high quality environment. These are matters which would be fully addressed at the planning application stage and it will

9

be important that any development proposals demonstrate how the design complements the existing area and the opportunities available for improving the character and quality of the local context. The Council is committed to making the best use of previously developed land to promote local area regeneration and deliver wider benefits and public transport improvements are central to the vision set out in the AAP. However, in response to the specific issues raised in responses to the Draft AAP and in the absence of a justification for higher density development and how these would be mitigated it is recommended that the number of residential units is amended to an indicative figure of 250 units as previously shown in the Revised Preferred Options. The Draft AAP states that the number of units should be in general conformity with the AAP and the developer will be required to demonstrate that the proposed development will not result in unacceptable impacts.

Site B: Tweedy Road The numbers of residential units were reduced to 70 in the Revised Preferred Options. In light of the outstanding appeal and the Inspectors site visit which took place on 3rd March, it is recommended to await the Inspectors decision before recommending any further changes to the development options for the site. However, development will not be judged purely on an indicative capacity and the revised AAP makes it clear that a sensitive and high quality design is essential to minimise the impact of development on the setting of the adjacent listed buildings.

Site C: Town Halls Representations have been received from both Cathedral and the London Fire Brigade. Whilst Cathedral would wish to see the inclusion of residential to assist viability the London Fire Brigade have requested that the development of a new fire station becomes part of a comprehensive mixed use development for Site C and include the existing fire station site within the site boundary. The development of the fire station is likely to be detrimental to the setting of the listed Town hall buildings and is likely to have an adverse impact on the character and appearance of the Bromley Town Centre conservation area. If the development of a new fire station is inappropriate there is no purpose in including the existing fire station within the site. Tweedy Road (A21) forms part of the TLRN and direct vehicular access onto this route would require approval from Transport for London which may not be forthcoming. However, in light of the potential for a realistic, viable scheme coming forward it is recommended that Members agree that allowance should be made for small scale residential development to deliver a viable mixed use development for the Site. Office uses would be a requirement of any future mixed use development in order to safeguard future employment opportunities.

Site K: Westmoreland Road car park

Given the agreement to proceed with Cathedral for a scheme to provide a multiplex cinema, residential units and an hotel, subject to planning permission, it may be appropriate as an acceptable element of any future mixed use cinema led development to include either wholly residential units or a mix of residential and hotel use in the relevant policy and to reduce the number of residential units.

Site L: former DHSS building

AtisReal, on behalf of Land Securities Trillium, has objected to the boundary extension and the inclusion of the safeguarding line for highway improvements. The company submitted a planning application based on the site identified in the Revised Preferred Options but this has been withdrawn by the applicants. The site in

10

the draft AAP was extended to include the Bromley Christian Centre The former DHSS building contains unoccupied office space. The recently received in draft (January 2009) ‘Economic Development & Employment Land Study’, which was commissioned to underpin the Local Development Framework, has highlighted the importance of reinforcing the role of the office sector and the quality of accommodation in town centres. It is therefore considered appropriate to include within the development options for Site L the requirement for an appropriate level of replacement office space as part of the mixed use development. Potential developers would be required to demonstrate why the inclusion of replacement office floorspace was not financially unviable.

4.11 The following table tracks changes to residential units proposed in the AAP. Developers may still press for further increases but it would be for them to demonstrate that such increases are appropriate and sustainable. If the suggestions detailed above are agreed the indicative housing numbers for the town centre will reduce from that shown in the Draft AAP from around 2000 to around 1800.

Opportunity Site Draft AAP Pre-submission Draft AAP Site A: Bromley North 400 250 Site B: Tweedy Road 70 70 – subject to Inspectors decision Site C: Town Halls/South Street car park - 20 Site F: Civic Centre 20 20 Site G: west of High Street 1180 1180 Site K: Westmoreland car park 270 200 Site L: Former DHSS building 40 40 Site P: Sainsbury, West Street 20 20 Total (around) 2000 1800

Non-Applicable Sections: PERSONNEL IMPLICATIONS


UDP adopted 2006 PPS6 ODPM March 2005 Government consultation on revision to PPS6 July 2008 Revised Preferred Options Document October 2007 Draft AAP November 2008

1

APPENDIX 1

Consultation of the Draft AAP November 2008 to February 2009

DATE

MEDIUM DISTRIBUTION

11 November

News Release Local media and LBB website Average 4,500 hits everyday `

12 November

Borough Briefing – page in News Shopper Plus posters around borough Public Notice in News Shopper

98,356 Average net circulation 400

13 November

Bromley Borough News local paper article 33,000

17 November

Written Consultation commenced

In total: 8000 leaflets printed and either hand distributed to local residential properties; included with letters – see below or handed out at meetings

Letters/Documents – Statutory Consultees Letters/leaflet – other consultees All borough libraries (3 of each documents for view or loan) Planning/main receptions Email notification

80 700 48 2 105

bromley.gov.uk Home page visual plus supporting documents published

Internet availability`

Onebromley – intranet homepage All Staff 18 November

Presentation/Leaflets 120 LBB Managers

19 November

News Shopper local paper article 98,356 Average net circulation

20 November

UPDATE – Residents Association & Community groups newsletter (including Members and media)

