TOWN AND COUNTRY PLANNING ACT 1990 ACQUISITION OF LAND ACT Inquiry into:

TOWN AND COUNTRY PLANNING ACT 1990 ACQUISITION OF LAND ACT 1981 Inquiry into: The London Borough of Haringey (Wards Corner Regeneration Project) Compulsory Purchase Order 2016 Proof of Evidence of Suzanne Johnson Haringey Council PINS Ref.: NPCU/CPO/Y5420/77066 Inquiry start date: 11 July 2017

CONTENTS Section 1- Qualifications and experience Section 2- Introduction and scope of evidence Section 3- Planning Policy Framework Section 4- The need for regeneration and development Section 5- Measures taken to promote regeneration Section 6- The Order Scheme Section 7- Scheme Delivery Section 8- Justification for Compulsory Purchase Section 9 - Negotiations Section 10- Response to objections Section 11- Conclusion/Summary and declaration APPENDICES Appendix 1 Market Traders Steering Group Minutes Appendix 2 Tottenham Green Ward Crime Statistics Appendix 3 Seven Sisters Public Space Protection Order Information Sheet Appendix 4 February 2012 Cabinet Report: Funding and Investment Package for the Tottenham Regeneration Programme Appendix 5 February 2012 Cabinet Report Minutes: Funding and Investment Package for the Tottenham Regeneration Programme Appendix 6 Tottenham Regeneration Timeline 1

Appendix 7 November 2009 Cabinet Report: NDC Succession Arrangements Appendix 8 November 2009 Cabinet Minutes: NDC Succession Arrangements Appendix 9 Wards Corner- Local Engagement Chronology Appendix 10 Secretary of State Consent Letter Appendix 11 Mayoral Decision: Wards Corner Regeneration Appendix 12 Elizabeth Collins v Secretary of State for Communities and Local Government [2013] EWCA Civ 1193 2

1 QUALIFICATIONS AND EXPERIENCE 1.1 My name is Suzanne Johnson and I am Head of Area Regeneration, employed by the London Borough of Haringey. I have worked for the Council since March 2014. I am responsible for the management of the Tottenham Regeneration Programme for the geographical area comprising Seven Sisters, Tottenham Green and Bruce Grove, including Tottenham High Road. My role involves managing physical, economic and social regeneration projects and programmes at a senior level including, the redevelopment of sites to deliver new homes and jobs, public realm improvement projects, town centre strategy preparation, town centre management, and economic development and growth initiatives. 1.2 My area of responsibility includes working with partners and stakeholders to strengthen the role and performance of Tottenham s town centres and Tottenham High Road, an aspiration set out in the Strategic Regeneration Framework for Tottenham (2014) (CD10/6) and in the draft Tottenham Area Action Plan (2016) (CD2/5). Since my appointment in March 2014 this has focused on delivering public realm improvement projects, bringing forward appropriate town centre development sites, and supporting existing and new businesses. I chair the Place Board for Tottenham and I am a member of the Tottenham Delivery Board (multidisciplinary partnership boards tasked with the ensuring the successful implementation and delivery of the regeneration programme). 1.3 In relation to the Wards Corner site I am the Council s Senior Officer responsible for ensuring the implementation of the regeneration proposals. I lead a team to manage the implementation of the Order Scheme Agreement (entered into on 3 August 2007) and all associated work related to the implementation of the development scheme. 1.4 Prior to joining Haringey I worked at the London Borough of Barking and Dagenham as Regeneration Manager responsible for Town Centres and Economic Development. My work at Barking and Dagenham included the preparation of a town centre strategy for Barking, the overall management of the Outer London Fund (Greater London Authority grant programme), the implementation of development sites and delivery of new homes and commercial space including Barking Riverside, the submission of a Townscape Heritage bid to the Heritage Lottery Fund, delivery of public realm 3

improvements, and the implementation and management of economic development and business support functions. Prior to Barking and Dagenham I worked at Enfield Council where I was responsible for the implementation and delivery of the New Southgate Masterplan and the initiation of the Edmonton Green Masterplan. Prior to this I was employed by the London Borough of Southwark as a senior policy planner with responsibility for preparing the Core Strategy as well as Area Action Plans and Supplementary Planning Documents for specific geographical areas including Canada Water, Peckham and Dulwich. 1.5 I have worked in Regeneration and Planning for 13 years and I am a chartered member of the Royal Town Planning Institute. 4

