Policy HS2 - Housing Site, former Register Office

Justification:

Two sites within the Hoe Neighbourhood Area are specifically allocated for housing development within the Plymouth and South West Devon Joint Local Plan: PLY27, the former Register Office, and PLY28, land to the north of Cliff Road on the former Quality Hotel site. Approximately 140 dwellings are allocated across these two sites, with PLY27's assessed capacity being 52 homes and PLY28's 88 homes. PLY27 is allocated for a mixed-use development, including a hotel alongside the housing.

There is significant common ground between the Hoe Neighbourhood Development Plan and Plymouth and South West Devon Joint Local Plan visions for the site, as expressed in the policy text for HS2 and PLY27 respectively. Recognising that Neighbourhood Development Plan policies should not restate those of higher level plans, these points of agreement have not been restated in Policy HS2 itself. However, they are listed here to aid in understanding the relationship between HS2 and PLY27 and to demonstrate that the Hoe Neighbourhood Development Plan aims to build on and refine, rather than directly challenge, the PLY27 approach. Both policies support:

• Allocation of the site for mixed-use development, including housing
• High-quality architecture maximising the site's redevelopment potential and its role as a strategic gateway to Armada Way
• Development to be informed by a detailed heritage character assessment
• Design to conserve and, where appropriate, enhance the character or appearance of the Hoe Conservation Area and Registered Park and Garden, including adjacent listed buildings
• Encouragement of active ground floor frontages to enliven all public streets and spaces, Armada Way and Citadel Road in particular
• Improved east-west public access along the site's northern boundary, linking Armada Way to Lockyer Street
• High-quality public realm, including the enhancement of Armada Way
• Innovative car parking solutions to reduce the visual impact of vehicles on the public realm

Since the adoption of the Plymouth and South West Devon Joint Local Plan in March 2019, the Hoe Neighbourhood Forum have, with the knowledge and full support of Plymouth City Council, reviewed the existing PLY27 evidence base. This work has included commissioning further evidence on urban design, architecture, and viability, along with carrying out additional local community consultation more rigorous than was possible for the strategic-level Plymouth and South West Devon Joint Local Plan. Plymouth City Council is aware of this further work and has been broadly supportive of it (see the Hoe Neighbourhood Plan Consultation Statement).

The updated evidence and additional consultation indicates that selected amendments to the PLY27 approach could be justified. The amendments are not aimed at 'cancelling' or replacing PLY27; rather they aim to build on and refine the Plymouth and South West Devon Joint Local Plan proposals, with a view to maximising the site's performance in both socio-economic and environmental terms and to ensure development meets local as well as wider needs. The prominence of the site means that the image of the City Centre as a whole will benefit as a result. Policy HS2 can also assist in facilitating the implementation of other relevant Plymouth and South West Devon Joint Local Plan policies, such as SO3: Delivering Growth in Plymouth's City Centre and Waterfront Growth Area.

The evidence justifying a divergence in HS2 from the PLY27 approach is as follows:

A) Building Height

Policy HS2 aims to ensure that the height of the redeveloped building has a positive relationship to the scale of adjacent streets, spaces, and buildings. This point is recognised in Plymouth City Council's Site Planning Statement, which is part of the Plymouth and South West Devon Joint Local Plan evidence base, albeit the Site Planning Statement aims at the same time to 'maximise building heights', which is arguably not consistent with this aim.

The site-specific architectural, urban design, and viability evidence commissioned by the Hoe Neighbourhood Forum demonstrates that it is possible to regenerate the site sustainably and viably without 'maximising' building heights (albeit that an increase in height from the current building is indeed justifiable). The HS2 approach thus significantly reduces the risk of development height, form, and massing being out of character with the Conservation Area, adjacent listed buildings, and the adjacent Registered Park and Garden. It also ensures consistency with the Hoe Neighbourhood Plan's own heritage policies.