Direct Mail 400 Leaflets and news item

21 November

Display at South London Business briefing

22 November

Residents Association Annual Planning seminar – presentation and leaflets

130

27 November

Stakeholder briefing Presentation and leaflets

140 invited

2 December

Presentation to Community Safety Panel

6 December

In Touch – newsletter for staff and contractors

3000 approx

December Bromley Town Talk distributed with leaflet 600 business 14 January

NewsShopper article giving closing date for consultation

98,356 Average net circulation

2

21 January

Council’s annual public meeting – AAP questions raised and answered

70 residents, mainly Reps for local groups

22 January

Minutes for about published on Homepage of website

Average 4,500 hits everyday

23 January

Presentation to Learning Disabilities Group

9 February Presentation to Physical & Sensory Impairment Partnership

9 February Presentation to the Health Social Care and Housing Partnership Board


APPENDIX 6

PROPOSED SUBMISSION AAP: INVITATION FOR REPRESENTATIONS ON SOUNDNESS AND LEGAL COMPLIANCE

8 JUNE – 17 JULY 2009

The Proposed Submission AAP was published on the 8th of June and made available for public

viewing at the Council offices, on the Council website, and through written correspondence to over a thousand consultees. CD’s containing all the relevant documents were also published and distributed to specific consultees. Representation forms with comprehensive guidelines on the Tests of Soundness were made available along with the following supporting documents.

i. Sustainability Appraisal ii. Equalities Impact Assessment iii. Updated Retail Capacity Assessment iv. Transport Strategy v. Strategic Flood Risk Assessment vi. Statement of Consultation vii. Evidence Baseline Report viii. A letter of Appropriate Assessment provided by Natural England

DATE

MEDIUM DISTRIBUTION

3 June

News Release

Local media and LBB website Average 4,500 hits everyday

3 June

Statutory Public Notice in News Shopper X 2 weeks


8 June

AAP Published Letters/Documents – Hard Copies and CDs Letters Documents on a CD – Specific Consultees Letters – other consultees All borough libraries (1 of each documents for view or loan plus CDs) Planning/main receptions Email notification CDs Distributed during the exercise

6 35 751 18 2 215 50

bromley.gov.uk Home page visual plus all supporting documents published

Internet availability

Onebromley – intranet homepage

All Staff

10 June

News Shopper local paper article


L O N D O N B O R O U G H O F B R OM L E Y S T A T E M E N T O F C O N S U L T A T I O N | 3 1

20 June

UPDATE – Residents Association & Community groups newsletter (including Members and media)

Direct Mail News item

* Includes hits on all pages of the web site

Listed below is a breakdown of organisations invited to submit representations on the Proposed Submission AAP based on the ‘Tests of Soundness’. Additionally, over 230 private individuals were also consulted during the exercise. Specific Consultees

Affinity Homes Group Assembly Member for Bexley & Bromley, GLA

British Gas Properties British Telecommunications (Planning Section) Bromley Adult Education College Bromley Association for People with Disabilities Bromley Community Health Council Bromley Family Health Services Authority Bromley Hospitals NHS Trust Bromley MyTime Bromley Primary Care Trust BT plc Civil Aviation Authority Coal Authority

Commercial Property, Network Rail Commission for Architecture and the Built Environment E.ON UK Plc EDF Energy, Major Business, Scanning and Indexing English Heritage

Environment Agency Freight Transport Association Government Office for London

Greater London Authority Highways Agency Homes and Communities Agency Kent Route (Stations), Network Rail LIFT Project, (NHS Local Improvement Finance Trust) Bassetts House Mayor of London

Member of Parliament for Bromley and Chiselhurst

Natural England, London Region Planning Inspectorate

Telereal (on behalf of BT) Thames Water Property Services Transco, South East London Transport for London


Other Consultation Bodies

A2 Dominion Accent South Acert Acorn, Land & Strategic Property Division ACX Express Affinity Sutton, Level 6 Age Concern Bromley Air Transport Users Council Airports UK Limited Albyfield Residents' Association Aldersmead Road Residents' Association Alan Hill & Co

Alexandra Residents' Association Anchor Housing Association Andace Park Residents' Association Anerley Association APCA APCA Core Panel Asda Stores Ltd Asprey Homes Atisreal (on behalf of Land Securities Trillium) Atisreal Ltd Babbacombe Road Residents Association Badgers Mount Residents' Association Baker Tilley Banner Homes Barnmead (Cator Estate) Residents' Association Ltd Barrett Haskins Designs Ltd Barton Willmore Planning Partnership Baxter Clark & Paul Beadon Road Residents' Association Beaver Housing Association Beckenham Civic Society Beckenham Constituency Conservative Association Beckenham Constitutional Club Ltd Beckenham Liberal Democrats Beckenham Place Park Residents' Association Beckenham Village Residents' Association Beechwood Residents' Association Bellway Homes Bennett Urban Planning Berkeley College Homes Limited Berkeley Homes (Eastern) Ltd Berwood Homes Bickley Park Residents' Association Biggin Hill & Darwin Branches of the Labour Party


Biggin Hill & District Residents' Association Biggin Hill Airport Ltd Biggin Hill News Ltd Biggin Hill Partnership

Biggin Hill Society Bilton plc Blenheim-Arpley Residents Association Steering Group Broad Oaks Estate Association Bromley & Chislehurst Labour Party Bromley & District Estate Agents Association Bromley & North West Kent Friends of the Earth Bromley & West Kent Archaeological Group Bromley Advocacy Project - Service User Involvement Team (SUITe) Bromley Allotment & Leisure Gardens Federation Bromley Asian Cultural Association Bromley Autistic Trust Bromley Borough Local History Society Bromley Borough Roads Action Group Bromley Children & Families Forum Bromley Christian Centre Bromley Citizen's Advice Bromley Civic Society Bromley College Bromley College of Further & Higher Education Bromley Common & Hayes Lane Association of Residents Bromley Common 2468 Residents Group Bromley Common Village Residents' Association Bromley Congregation Of Jehovah's Witnesses Bromley Conservative Club Bromley Council on Ageing Bromley Court Hotel Bromley Education Business Partnership Bromley Federation of Housing Associations Bromley Fire Station Bromley Friends of the Earth Bromley Green Party Bromley Housing Advisory Service Bromley Labour Party Local Government Committee Bromley Learning Disabilities Forum Bromley Learning Disabilities Forum c/o Bromley Mencap Bromley Little Theatre Bromley Magistrates' Court Bromley Mencap Bromley Mental Health Forum Bromley Mental Health Services Social Inclusion Unit Bromley Mind Bromley Museum Service