2 INTRODUCTION AND SCOPE OF EVIDENCE 2.1 I have prepared this proof of evidence in support of the compulsory purchase order ( the Order ) that has been made by the Council to facilitate the redevelopment of the Wards Corner site and deliver the regeneration of Seven Sisters. 2.2 The site is part of the Tottenham Regeneration area. Tottenham is undergoing a major regeneration programme which was initiated in 2012. It is one of the largest regeneration projects in Europe with the aim of delivering 10,000 new homes and 5000 new jobs by 2026. The regeneration of Tottenham is strongly supported by other public sectors partners including the Greater London Authority and Transport for London both of whom are represented on the Tottenham Delivery Board. 2.3 The Wards Corner redevelopment scheme will be delivered by Grainger, the Council s Development Partner who received planning consent for the site in 2012 (reference HGY/2012/0915) (CD4/3) following the completion of a conditional Development Agreement (CD4/1) between the Council and Grainger in 2007 and several years of scheme design development, consultation and land assembly. The development will provide 196 new high quality homes in Seven Sisters/West Green Road district town centre and 3693m2 of commercial space (A1/A2/A3/A4 use classes) including a new and improved market hall for Seven Sisters indoor market. In addition the scheme will deliver significant public realm improvements for the land around the site. 2.4 Grainger have to date completed the relevant conditions set out in the 2007 Development Agreement, including the implementation of the planning permission on 5th May 2017 (reference HGY/2017/0861) (CD4/37). More details on scheme delivery are set out in Sections 7 and 8. 2.5 The Wards Corner scheme ( the Order Scheme ) will result in a high quality mixed use commercial and residential development in one of the borough s district town centres in the Tottenham regeneration area (a defined Area of Regeneration in the London Plan (CD2/2)), on one of the most accessible and well connected sites in Tottenham directly above Seven Sisters underground and rail station and on a strategic transport corridor (the A1010). 5

2.6 The Order Scheme will significantly enhance the quality of the physical environment in the central core of the Tottenham regeneration area by providing high quality mixed used town centre development at the key public transport gateway into Tottenham. The redevelopment of the site will provide space for enhanced and additional retail units in the district town centre, including a new and improved Seven Sisters Market, which will be complemented by an enhanced town centre public realm. 2.7 A mix of different sizes of new homes in this highly accessible location will also help to support the vitality and viability of the town centre and encourage people to shop locally. Overall the scheme will act as a catalyst for the wider regeneration of Tottenham by providing new homes, jobs, shopping and leisure opportunities as well an enhanced public realm and physical environment in a strategic town centre location within the Tottenham regeneration area. 2.8 My proof of evidence is set out as follows: Section 1- Section 2- Section 3- Section 4- Outlines my qualifications and experience Introduces and sets out the scope of my proof of evidence Outlines the planning policies relevant to Order Scheme Sets out the need for regeneration and development Section 5- Describes the steps the Council has taken to promote the regeneration of the area Section 6- Section 7- Section 8- Section 9- Section 10 - Explains the Order Scheme in detail Explains how the proposals will be delivered by the Council and its Development Partner. Sets out the justification for the Compulsory Purchase Order Sets out the appraoch to negotiations Sets out the Council s repsonse to objections 6

Section 11- Conclusions / Summary and declaration 7

3 PLANNING POLICY FRAMEWORK 3.1 The regeneration of Wards Corner is a long standing objective for the Council, the site having first been identified in 2004 as having scope for redevelopment in the Wards Corner/Seven Sisters Underground Development Brief ( the Development Brief ) (CD2/3). The section below sets out the planning policy framework as well as other strategies and plans that relate to, and support, the delivery of the Order Scheme and the transformative economic, social and environmental regeneration of Tottenham. National Planning Policy Framework 3.2 The National Planning Policy Framework (NPPF) sets out the Government s planning policies for England, it provides the framework for Local Planning Authorities when preparing their local Development Plan documents and is a material consideration in the determination of planning applications. The NPPF provides a presumption in favour of sustainable development. This means that in plan-making Local Planning Authorities should positively seek opportunities that meet the strategic development needs of their area (including policies for housing and economic development) and, in decision- taking, Local Planning Authorities should approve development proposals that are in accordance with the development plan without delay. 3.3 The NPPF sets out a number of core planning principles that should underpin both planmaking and decision-taking. The regeneration of Wards Corner and the Order Scheme directly address the following core planning principles in paragraph 17 of the NPPF (CD2/8): (a) (b) Proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth; Always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings; 8

(c) (d) (e) (f) (g) Take account of the different roles and character of different areas promoting the vitality of our main urban areas; Encourage the effective use of land by reusing land that has been previously developed (brownfield land); Promote mixed use developments, and encourage multiple benefits from the use of land in urban areas; Actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable; and Conserve heritage assets commensurate with their significance. 3.4 In addition to the core planning principles set out above the Order Scheme also accords with the delivery of the following NPPF policies (CD2/8): (a) Building a strong and competitive economy (para. 18-22); (b) Ensuring the vitality of town centres (para. 23-27); (c) Promoting sustainable transport (para. 29-41); (d) Delivering a wide choice of high quality homes (para. 47-55); (e) Requiring good design (para. 56-68); (f) (g) Promoting healthy communities (para.69-78); and Conserving and enhancing the historic environment (para.126-141). Development Plan 3.5 The statutory development plan comprises the following documents: (a) London Plan as amended with alterations (2016); 9