The height of the Crowne Plaza Hotel (13 storeys), which is used as a benchmark for building heights in some of the PLY27 evidence base, is not considered an appropriate yardstick for building height on this site for a number of reasons. Firstly, the hotel is outside the Conservation Area and was constructed before it was designated. Secondly, it is neither a listed building nor a non-designated heritage asset. Finally, it is described in the Hoe Conservation Area Appraisal and Management Plan as not preserving or enhancing the special quality of the Conservation Area, being 'so large and of such mundane design, that [it] impinge[s] significantly on [it]'.

On this basis, development of the site with any kind of 'landmark tower' would be inappropriate. This view is supported by much Plymouth City Council evidence and policy produced in recent years, including the Tall Buildings Strategy (2005), the Hoe Conservation Area Appraisal and Management Plan (2008), Zones of Opportunity for Tall Buildings in the Core Strategy (2009), the City Centre Strategic Masterplan (2017) and the Plymouth and South West Devon Joint Local Plan Supplementary Planning Document (2020). Collectively, these documents indicate the site has always been, and still is, outside designated zones of opportunity for tall buildings. The Hoe Neighbourhood Forum's own architectural and urban design evidence came to a similar conclusion, and the Plymouth and South West Devon Joint Local Plan Supplementary Planning Document (2020) indicates that a lower building height would also be supported by Historic England, a statutory consultee for all major planning applications.

B) Land Uses

While policy PLY27 supports the provision of a new hotel and Hoe Neighbourhood Forum agrees that Plymouth as a whole needs more hotel accommodation, the site-specific suitability of such a use is not supported by relevant evidence. The two Colliers hotel market studies commissioned by Plymouth City Council in 2014 and 2019 alongside some of the evidence supporting the allocation of PLY27, for example the Waterfront Strategic Masterplan, indicate that the site would be just as suitable for housing as for a hotel.

Further site-specific evidence gathered since the adoption of the Plymouth and South West Devon Joint Local Plan indicates that the site would be more suitable for housing provision. This includes:

• The Hoe Housing Needs Assessment, which shows evidence of the need for family and affordable housing locally, in particular for three-bedroom units in terms of dwelling size and for affordable rent and intermediate homeownership in terms of housing tenure
• Plymouth City Council's Plan for Homes, which identifies the site as having affordable housing potential and allocates it as such
• The site-specific Feasibility Report, which demonstrates how the site could be sustainably developed for housing-led mixed use
• The site-specific Viability Report, which demonstrates that development of housing-led mixed use would be viable
• Engagement with local residents, who expressed a preference for affordable and family housing on the site

Community consultation also showed a local preference for retaining registry office functions on site, in part because many local small businesses benefited from the wedding ceremonies. The wider functions of the city’s Registry Office have now moved to Derriford, but dialogue between Plymouth City Council and the Hoe Neighbourhood Forum indicated no in-principle objection to the capacity to host wedding ceremonies on the part of Plymouth City Council, despite the lack of explicit mention in PLY27. Retention of this function carries further benefit because it would support viable community use of the space, thus improving local community cohesion and town centre vibrancy and vitality, particularly in the evenings. In the view of the Hoe Neighbourhood Forum and supported by the Plymouth City Council evidence base, the site’s prominence and importance makes it a particularly suitable location to retain the capacity to host wedding ceremonies.

Finally, HS2 recognises that the use of the community space, including any capacity to host weddings, must not impact negatively on residential amenity in terms of privacy, noise, access, or security. This is a standard and common requirement for any well-designed mixed-use development.

Intent:

Policy HS2 sets out specific requirements for the Plymouth and South West Devon Joint Local Plan allocation PLY27, which is allocated for 52 homes at the former Register Office site.

Key Evidence Sources:

• Plymouth and South West Devon Joint Local Plan
• Plymouth and South West Devon Joint Local Plan Supplementary Planning Document (pages 38 to 53)
• Site Planning Statement: Plymouth Register Office Site
• Draft Tall Buildings Strategy
• Plymouth City Centre Strategic Masterplan
• The Hoe Conservation Area Appraisal and Management Plan
• Plymouth Waterfront Strategic Masterplan
• The Hoe Housing Needs Assessment
• Plymouth Hoe Design Guide
• Former Plymouth Registry Office Feasibility Study