Bromley Muslim Association Bromley MyTime Bromley North Residents' Association Bromley Physical Disability & Sensory Impairment Forum Bromley Police Community Consultative Group Bromley Police Station Bromley Primary Care Trust Bromley Racial Equality Council Bromley Ramblers Bromley Small Business Club Bromley Somali Community Association Bromley South Action Group Bromley Town Business Forum Bromley Town Church Bromley United Reformed Church Bromley Voluntary Sector Trust Bromley Wheelchair User Group Bromley Youth Council BRONSPART Broomleigh Housing Association Bropar Limited Burnett Planning and Development Burnt Ash Housing Association C B Richard Ellis c/o United Reformed Church Cala Homes Capisano Restaurant Capita Business Services Ltd Capital Shopping Centres PLC Capitec (Part of NHS Estates) Carers Bromley Castlemore Cathedral Group Plc Cator Estate (Beckenham) Ltd Central Beckenham Liberal Democrats CGMS Consulting (on behalf of Royal Mail Property Holdings) CGMS Consulting (on behalf of the Metropolitan Police Authority) Chancery Lane/Limes Road Residents' Association Charles Church Developments Charles Planning Associates Chelsfield Park Residents' Association Chelsfield Village Society Chelsham & Farleigh Parish Council Cherrycot Residents' Association Chesterton Chinbrook Estate Residents' Association Chislehurst & Sidcup Housing Association


Chislehurst Conservative Association Chislehurst Constituency Labour Party Chislehurst Social & Liberal Democrats Chislehurst Society Chislehurst Village Society Churches Together in Bromley Churchill Insurance Churchill Theatre Bromley Circa Ltd

City of London Corporation Citygrove Securities plc Civil Aviation Authority

Colliers CRE Commission for Architecture and the Built Environment

Communities and Local Government Community Care Protection Group Community Links Bromley Community Options Computer Cab plc Confederation of British Industry Conrad Ritblat Erdman Conservative Future Conservative Penge Action Team Copers Cope Residents Association

Council for the Protection of Rural England Country Land & Business Association Countryside Strategic Projects plc Crest Strategic Crockenhill Parish Council Crockthorn Orpington Fairworth Bromley & Beck Valley Trusts Crofton Residents' Association Crowborough Drive Residents' Association Croydon & South London Chamber of Commerce & Industry Crystal Palace Community Association Cudham Conservation Group Cudham Residents' Association Curtis Haines Cushman & Wakefield, Healey & Baker D & M Planning Dartford District Council David Lock Associates David Wilson Homes Deaf Access Bromley Department for Children, Schools and Families Department of Child Health Department of Trade & Industry Direct Build Services


Disability Consultative Group Disability Voice Bromley Disabled Living Foundation DMI Properties Dovetail Club for Physically Disabled Downe Residents' Association Downes Planning Partnership DPDS Consulting Group

DPP LLP Dron & Wright Property Consultants Durham Avenue Residents' Association Dysart Surgery Eden Park Residents' Association Elmers End Residents' Association Empty Homes Agency English Partnerships, South London Region English Sports Council, Greater London Environment & Leisure Services, London Borough of Bexley Environment Bromley Ethnic Communities Programme / Network ETSU, Department of Trade and Industry Fairview New Homes Ltd Family Housing Association Farnborough Park Estate Ltd Residents' Association Farwig Area Residents' Association Federation of Members Sporting Clubs (Bromley) Federation of Small Businesses Felmingham Road Ressidents' Association Fernwood Close Residents' Association First Title Services Ltd Firstplan Florida Court Residents' Association FPD Savills Friends of Bromley Town Parks and Gardens Garden Estates Association Geffreys Estate Steering Group George Wimpy South London GHP Group GL Hearn Glen View Road and The Glade Residents' Association Goddington North Residents' Association Goddington Park Preservation Association Gough Planning Services Graham Simpkin Planning

Greater London Authority (Member) Greater London South County Scout Council Green Street Green Association


Green Street Green Residents' Association Green Street Green Village Society GVA Grimley Ltd Halifax Building Society Halstead Parish Council Hamptons Hayes Village Association Haysford Gardens Trust Hazlehurst Residents' Association Henry Boot Developments Ltd Hexagon Housing Association Hilda Lane Community Association Historic Parks & Gardens Trust House Builders Federation House of Fraser Housing Corporation Hyde Housing Association Hyde Housing Group I.K. Wyatt Building Design Ltd Iceni Projects Limited

Independent Land Acquisitions Insignia Richard Ellis Inventures (NHS Estates) JEMA Fund Management Limited John Lewis JR Goodman Property Consultants JusB, Chair of Children and Family Forum Kelsey Housing Association Kelsey Park Estate & District Protection Association Kent Archaeological Rescue Unit Kent Association for the Blind

Kent County Council Kent Downs Area of Outstanding Natural Beauty Unit

Kent Trust Conservation Corps Kent Wildlife Trust Kent Wildlife Trust (Bromley Group) Keston Park (1975) Ltd Keston Village Residents' Association Kevington Residents' Association Kier Property Kitewood Estates Knoll House Residents Laing Homes South East Thames Lambert Smith Hampton (on behalf of NOMS / HM Prison Service) Land Use Consultants Leander Group Leaves Green & Keston Vale Residents' Association


Leesons Residents' Assocociation Legal & General Property Ltd Lennon Planning Lennon Planning (on behalf of Linden Homes) Lennon Planning Partnership LGBT Forum Liberata Linays Commercial Linden Homes South-East Links Estate Residents Association