(b) Haringey Local Plan: Strategic Policies Development Plan Document (2013) ( Strategic Policies ); and (c) Haringey Unitary Development Plan (detailed saved policies) (adopted in July 2006 and as modified following adoption of the Strategic Policies in March 2013) ("UDP"'). 3.6 The following policies of the development plan are relevant to the making of the Order: (a) The London Plan 3.7 The London Plan (CD2/2) sets out the planning framework for London as a whole including a number of specific area based policies for the area in which the Order Scheme is located. There are a number of policies in the London Plan with which the scheme will comply, namely: 3.8 Overall focus on promoting growth, sustainable development and a good, sustainable quality of life for everyone in London (Policy 1.1). 3.9 Policy 2.3, Growth areas and co-ordination corridors endorses the nationallyrecognised London-Stansted-Cambridge-Peterborough Growth Corridor. Tottenham lies towards the southern end of this Growth Corridor. This policy requires stakeholders to identify and develop linkages across, and the capacity of, such nationally recognised areas. 3.10 Policy 2.6 Outer London: Vision and Strategy, emphasises the need to improve the quality of life in outer London and to promote improvements that are sensitive to the needs of existing neighbourhoods. 3.11 Policy 2.7 Outer London: Economy, seeks to ensure that opportunities for economic growth are maximised and capacity is identified and brought forward in and around town centres with good public transport accessibility to support viable local economic activities, including leisure and retail, and higher density housing. This policy also advocates the use of compulsory purchase to assemble sites to promote growth of retail and leisure facilities in and around town centres. 10

3.12 Policy 2.8 Outer London: Transport, recognises the benefits of integrating land use and transport planning to ensure use of vacant and under-used land is optimised. 3.13 Policy 2.13, Opportunity Areas and Intensification Areas, identifies the Upper Lee Valley (which includes Tottenham and the Order Land) as an Opportunity Area in London. The Mayor supports proactive policies for growth, regeneration and improved environmental quality in such areas and encourages partnerships in preparing and implementing opportunity area planning frameworks to realise the growth potential of these areas. Opportunity Areas are described as the capital s major reservoir of brownfield land with significant capacity to accommodate new housing, commercial and other development linked to existing or potential improvements to public transport accessibility. Development proposals in Opportunity Areas should seek to optimise residential and non-residential output and densities, provide necessary social and other infrastructure to sustain growth and, where appropriate, contain a mix of uses. 3.14 Policy 2.14, Areas for Regeneration, identifies Tottenham (including the Order Land) as within a regeneration area because the area is in the 20% most deprived areas in London (based on Lower Layer Super Output Areas ('LSOA')). In such areas, the London Plan calls for action to promote sustained renewal by coordinated and integrated neighbourhood-based action and investment based on partnership working with the Mayor, strategic and local partners. Boroughs should set out spatial policies which bring together regeneration, development and transport proposals together with improvements in learning and skills, health, safety, access, employment, environment and housing. 3.15 Policy 2.15, Town Centres (including the West Green Road/ Seven Sisters district centre in which the Order Land is located), requires that developments should sustain and enhance the vitality and viability of the centre and relate the existing and planned roles of individual centres to the network as a whole to achieve its broader objectives. Boroughs should also consider the scope for consolidating and strengthening them by encouraging a wider range of services; promoting diversification, particularly through high density, residential led, mixed use re-development; improving environmental quality; facilitating site assembly, including through the compulsory purchase process. Boroughs should also actively plan and manage the consolidation and redevelopment of 11

medium sized centres to secure sustainable, viable retail offer; a range of non-retail functions to address identified local needs; and significantly higher density housing in a high quality environment. 3.16 Policy 3.1, Ensuring Equal Life Chances for All, requires that developments should protect and enhance facilities and services that meet the needs of particular groups and communities and should not involve the loss of these facilities without adequate justification or provision for replacement. 3.17 Policy 3.3, Increasing Housing Supply, recognises the pressing need for more homes and requires boroughs to achieve and exceed their annual housing growth targets (which, in the case of Haringey, equates to 1,502 new dwellings per annum for the period 2015-2025). In particular, the London Plan urges boroughs to realise the potential capacity on brownfield sites in opportunity areas, regeneration areas and growth corridors to maximise housing delivery and provide as many new homes as possible to meet the needs of London s growing population. 3.18 Policy 3.4, Optimising Housing Potential, calls on boroughs to identify the range of needs within their areas and to ensure that developments optimise housing output for different locations within the relevant density range. 3.19 Policy 3.8, Housing Choice, calls on boroughs to identify the range of needs within their areas and to ensure that developments offer a range of housing choices in terms of size, type and tenure within an area. 3.20 Policy 3.9, Mixed and Balanced Communities, emphasises the importance both of promoting mixed and balanced communities by tenure and household income and of ensuring attractive design, adequate infrastructure and an enhanced environment. It states that a more balanced mix of tenures should be sought in all parts of London, particularly in some neighbourhoods where social renting predominates and there are concentrations of deprivation. 3.21 Policy 3.14, Existing Housing, requires that loss of housing should be resisted unless the housing is replaced at existing or high densities. 12

3.22 Policy 4.7, Retail and Town Centre Development, advocates a strong partnership approach to assessing need and identifying and bringing forward capacity for retail, commercial, cultural and leisure development in town centres. Proposed retail and town centre development should be focused on sites within town centres and should be guided by policies based upon identified future retail and town centre floor space need, regular town centre health checks and a partnership approach to identifying capacity and bringing forward development within town centres. A diverse range of night time activities should be encouraged in town centres to help keep public spaces safe. 3.23 Policy 4.7 also states that proposed retail and town centre development should be focused on sites within town centres and should be guided by policies based upon identified future retail and town centre floor space need, regular town centre health checks and a partnership approach to identifying capacity and bringing forward development within town centres. A diverse range of night time activities should be encouraged in town centres to help keep public spaces safe. 3.24 Policy 4.8, Supporting a Successful and Diverse Retail Sector and Related Facilities and Services, includes supporting convenience retail particularly in district centres (which includes the West Green Road/Seven Sisters Road district centre within which the Order Land is located, as to which see further below) and the range of London s markets, complementing other measures to improve their management, enhance their offer and contribute to the vitality of town centres. 3.25 Policy 4.9, Small Shops, in considering proposals for large retail developments, boroughs should, consider imposing conditions or seeking contributions through planning obligations where appropriate, feasible and viable, to provide or support affordable shop units suitable for small or independent retailers. 3.26 Policy 6.1, Strategic Approach, encourages the closer integration of transport and development by encouraging patterns and nodes of development that reduce the need to travel, promoting walking by ensuring an improved public realm and seeking to ensure that all parts of the public transport network can be used safely and easily. 13

3.27 Policy 6.10, Walking, aims to bring about a significant increase in walking in London by emphasising the quality of the pedestrian and street environment, including through simplified streetscape, de-cluttering and access to all. 3.28 Policy 7.1, Lifetime Neighbourhoods, promotes development that (amongst other things) contributes to people s sense of place, safety and security. Development should be designed to interface with surrounding land and improve people s access to social and community infrastructure, local shops, employment and training opportunities and public transport. The design of new buildings and the spaces they create should help reinforce or enhance the character, legibility, permeability, and accessibility of the neighbourhood. 3.29 Policy 7.3, Designing out Crime, requires that a safe, secure and appropriately accessible environment should be created with developments which reduce the opportunities for criminal behaviour. 3.30 Policy 7.4, Local character, states that developments should have regard to the form, functions and structure of an area and should build on the positive elements that can contribute to establishing an enhanced character for the future. 3.31 Policy 7.5, Public Realm, seeks the highest quality design and public realm that is secure, accessible and enables easy movement. Development should make the public realm comprehensible at a human scale, using gateways, focal points and landmarks to help people find their way. Landscape treatment should be of the highest quality and contribute to the easy movement of people through the space, with opportunities for the integration of high quality public art. 3.32 Policy 7.8, Heritage Assets and Archaeology, advises that development should identify, value, conserve, restore, re-use and incorporate heritage assets, where appropriate. 3.33 Policy 8.2, Planning Obligations, states that the consideration of planning obligations in relation to development proposals should take account of economic viability. (b) Haringey Planning Framework 3.34 The principle of redevelopment of the Wards Corner site is set out in several Haringey Local Plan documents. The Order Land is within both a designated Area of Change and 14

the High Road Corridor, and is within a defined Town Centre (see the diagrammatic plan of Tottenham). DIAGRAMMATIC PLAN OF TOTTENHAM Order Land Source: Draft Tottenham Area Action Plan 15

(c) Haringey Local Plan: Strategic Policies 3.35 The Strategic Policies (CD2/4) designate the West Green Road, High Road and Seven Sisters Road frontages of the Order Land as part of the West Green Road/Seven Sisters District Town Centre. The Strategic Policies regard the district centre as an important shopping destination for the local community. 3.36 The Strategic Policies identify the Seven Sisters Road Corridor a priority area for change with a strategic role to play in the future growth of the borough. Seven Sisters Underground station is located in the Seven Sisters Road Corridor at its eastern end. In setting out the Council s aspirations for this Corridor, the Strategic Policies (page 57) envisage the: Opportunity for ensuring that the Seven Sisters area and the tube and train station provides landmarks/gateways to aid legibility through redevelopment and/or renewal;.. Wards Corner regeneration delivering houses, shops and public realm improvements through redevelopment and/or renewal 3.37 Policy SP0, Presumption in Favour of Sustainable Development, accords with the presumption in favour of sustainable development (per the National Planning Policy Framework (2012) ('NPPF')) and confirms that the Council will work proactively to secure development that improves the economic, social and environmental conditions in Haringey. 3.38 Policy SP1, Managing Growth, identifies Tottenham High Road and the Seven Sisters Corridor as areas of change where development will be promoted. 3.39 Policy SP2, Housing, states that the Council will aim to provide homes to meet Haringey s housing need through a range of requirements for new development, including meeting the density levels set out in the London Plan and meeting affordable housing targets, subject to viability. 3.40 Policy SP7, Transport, seeks to locate major trip generating developments in locations with good access to public transport and so better integrate transport and land use planning and promote road safety and pedestrian movement particularly in town centres and close to local services.