Lloyds Commercial Property Developments Local History Society for the London Borough of Bromley London & Quadrant Housing Trust London Ambulance Service London Borough of Bexley London Borough of Bromley Residents' Federation London Borough of Croydon London Borough of Greenwich London Borough of Lambeth London Borough of Lewisham London Borough of Southwark London Borough of Southwark Chiltern London Central Bus Co Ltd London City Airport London Councils London Cycling Campaign London Development Agency London Fire & Emergency Planning Authority London Fire & Emergency Planning Authority, Southern Command London First Group London Green Belt Council London Transport Users Committee London Travel Watch London Walking Forum Lower Amherst Residents' Association Lowood Court Residents' Association Lullington Road Tenants' Association LXB M. J. Gleeson Group MacDonalds Restaurants Ltd Magpie Dance Marks and Spencers Marlowe Society Martin Grant Homes Ltd Mead Road Residents' Association Medical Journalists Association and the Guild of Health Writers

Members of the Bromley Friends’ Group Forum


Metrobus Ltd Metropolitan Police Metropolitan Police Service - Property Services Michael Rogers Minc Property Enterprises Ltd

Minority Ethnic Forum Mission Care Moat Housing Group Ltd Mobile Operators Association Monks Orchard Road Residents' Association Morley Fund Management Motor Cycle Action Group Mottingham Estate Tenants' Association Mottingham Residents' Association Mountview & Perry Hall Residents' Association Museum of London Archaeology Service Nash Residents' Association Nathaniel Lichfield and Partners Nathaniel Lichfield and Partners National Car Parks Ltd National Liberal Club National Playing Fields Association National Trust, Orpington & Chislehurst Centre Nationwide Planning NATS NCMA Network Rail Newlands Unit NHS Executive London Nicholson Estates North Bromley Residents' Assocation North Street Residents' Association (Bromley) Northpoint, Sherman Road Residents Association Oakfield Lane Residents' Association Oakwood, Pound Lane, Knockholt Old Hill and Cudham Lane North Residents’ Association

Old St. Paul's Cray Village Residents' Association Orange Personal Communications Services Ltd Orchard Road Society Oregon Park Residents' Association Orpington & District Amenity Society Orpington & District Archaeological Society Orpington Social and Liberal Democrats Outdoor Advertising Association Oxleas NHS Trust Palace Estate Residents' Association Palace Road Residents' Association


Palmer Johnson Design Park Langley Residents' Association Parkside Avenue Residents' Association Parliamentary, Correspondence and Briefing Unit Parsons Brinckerhoff

Paul Hyett Architects Peacock & Smith Limited Pedestrian Association Pellings Limited Penge East Residents' Association Penge Forum Persimmon Homes Petts Wood & District Residents' Association Phillips Planning Services Limited Phoenix Pre-school Centre Pillar Property Ltd Place Farm & Sparrows Drive Estates Residents' Assoc Planning Aid For London Planning Newspaper Planning Publications Ltd Playlink Post Office Property Holdings Presentation Housing Association Limited Primedene Properties Ltd Princes Plain Primary School Professional Planning Services Queen Adelaide Court Tenants & Residents' Association Radcliffe Housing Association Ramblers' Association Ramsden Residents' Association Rapleys Ratcliffes

Ravensbourne Valley Preservation Society Redrow Homes Religious Society of Friends (Quakers) Renewal & Recreation London Borough of Bromley Rialto Group plc Ringers Court Residents Association Robert Turley Associates Robinson Escott Planning Rookery Residents' Association Rowan Park Residents' Association Royal Horticultural Society Royal London Mutual Insurance Society Ltd Royal Mail RPS RPS Ashdown


RPS Planning & Development (on behalf of Fairview New Homes) RPS Planning & Development (on behalf of Invista Foundation Property Ltd) Rydon Homes Sainsbury's Supermarkets Ltd Salvation Army Sanctuary Housing Association SBAX

SCOTRA

Scott Wilson Scott-Brown Partnership SE London Green Chain Sevenoaks District Council Shackleton Real Estates Ltd. Shire Consulting (on behalf of Barclays Bank PLC Shortlands Residents' Association Showman’s Guild of Great Britiain

Sinclair Jones Slough Estates Plc Social and Liberal Democrats SOLOTEC Somerfield Stores C/O Roger Tym + Partners South East London Museums Service South East London Strategic Health Authority South Eastern Trains Ltd South London and Maudsley NHS Trust South London Business South London Family Housing Association South Penge Park Residents' Association Southill Residents' Association Sport Bromley Sport England, Greater London Region St Cecelia’s Cheshire Home

St James Developments St James's Investments Ltd St Mary Cray Residents Association St. George's C E Primary School St. Joseph's R C Primary School St. Mark's (C of E) Church St. Mark's C E Primary School St. Mary Cray Action Group St. Paul's Cray Community Association St. Paul's Cray Residents' Association St. Paul's Cray Tenants & Residents' Association Stagecoach Selkent Star Planning and Development Stateside Services UK Ltd Stepping Stones Club


Stirling Drive Residents' Association Stradella and Springfield Residents' Association Strategic Land & Planning Consultants Strategic Rail Authority Strutt and Parker Stylish Living Ltd Sundridge Park Preservation Society Sundridge Park Residents' Association Sundridge Residents' Association Suretex Textilers Care Centre Surrey County Council Sustrans Swanley Town Council Tandridge District Council Tatsfield Parish Council Taylor Woodrow Developments Limited Temple Homes Thames Water Property Services The Abbeyfield Beckenham Society Ltd The Abbeyfield Bromley Society Ltd The Architect's Panel The Barton Willmore Planning Partnership-Northern The Beckenham Place Park Society The Bickley Park Residents Group The British Motorcyclists Federation The Broadoaks Estate Association The Bromley Children Project