3.41 Policy SP8, Employment, looks to support local employment and regeneration aims. 3.42 Policy SP9, Improving Skills and Training to Support Access to Jobs and Community Cohesion and Inclusion, seeks to address unemployment by increasing the employment offered in the borough. 3.43 Policy SP10, Town Centres, promotes the distribution of retail growth to meet the required needs in the Metropolitan and five district centres in the borough. The Council will promote and encourage development of retail, office, community, leisure, entertainment facilities, recreation uses, arts and cultural activities within its town centres according to the borough s town centre hierarchy. The district town centres (including West Green Road/Seven Sisters) will continue to be supported and strengthened as important shopping and service centres to meet people s day-to-day needs. The Council will take a proactive partnership approach to reinvigorating these town centres, widening their role and offer, developing their identities, improving the public realm and accessibility to them. 3.44 Policy SP10 also establishes a requirement for an increase in retail provision of 23,995m2 floorspace (13,800m2 comparison goods and 10,195m2 convenience) across the borough up to 2026. 3.45 Policy SP11, Design, requires that all new development should enhance and enrich Haringey s built environment and create places and buildings that are high quality, attractive, sustainable, safe and easy to use. 3.46 Policy SP12, Conservation, looks to ensure the conservation of the historic significance of Haringey s heritage assets, their setting, and the wider historic environment. (d) Haringey Unitary Development Plan ( UDP ) 3.47 A number of policies from the UDP have been saved and sit alongside the Haringey Local Plan Strategic Policies. Relevant policies from the UDP include (CD2/7): 3.48 ENV7: Air, Water and Light Pollution which requires developments to control potential pollution by locating it in areas that minimise the levels of air, water and light pollution created and minimising any impacts where appropriate. 17

3.49 EMP5: Promoting Employment Uses supports employment generating activities outside of Defined Employment Areas where trips generated by the proposal are sustainably catered for. 3.50 Policy TCR5: A3 Restaurants and Cafes sets out a number of criteria which must be taken into account when assessing proposals for restaurants and cafes, including management of the use and the impact on the town centre. 3.51 Policy M9: Car Free Residential Developments sets out requirements for proposals which do not provide car parking, including good public transport accessibility. 3.52 Policy CSV7: Demolition in Conservation Areas seeks to protect buildings within Conservation Areas unless in exceptional cases where substantial community benefit would result from the total or substantial demolition of the buildings. 3.53 There is reference to Wards Corner as a key site in the West Green Road/ Seven Sisters town centre, within the supporting text for Town Centres and Retailing chapter (paragraph 6.27). In particular, Wards Corner (together with Apex House) is identified as part of a site specific proposal (site no. 21) for comprehensive mixed use development, with specific reference to the 2004 Development Brief (CD2/3). Other material considerations 3.54 Paragraph 216 of the NPPF (CD2/8) states that weight should be given to emerging plans in making planning decisions according to; the stage of preparation of the emerging plan, the extent to which there are unresolved objections, and the degree of consistency of the emerging plan to the policies in the NPPF. The following documents and policies are material considerations that relate to the Wards Corner site and Order Scheme: London Plan: Draft Supplementary Planning Guidance Culture and the Night Time Economy (2017) 3.55 The Mayor of London recently consulted a draft Culture and Night Time Economy SPG (CD2/11). This SPG provides further guidance on the implementation of the London Plan policies that have a bearing on London s culture and the night time economy. It sets out the business case for supporting the night time economy, 18

capitalising on the recently launched Night Tube (including the Victoria Line which runs through Seven Sisters), but also the need to balance the needs of different groups at the same time. 3.56 The major contribution that the evening and night time economy can have on town centres is identified. Boroughs are encouraged to proactively identify and manage night time economy clusters, promoting the vitality that this can bring, while working with police, businesses and other partners to address place-based crime and any other negative impacts which might arise. 3.57 The improvement of the restaurant and market offer on the site as well as the improved public realm as a place to dwell and spend time in will contribute to the improvement of the cultural offer and evening economy in the Seven Sisters/West Green Road district town centre. It is also anticipated that in the medium to long term this improved cultural and evening economy offer will spread to other areas in the district centre and further up the High Road to areas such as Tottenham Green where a number of civic and cultural uses are situated such as the Bernie Grant Arts Centre, Tottenham Green Leisure Centre, Marcus Garvey Library and the College of North East London (Tottenham Green campus). Draft Tottenham Area Action Plan (2016) 3.58 In January 2016 the Council published the pre-submission version of the draft Tottenham Area Action Plan (2016) ( AAP ) (CD2/5), which seeks to guide new development in Tottenham by providing clarity and certainty on how opportunities for improving, and achieving regeneration in, Tottenham should be delivered. The AAP gives effect to the spatial strategy by identifying and allocating deliverable sites with capacity to accommodate a minimum of 10,000 new homes and 5,000 jobs. It includes a number of area-wide policies for Tottenham as well as more place specific policies for neighbourhood areas and opportunities sites. 3.59 The Examination in Public hearing sessions on the draft AAP took place between 23 August and 8 September 2016. As part of this process Alterations to the Tottenham AAP was subject to a Main Modifications Public Consultation from 18 November 2016 to 13 January 2017. 19

3.60 No modifications are proposed to the Wards Corner site allocation SS5, however, some modifications were proposed to the planning policy for the Seven Sisters and West Green Road District Centre (SS1) details of which are set out the relevant policy paragraph below. 3.283.31 The relevant policies of the Tottenham Area Action plan are: 3.61 AAP1: Regeneration and Masterplanning which requires development proposals to come forward comprehensively in order to optimise development outcomes on individual sites to deliver and support the regeneration objectives for Tottenham, and the vision of the AAP. Wards Corner is specifically identified in Table 2 as a site requiring a comprehensive approach to development. 3.62 AAP2: Supporting Site Assembly states that the Council will support land assembly to achieve comprehensive development and will use compulsory purchase powers when necessary and where a set of criteria have been satisfied. 3.63 AAP5: Conservation and Heritage states that, in line with the relevant parts of the NPPF, where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use. It also states that if substantial or total loss of significance of designated heritage assets would only be considered where it satisfactorily justifies and demonstrates that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss. 3.64 AAP6: Urban Design and Character Including Tall Buildings, states that high density development is expected adjacent to public transport nodes, Growth Areas and Areas of Change. 3.65 AAP7: Transport, states that the Council will work with its partners to promote and support the delivery of key infrastructure proposals to support the regeneration of Tottenham, including proposals that enhance the transport interchange between Tube, train, buses, walking and cycling at Tottenham s transport interchanges. 3.66 AAP8: Development along Tottenham High Road states that development along the High Road will be supported where it is demonstrated to positively enhance the 20

overall character and setting of the High Road and produces improved views along the High Road. It also provides that car-free development will be supported due to the excellent public transport connections along the High Road, which is a point that applies particularly to the Wards Corner site given its location above Seven Sisters underground station. 3.67 The Seven Sisters/ West Green Road Sub Area envisages redevelopment of a number of key sites including Wards Corner, Apex House, Lawrence Road and Gourley Triangle to deliver enhancement of the urban realm and transport interchange at Seven Sisters Underground station, refocusing of retail floorspace at the Seven Sisters end of the district centre and a number of other new uses for the area and place making initiatives. 3.68 The AAP advocates urban realm improvements for the Seven Sisters area including, improvements to footway and public realm/station entrances, new wayfinding/ signage as part of wider Tottenham strategy, targeted streetscape and environmental improvements including an enhanced urban realm between Seven Sisters and Tottenham Green and recognition/redesign of the street to encourage use of the proposed Green Link through Tottenham Hale towards Lee Valley Regional Park. 3.69 Policy SS1 sets out the aspirations for the Seven Sisters and West Green Road District Centre which include promoting positive regeneration, retaining the viability of the shopping area, active town centre uses, high quality urban realm around Seven Sisters station, retention of Seven Sisters market and the conservation and enhancement of heritage assets. As a result of the examination into the AAP an additional element to this policy is proposed, which would require proposals to conserve and enhance heritage assets and their setting, consistent with other policies in the AAP. 3.70 SS2: Lawrence Road and SS4: Gourley Triangle site allocations include provision for retaining employment uses and increasing the density of employment uses with some residential development and enabling the delivery of affordable employment space. Proposed employment uses for the Gourley Triangle site allocation are intended to support and create flexible workspace for businesses in the knowledgedriven economy. These sites, and their corresponding site allocations, are important 21

to note in relation to their proximity to the district town centre as the retention and promotion of employment uses on edge of town centre sites will assist with strengthening and supporting the role of the town centre. 3.71 SS5: Wards Corner is identified as a site specific allocation for comprehensive mixed use development including town centre uses at ground floor and a replacement market, with residential uses above, due to its location above Seven Sisters Station, in the Seven Sisters/ West Green Road district centre and at a gateway location into Tottenham and the High Road. The re-provision of the Seven Sisters Market also seeks the provision of small and affordable retail units to enable accessibility for local independent traders, temporary re-housing of the Market and the provision of retail and town centre uses ground floor levels (on all frontages other than Suffield Road) to strengthen and reinvigorate the town centre. 3.72 A further result of the examination into the Tottenham Area Action Plan was the addition of a table setting out a trajectory for sites in Tottenham which will contribute to the borough requirement (set out in the Strategic Policies DPD 2013 (as amended by Alterations 2016)(CD2/18)) to deliver 23,995m2 of town centre floorspace up to 2026 (13,800m2 comparison goods and 10,195m2 convenience). To meet this requirement, the AAP identifies sites with potential to deliver 85,570m2 of town centre floorspace. The vast majority of this town centre floorspace is anticipated to be within the retail use classes (A1 and A2). The trajectory specifies that 3,700m2 of this town centre floorspace will be delivered on the Wards Corner site. 3.73 The AAP allocates Tottenham Hale as a new district town centre. A map of the town centres in Tottenham including the Tottenham Hale allocation is provided in the AAP (see map below). 22