The Camden Society The Chenies Road Association The Countryside Agency - South East Region Office The Crown Estate Commissioners The Crystal Palace Foundation The Denis Wilson Partnership The Fairfield Partnership The Federation of Broomleigh Residents The Garden History Society The Gardens Residents' Association The Glades Merchants' Association The Glades Youth Chaplain The Grove Park Community Group The Groves Residents' Association The Hayes (Kent) Community Council The Highway & District Residents' Association The Homes and Communities Agency The Knoll Residents' Association The Lambethans' Society The London Forum of Amenity and Civic Societies


The Mead & Mead Way Residents' Association The National Trust (South East Region) The Open Spaces Society The Pavilion The Planning Bureau Ltd The Ravensbourne School The Rookery Estates Company The Rotary Club of Chislehurst The Royston Estate Residents' Association The Theatres Trust The Tree Council The Victorian Society Tinkling Springall Solicitors Tower Homes Ltd Town & Country Housing Town Centre Chaplain Transport & Travel Research Ltd and South London Freight Quality Partnership Transport for London Tree Council Triscape Planning Trustees of Bromley & Sheppard's Colleges Turley Associates Turley Associates on behalf of TRW Pensions Trust Ltd Turley Associaties (on behalf of Sainsbury's Supermarkets) Turpington Community Association Twentieth Century Society University of the Third Age University of Westminster Urban Environment Today Urban Regeneration Partnership Vinson Close Residents' Association Visit London Waitrose Wates Wellers Solicitors West Beckenham Conservative Club Ltd West Beckenham Residents' Association West Wickham Residents Association West Wickham South Residents Association

Westerham Parish Council Westminster City Council Whitbread Property Wickham Common Residents' Association Wilcon Homes William Andrews & Co Wilson Connolly Homes Windsor Drive Community Association


WM Morrison Supermarkets Plc Woodlands Valley Residents' Association Wright (Properties) Ltd and Waitrose Ltd WSP Developments Yester Park Residents' Association Youth Housing Forum


APPENDIX 6.1 PROPOSED SUBMISSION AAP: REPRESENTATION FORM

1

Proposed Submission Area Action Plan (AAP) for Bromley Town Centre

Publication Stage Representation Form

Ref: PS011 (For official use only)

Name of the DPD to which this representation relates: Proposed Submission Area Action Plan for

Bromley Town Centre

Please return to

Marc Hume N98, North Block Civic Centre, Stockwell Close Bromley, BR1 3UH

This form has two parts – Part A – Personal Details Part B – Your representation(s). Please fill in a separate sheet for each representation you wish to make.

Part A

1. Personal Details* 2. Agent’s Details (if applicable) *If an agent is appointed, please complete only the Title and Name boxes below but complete the full contact details of the agent in 2.

Title

First Name

Last Name

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Line 2

Line 3

Line 4

Post Code

Telephone Number

E-mail Address

(where relevant)

2

Part B – Please use a separate sheet for each representation

Name or Organisation:

3. To which part of the AAP does this representation relate?

Paragraph Policy Proposals Map

4. Do you consider the AAP is :

Legally compliant Yes No

Sound Yes No

5. Do you consider the AAP is unsound because it its not:

(1) Justified

(2) Effective

(3) Consistent with national policy

6. Please give details of why you consider the AAP is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the AAP, please also use this box to set out your comments.

(Continue on a separate sheet /expand box if necessary)

7. Please set out what change you consider necessary to make the AAP legally compliant or sound,

having regard to the test you have identified at 5 above where this relates to soundness. You will need to say why this change will make the AAP legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of policy or text. Please be as precise as possible?

(Continue on a separate sheet /expand box if necessary)

Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested change, as there will not normally be a subsequent opportunity to make further representations based on the original representation at the publication stage. After this stage, further submissions will be only at the request of the inspector, based on the matters and issues he/she identifies for examination.

3

8. If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination:

No, I do not wish to participate at the oral examination

Yes, I wish to participate at the oral examination

9. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary:

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

10. Please indicate below if you wish to be notified of any of the following

(a) That the AAP has been submitted to the Secretary of State for independent examination

(b) The publication of the recommendations of the independent examination, and

(c) The adoption of the Area Action Plan

Signature: Date:


APPENDIX 6.2 PROPOSED SUBMISSION AAP: LETTER TO GLA: REQUEST FOR GENERAL CONFORMITY

020 8461 7637 [email protected] Town Planning Information BTC/AAP/PropSub/reg29 Mr. Giles Dolphin Greater London Authority, City Hall The Queen's Walk London SE1 2AA 8 June 2009 Dear Mr. Dolphin, Bromley Town Centre Area Action Plan Proposed Submission Document – Request for General Conformity I am writing to formally request that the Mayor of London consider the general conformity of the Proposed Submission Area Action Plan for Bromley Town Centre and supporting documents as required under new regulation 29 of the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008. You have been sent the proposed submission documents and a statement of representations procedure separately, but please find enclosed a cd containing all the relevant documentation. The Mayor’s opinion must be received no later than 17:00 on Friday 17th July 2008. Representations may be submitted using the enclosed standard response form but if required, a Microsoft Word version of the form to complete electronically can be provided by contacting us on 020 8461 7637 or emailing [email protected] For further information please do not hesitate to contact us at the abovementioned number or email address. Yours Sincerely,

Jonathan MacDonald Assistant Director of Renewal Town Centre Development Team cc. Alison Fairhurst, Government Office for London

Ms. Alison Fairhurst Government Office for London 157-161 Millbank London SW1P 4RR

020 8313 4787 [email protected]

btc/aap/propsub/reg29

11th June 2009

Dear Ms. Fairhurst,

Bromley Town Centre Area Action Plan:

Letter to Mayor of London Requesting General Conformity Please find attached the letter to Giles Dolphin to formally request that the Mayor of London consider the general conformity of the Proposed Submission Area Action Plan for Bromley Town Centre and supporting documents as required under new regulation 29 of the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008.