District Town Centre Map. Source: draft Tottenham AAP Alterations to Strategic Policies (2016) 3.74 In January 2016 the Council published the pre-submission version of Alterations to the Strategic Policies (CD2/18). As with the Tottenham AAP, the EiP hearing sessions took place between 23 August and 8 September 2016. As part of this process Alterations to the Strategic Policies was subject to a Main Modifications Public Consultation from 18 November 2016 to 13 January 2017, but no modifications were proposed which impact on the 2013 Strategic Policies document outlined earlier in this section. 3.75 The purpose of the alterations was to reflect Haringey s new strategic housing requirement in the London Plan which saw the annualised housing target for the borough increase from 820 to 1,502 net new dwellings per annum. The London Plan 23

also revised Haringey s jobs forecast significantly upward to 22,000 jobs for the period 2015 to 2031 The alterations reaffirm the spatial strategy for the Borough, with Tottenham continuing to be the Council s priority for regeneration and growth over the period to 2026 and beyond, providing a minimum of 10,000 homes and 5,000 jobs. The final document is scheduled to be adopted by the Council in July 2017. Draft Development Management DPD (2016) 3.76 The draft Development Management DPD (2016) (CD2/17) sets out borough-wide policies. In January 2016 the Council published the pre-submission version of Development Mangement DPD. As with the Tottenham AAP, the EiP hearing sessions took place between 23 August and 8 September 2016. As part of this process the Devleopment Management DPD was subject to a Main Modifications Public Consultation from 18 November 2016 to 13 January 2017. The Development Management DPD policies relevant to the order site are: 3.77 DM32: Parking, which states that the Council will support proposals for new development with limited or no on-site parking in areas with a Public Transport Accessibility Level of 4 and above, with the exception of provision for disable parking. 3.78 DM41: New Town Centre Development, provides support for proposals for new retail uses within designated town centres where these are consistent with the role and function of the centre and contribute to the vitality and viability of the town centre network. 3.79 DM42: Primary and Secondary Shopping Frontages, seeks active ground floor frontages within the borough s designated town centres and to control the amount of frontage in non-retail use, especially within the primary shopping frontages. 3.80 DM45: Maximising the Use of Town Centre Land and Floorspace, seeks to optimize the development potential of sites located within a town centre by encouraging mixed use development. London Plan: Supplementary Planning Guidance Town Centres (2014) 3.81 The Town Centres Supplementary Planning Guidance (SPG) (CD2/10) provides further guidance on the implementation of the London Plan policies on town centres 24

and focuses on supporting the evolution and diversification of town centres, the intensification of town centres with the introduction of high density housing, improving quality, promoting accessibility and connectivity. It also includes regeneration initiatives and mechanisms as well as proactive town centre strategies. The Order Scheme fully accords with the principles set out in this guidance in relation to the intensification and diversification of London s town centres via the delivery of higher density and high quality mixed use schemes. Wards Corner/Seven Sisters Underground Development Brief (2004) 3.82 The aspiration to redevelop the site as a mixed use residential and retail development was established in 2004 in the Wards Corner/Seven Sisters Underground Development Brief (CD2/3) which supports a landmark development to act as a gateway to Seven Sisters. 3.83 The site was identified at this point in time as suffering from high crime levels, a poor quality environment and an underperforming retail offer. The 2004 Development Brief set out how urban design, transport and access and land use and development principles should be set to guide the redevelopment of the site, including introducing new, modern buildings while enhancing the Page Green Conservation Area, making the most of existing opportunities presented (buildings of merit, rich and diverse communities) while improving the public realm, introducing a mix of uses including housing, ensuring development is comprehensive, sustainable and accessible. Use of compulsory purchase powers is not ruled out where used to secure comprehensive redevelopment. Other plans, strategies and considerations Upper Lee Valley Opportunity Area Planning Framework (OAPF) (2013) 3.84 As stated previously, the Upper Lee Valley Opportunity Area ( Opportunity Area ) is designated in the London Plan Policy 2.13. Opportunity Area. The OAPF (CD2/6) is Supplementary Planning Guidance to the London Plan and was adopted in 2013. The Order Scheme is in conformity with the guidance for the Opportunity Area as it will; optimise a redevelopment opportunity along the Tottenham High Road Corridor (also referred to as the A10/A1010 corridor), deliver new homes, jobs, investment, 25

and improved transport infrastructure. Furthermore, the scheme will directly deliver the aspirations contained in the Supplementary Planning Guidance to create a gateway into Tottenham and the High Road at Seven Sisters and to bring about the comprehensive redevelopment of Ward Corner to deliver new homes, retail and public spaces. Draft Seven Sisters/Page Green Conservation Area Appraisal and Management Plan (2016) 3.85 The draft Seven Sisters/Page Green Conservation Area Appraisal and Management Plan (2016) (CD2/13) was published for public consultation in 2016. The purpose of this document is to provide an update to the 2009 Tottenham High Road Historic Corridor Character Appraisal (CD2/16) by setting out and recording those aspects of Conservation Areas which make a particular contribution to their character and appearance and should be preserved or enhanced, or those that detract from the Conservation Area and any specific action to be taken based on these impacts in the form of a management plan. 3.86 The 2016 update concludes that there has been a reduction in the quality and the appearance of the buildings in the row of buildings facing the High Road in comparison to the 2009 appraisal: this terrace was a prominent feature of the area, especially after it formed the frontage of the local department store that gave its name to Wards Corner. In its current condition however the terrace has lost any sense of its former architectural interest, compounded by the poor visual interest of the shop fronts now facing the High Road. 3.87 The map of the Conservation Area identifies the locally listed buildings on the site as 227 High Road (the former Wards department store) and 1A and 1B West Green Road (trading as Tottenham Wines). The buildings at 255-259 High Road are listed as a positive contributor to the Conservation Area and no s 229 to 249 High Road are listed as having a neutral impact on the Conservation Area. No 251-253 is now an empty site with no buildings on it. 3.88 The final document is scheduled to be adopted by the Council s Cabinet on 20 th June 2017 and is therefore likely to be in place at the time of the public inquiry. 26

Assets of Community Value 3.89 The ground floor of the market building was added to the Council's list of Assets of Community Value ('ACV') (CD11/16) in March 2014, pursuant to Part 5 of Chapter 3 of the Localism Act (CD1/7). The effect of the ACV designation is only to impose a moratorium on disposals, and not a prohibition, and in any case, the moratorium does not apply to land which is compulsorily purchased. 27

4 THE NEED FOR REGENERATION AND DEVELOPMENT 4.1 This section of the proof provides an overview and description of the current provision and offer on the Wards Corner site in relation to what the Order Scheme will deliver. More detailed information on the need for regeneration and development and the justification of the Compulsory Purchase Order are set out in Lyn Garner s proof of evidence and in section 8 of this proof of evidence. Area context 4.2 Tottenham comprises seven Wards (Tottenham Green, Seven Sisters, St. Ann s, Northumberland Park, White Hart Lane, Tottenham Hale and Bruce Grove). The long central spine of Tottenham High Road contains a mix of shops, sports, leisure and community facilities together with public buildings and some residential development. Tottenham High Road has a mixture of fine Georgian, Victorian and Edwardian buildings, some of which are listed by Historic England as having special architectural and historical interest of national importance. 4.3 The High Road has been in decline over a number of years demonstrated by its designation as an Area of Regeneration in the London Plan, poor performance in relation to the Indices of Multiple Deprivation (further information which is set out in Lyn Garner s proof of evidence), efforts undertaken as part of the Tottenham regeneration programme, and the relatively poor performance of its town centres in comparison to other district centres in Haringey. Consultation with the local community over recent years has highlighted the need to improve the physical environment of the High Road and secure more of a variety of higher quality national and independent retailers. Town Centre and Retail 4.4 The site has been identified for mixed use town centre redevelopment since the publication of the 2004 Development Brief (CD2/3). The former Wards Corner department store closed around 1972 and since then the retail offer of the site has consisted of Seven Sisters market (around 60 market stalls/units incorporating approximately 38 businesses) and around 10 individual retail stores (retail premises 28

along Seven Sisters Road and West Green Road as well as one non market retail unit along the High Road frontage). 4.5 The site is in a highly accessible location and forms part of a multimodal transport hub directly on top of Seven Sisters underground station (serviced by the Victoria Line), next to Seven Sisters rail station and along the High Road bus corridor. In my view given its corresponding high PTAL score (6a) and its location in the core of both a district town centre and Area of Regeneration the site is not fulfilling its considerable potential to deliver a high quality mixed use town centre development that boosts the vitality and viability of the town centre, improves the physical appearance of the whole area, improves the arrival experience into Tottenham, and ultimately delivers transformative economic, social and environmental regeneration for Seven Sisters and Tottenham as a whole. 4.6 The Haringey Retail and Town Centres Study prepared by Nathaniel Lichfield and Partners (2013) (CD11/8) provides an analysis of the economic performance of all district town centres in Haringey. The study states that the Seven Sisters/West Green Road District Town Centre has an above average number of vacant units compared to national averages and an above average number of convenience retailers, in particular beauty shops and takeaways. Vacancy rates are used provide a useful indication of the economic health of the town centre and generally speaking, the more vacant units there are, the less economically successful a town centre is. 4.7 In addition, the 2013 report states that the Seven Sisters/West Green Road Town centre has a limited range of higher order or national multiple retailers and that turnover rates are relatively high. It indicates that compared to the results of a 2008 perception survey of the district town centre it appears to have declined and that overall perceptions are worse compared to analysis undertaken in 2008. A survey of residents was carried out which asked what would make them visit the town centre more often and better choice of shops was the most frequent response for the Seven Sisters/West Green Road district town centre. 4.8 The study concludes by recommending that diversification of the retail offer in the Seven Sisters/West Green Road district town centre should be encouraged to ensure the future success and prosperity of the town centre. 29