Please do not hesitate to contact us at the abovementioned number or email address

if you have any queries. Yours sincerely,

Jonathan MacDonald Assistant Director of Renewal


APPENDIX 6.3 PROPOSED SUBMISSION AAP: EXAMPLE CONSULTATION LETTER SENT OUT BY LB BROMLEY

020 8461 7637 [email protected] Town Planning Information BTC/AAP/PropSub 9 June 2009 Bromley Town Centre Area Action Plan Proposed Submission Document The Proposed Submission Area Action Plan (AAP) for Bromley Town Centre and supporting documents contained in the enclosed cd are to be published on the 8th of June 2009 and the Council is inviting you to make a formal representation based on the ‘Test of Soundness’ of the documents. Representations should be made using the enclosed form with the guidance notes as a reference. The AAP contains the planning policy framework for managing development in the town over the next 15 years whilst at the same time protecting and enhancing the town's historic features. Based on the responses to the three previous rounds of public consultation, the proposals have been further refined. The AAP provides the necessary structure to support the regeneration of the town centre by including significant proposals for retail, leisure, residential and commercial development. All representations will be forwarded along with the plan itself to the Secretary of State for examination. The closing date for the submission of representations is 5pm on 17th July 2009 and these should be sent to: Marc Hume, Director of Renewal & Recreation c/o Town Centre Development Team, Room N98, Bromley Civic Centre, BR1 3UH or via email to: [email protected] The plan and its supporting documents are available for inspection at all the Council’s libraries, at reception in the Civic Centre or on the Council’s web site: www.bromley.gov.uk/BromleyTownCentreAAP . Please use the contact number above or email [email protected] if you have any further queries. Yours Sincerely,

Jonathan MacDonald Assistant Director of Renewal Town Centre Development Team


APPENDIX 6.4 PROPOSED SUBMISSION AAP: NOTICE OF PUBLICATION

LONDON BOROUGH OF BROMLEY

NOTICE OF PUBLICATION OF THE PROPOSED SUBMISSION VERSION OF THE AREA

ACTION PLAN FOR BROMLEY TOWN CENTRE

Planning and Compulsory Purchase Act 2004 as Amended by the Town & Country Planning (Local Development) (England) (Amendment) Regulations 2008

Representations on Soundness are being invited from 8 June 2009 to 17 July 2009.

(a) The title. Bromley Town Centre Area Action Plan – Proposed Submission Document

(b) The subject matter. The Area Action Plan is a Development Plan Document (DPD) which sets out the development opportunities for Bromley Town Centre over the next 15 years. It includes major redevelopment opportunities and major traffic and transport infrastructure changes. It sets out the planning framework for significant change and conservation, including detailed development control policies.

(c) The period within which representations may be made. The Bromley Town Centre Area Action Plan proposed submission document will be available for comment from 8

th June 2009 until 5 pm on 17th July 2009.

(c) How representations should be made In accordance with regulations, representations on the soundness of the DPD should be made using the response form downloadable electronically via the website (http://www.bromley.gov.uk/environment/planning/town+centre+action+plan/) and the guidance notes as a reference.

(d) The address to which representations must be sent.

All representation forms on the Proposed Submission Bromley Town Centre Area Action Plan must be sent to: Marc Hume Director of Renewal & Recreation c/o Town Centre Development Team Room N98 Bromley Civic Centre Stockwell Close Bromley BR1 3UH All electronic versions of the forms must be sent to: [email protected]

(e) Statement of notification. Please remember to indicate in your response if you wish to be notified of any of the following:

(a) That the DPD has been submitted to the Secretary of State for independent examination

(b) The publication of the recommendations of the independent examination, and (c) The adoption of the Area Action Plan

This notice is prepared in accordance with the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008. The Proposed Submission Bromley Town Centre Area Action Plan together with its supporting documents are available for inspection on the Bromley Council Web site –

http://www.bromley.gov.uk/environment/planning/town+centre+action+plan/

and at the following locations during the hours specified over a period of 6 weeks:

The Civic Centre, Stockwell Close, Bromley Main Reception Mon, Fri, 8.30am to 5.30pm Planning Reception Mon, Fri, 8.30am to 4.45pm Bromley Central Library, High Street, Bromley Mon, Wed, Fri 9.30am - 6.00pm Tues, Thurs 9.30am - 8.00pm Sat 9.30am - 5.00pm Anerley, Town Hall, Anerley Road, Penge Mon 9.30am - 8.00pm Tues, Wed, Fri 9.30am - 6.00pm Sat 9.30am - 5.00pm Beckenham Library, Beckenham Road, Beckenham Mon, Tues 9.30am - 6.00pm Wed, Fri 9.30am - 8.00pm Sat 9.30am - 5.00pm Mottingham Library, 31 Mottingham Road, Mottingham Mon to Wed 9.30am - 6.00pm Fri 9.30am - 8.00pm Sat 9.30am - 5.00pm Orpington Library, The Priory, Church Hill, Orpington Mon, Wed 9.30am - 6.00pm Tues, Fri 9.30am - 8.00pm Sat 9.30am - 5.00pm Shortlands Library, 110 Shortlands Road, Bromley Mon 9.30am - 8.00pm (Closed 1.00- 2.00pm) Tues, Wed, Fri 9.30am - 6.00pm (Closed 1.00-2.00pm)

Sat 9.30am - 5.00pm (Closed 1.00-2.00pm)

With the exception of the Civic Centre & Central Library, the above Libraries are closed on Thursdays, and those below are closed on Wednesdays Penge Library, 186 Maple Road, Penge Mon, Tues, Thurs, Fri 9.30am - 6.00pm Sat 9.30am - 5.00pm Southborough Library, Southborough Lane, Bromley Mon, Tues, Thurs 9.30am - 6.00pm Fri 9.30am - 8.00pm Sat 9.30am - 5.00pm St. Paul's Cray Library, Mickleham Road, St Paul`s Cray

Mon, Thurs, Fri 9.30am - 6.00pm Tues 9.30am - 8.00pm Sat 9.30am - 5.00pm Biggin Hill Library, Church Road, Biggin Hill Mon, Thurs, Fri 9.30am - 6.00pm Tues 9.30am - 8.00pm Sat 9.30am - 5.00pm Chislehurst Library, Red Hill, Chislehurst Mon, Thurs 9.30am - 8.00pm Tues, Fri 9.30am - 6.00pm Sat 9.30am - 5.00pm Petts Wood Library, Frankswood Avenue, Petts Wood Mon, Thurs 9.30am - 8.00pm Tues, Fri 9.30am - 6.00pm Sat 9.30am - 5.00pm

West Wickham Library, Glebe Way, West Wickham Mon, Fri 9.30am - 8.00pm Tues, Thurs 9.30am - 6.00pm Sat 9.30am - 5.00pm The following two Libraries are closed, in addition to Wednesday, on the days specified: Burnt Ash Library, Burnt Ash Lane, Bromley Mon, Thurs 9.30am - 6.00pm (Closed 1.00pm - 2.00pm) Sat 9.30am - 5.00pm (Closed 1.00pm - 2.00pm) Tues, Wed, Fri – Closed Hayes Library, Hayes Street, Hayes Tues, Fri 9.30am - 6.00pm (Closed 1.00-2.00pm) Thurs 2.00pm - 8.00pm Sat 9.30am - 5.00pm (Closed 1.00-2.00pm) Mon, Wed - Closed Sat 9.30am - 5.00pm Mobile library times and route available on

www.bromley.gov.uk

Further information is available on the Bromley Council Web site – http://www.bromley.gov.uk/environment/planning/town+centre+action+plan/ or from the Town Centre Development Team - 020 8461 7637


APPENDIX 6.5 PROPOSED SUBMISSION AAP: COMMITTEE REPORT

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Report No. DRR09/00107


PART 1 - PUBLIC

Agenda Item No.

Decision Maker: Development Control Committee

Date: 20th October 2009

Decision Type: Non-Urgent Executive Key

Title: SUBMISSION OF THE AREA ACTION PLAN FOR BROMLEY TOWN CENTRE FOR INDEPENDENT EXAMINATION

Contact Officer: Bob McQuillan, Chief Planner Tel: 020 8313 4441 Email: [email protected] Jonathan Macdonald, Assistant Director, Renewal and Recreation Tel: 020 8313 4847 E-mail: [email protected]

Chief Officer: Director of Renewal & Recreation

Ward: Bromley Town


1.1 Having undergone the formal period of consultation on “soundness” during the summer, the next step for the Area Action Plan for Bromley Town Centre (The AAP) will be its submission to the Secretary of State for independent Examination.

1.2 This report presents the main issues arising from the final period of consultation which will

be put forward to the Inspector and suggests some amendments to deal with additional minor issues. The amendments do not alter any of the strategy or objectives of the plan, nor should their inclusion cause any concerns over soundness.

________________________________________________________________________________


2.1 Members of Development Control Committee are asked to note

• the main issues raised in the representations on the pre-submission AAP, and

• the suggested minor amendments to be approved by Executive

• the provisional timing of events post submission.

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Corporate Policy

1. Policy Status: New policy. The AAP will be the Council’s first Development Plan Document (DPD) in the Local Development Framework (LDF). As a DPD the AAP is subject to independent examination.

2. BBB Priority: Vibrant Thriving Town Centres. ________________________________________________________________________________

Financial

1. Cost of proposal: N/A The sites identified in the AAP present opportunities for private sector investment of the type that resulted in the development of The Glades. While the Council may incur expenditure in assisting in site assembly it would only do so if it is assured that those costs will ultimately be met by the developer. There is also an opportunity for the Council to obtain capital receipts for the sale of its own land. The Council owns 6 of the 12 opportunity sites

2. Ongoing costs: N/A.

3. Budget head/performance centre: R & R

4. Total current budget for this head: £n/a

5. Source of funding: Consultancy costs have been met from the Planning Development Grant, Town Centre Improvement Fund, LABGI and the LPSA 1 reward funds and are within the approved budget.

________________________________________________________________________________

Staff

1. Number of staff (current and additional): n/a

2. If from existing staff resources, number of staff hours: n/a ________________________________________________________________________________

Legal

1. Legal Requirement: Statutory requirement. The Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 amend the 2004 regulations and prescribe the procedure for submission and adoption of the Area Action Plan.

2. Call-in: Call-in is not applicable. ________________________________________________________________________________

Customer Impact

1. Estimated number of users/beneficiaries (current and projected): borough -wide ________________________________________________________________________________

Ward Councillor Views

1. Have Ward Councillors been asked for comments? No.

2. Summary of Ward Councillors comments: NA

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3. COMMENTARY

Main issues outstanding from representations on the pre-submission AAP. 3.1 During the consultation period on the Soundness of the plan, 40 representors put forward

104 representations. Representors include local residents, businesses, interest groups, statutory consultees, Government Office for London (GOL) and the GLA. A list of representors is attached as Annex 1. The representations will shortly be available to view on the Council’s website (with personal details removed) and a summary table has been placed in the Members’ Room for information. All the representations will be submitted to the Secretary of State alongside the plan.

3.2 The main issues are:

• Level of parking standards

• Deliverability, Phasing and Flexibility of Opportunity Sites

• Safeguarding of land for transport improvements

• Impact of Development on the Conservation Area

• Viability of Opportunity Sites A, J & G 3.3 The Greater London Authority (GLA) suggests that some minor changes are required in

order for the plan to be considered in general conformity with the London Plan. Some of these will be dealt with by making minor amendments to the AAP (see below). However, there remains an outstanding issue raised by Transport for London (TfL) to the effect that additional car parking be expressed as a maximum, not a minimum standard.

3.4 Government Office London (GOL) seeks greater clarification on interrelationship in the

phasing of Sites E, F and G (The Pavillion, The Civic Centre and the western side of the High Street), and alternative arrangements should proposals not proceed in accordance with the proposed phasing.

3.5 Telereal Trillium, previous applicants for planning permission on Site L (the DHSS building

and Christian Centre), question the need for the safeguarded land at the edge of their site which they consider to hinder the deliverability of their proposals.

3.6 A number of representors raise concerns about the impact of the plans upon the

Conservation Area and other elements of the historic environment. English Heritage, Friends of Bromley Parks and Gardens and APCA, for example, consider that the AAP is not consistent with national planning policy (PPG15 – historic conservation) in its assessment of the town’s historic fabric.

3.7 Linden Homes and Network Rail indicate that the reduction of residential units from 400 to

around 250 on Site A (Bromley North Station) would make the scheme economically unviable due to the high costs associated with the relocation and replacement of the multi-storey car park. Conversely, the Bromley Civic Society and Babbacombe Residents Association consider that the quantum of development on this site is unjustified and wish for the impact on the character of the surrounding area to take greater importance.

3.8 Turley Associates, representing some of the properties located within Site G (West of the

High Street) and residents of Ethelbert Close / Ringers Road / Ethelbert Road object to the parking schemes, density and the design of Site G proposals, citing conservation, sustainability and blight issues.

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3.9 It is proposed not to make significant changes to the plan as a result of these main issues, but to submit the plan as published.

Minor amendments 3.10 In order to address some typographical errors, remove duplications and assist clarification

of the plan, a schedule of minor amendments has been prepared (see Annex 2). Subject to approval, this would be submitted alongside the AAP for the Inspector to consider. The amendments do not alter any of the strategy or objectives of the plan, nor should their inclusion cause any concerns over soundness.

Examination of the AAP 3.11 Examination of the AAP starts with the submission of the document to the Secretary of

State (The Planning Inspectorate in practice). A Planning Inspector will consider the soundness of the plan in general as well as considering potential issues raised by the representations and the Inspector may raise issues in addition to those summarised here. Subject to Executive formally approving the minor amendments suggested, the AAP will be submitted to the Planning Inspectorate following their meeting on 4th November 2009. The Planning Inspectorate will then appoint a Planning Inspector (PI) who will confirm the key dates for Pre-Hearing Meetings and the dates of any Hearings deemed necessary.

3.12 A Programme Officer (PO) is in place who will deal with the practical and administrative

requirements of the representors and the Inspector during the Examination stage. Although based at the Civic Centre, the PO remains independent of the Council. Communication will also be assisted through the development of a section of the Council’s website specifically for the Examination where all necessary documents will be made available.

3.13 Although the Examination timetable remains in the hands of the Inspector, the Planning

Inspectorate expect to keep to a tight week-by-week schedule. Based upon guidance issued by the Planning Inspectorate we would anticipate the Examination Hearings to take place in early March 2010 and the Inspector’s report to be submitted to the Council by the end of June 2010. The Council must then publish the report, and if the plan is found sound, it should be adopted at the earliest opportunity.

4. POLICY IMPLICATIONS

4.1 The AAP sets out the policy framework for the future development of Bromley Town Centre. Proposals within the plan take into account national and regional planning policy and, as a spatial plan, other non-planning policies. The soundness and legal compliance of these proposals will be tested by a Planning Inspector at Examination.

4.2 The attainment of Vibrant and Thriving Town Centres is a key Council priority under

“Building a Better Bromley” corporate policy and implementing an AAP is crucial to strengthening the Town Centre’s position in the current economic climate and ensuring its future prosperity in the face of increasing competition.

5. FINANCIAL IMPLICATIONS

Funding for the AAP progress is being met from the Planning Delivery Grant, Town Centre Improvement Fund, LABG1 and LPSA 1 reward funds.

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6. LEGAL IMPLICATIONS

6.1 The Plan is a statutory document and has been prepared under the Planning and Compulsory Purchase Act 2004, and in accordance with The Town & Country Planning (Local Development) (England) Regulations 2004 as Amended by the Town & Country Planning (Local Development) (England) (Amendment) Regulations 2008

7. PERSONNEL IMPLICATIONS

NA

Non-Applicable Sections: PERSONNEL IMPLICATIONS


Proposed Submission AAP June 2009


APPENDIX 6.6 LETTER TO PLANNING INSPECTORATE

Alison Ingham The Planning Inspectorate 3/25 Hawk Wing Temple Quay House, 2 The Square, Temple Quay Bristol BS1 6PN

020 8313 4787 [email protected]

btc/aap/propsub/reg27

4th June 2009

Dear Ms. Ingham,

Bromley Town Centre Area Action Plan:

Invitation for representation(s) on the Soundness of the Proposed Submission

Area Action Plan for Bromley Town Centre

As required under Regulation 27 of the Town & Country Planning (Local

Development) (England) Regulations 2004, please find enclosed a hard copy and a

cd of the Proposed Submission Area Action Plan for Bromley Town Centre and

supporting documents.

I also enclose a copy of the Statutory Notice from the Bromley Newsshopper

published on the 3rd of June 2009. Yours sincerely,

Jonathan MacDonald Assistant Director of Renewal

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