planning report D&P/0181b/01 29 July 2015 East India Dock Estate, Clove Crescent, E14 2BE in the Borough of Tower Hamlets

planning application no. PA/15/01005

Strategic planning application stage 1 referral Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008.

The proposal Hybrid planning application: Outline planning application (all matters reserved): Demolition of all existing buildings; comprehensive mixed use redevelopment comprising a maximum of 78,871 sq.m of floorspace (excluding basement) for the following uses: residential (Class C3), business use including office and flexible workspace (Class B1), leisure uses (class D2), retail (Classes A1-A4); streets, open spaces, landscaping and public realm, utilities including sub-station(s) and other incidental works. Full planning application: Demolition of the existing building and redevelopment to provide 41,709 sq.m of floorspace (excluding basement) comprising residential (Class C3), retail, food and drink uses (Classes A1-A4), business uses (Class B1) and leisure use (Class D2) in buildings ranging from 10-27 storeys in height (plus 2 storey plant enclosure), together with car and cycle parking, associated landscaping and new public realm.

The applicant The applicant is EID Ltd and the architect is 3D Reid.

Strategic issues The loss of offices on this site raises no strategic concern and the land use principles are supported on this site within the Lower Lee Valley and emerging Isle Dogs and South Poplar Opportunity Areas, subject to sufficient mitigation for social infrastructure impacts. The affordable housing offer of 25%, the tenure split proposed and the inclusion of PRS units within the private element are all welcome, subject to the applicant’s viability appraisal being independently verified to confirm that the maximum reasonable amount of affordable housing is being secured. Given the phasing of the development, a review mechanism will be required. Whilst the layout, height, massing and public realm improvements are welcome, the residential quality raises strategic concern given the high density. Matters of flooding and energy are broadly acceptable subject to some further clarification, and more information is required on matters of air quality and transport. Recommendation That Tower Hamlets Council be advised that whilst the proposals are broadly supported, the application does not fully comply with the London Plan for the reasons set out in paragraph 105 of this report, which should be addressed before the application is referred back to the Mayor.

page 1 Context

1 On 23 June 2015 the Mayor of London received documents from Tower Hamlets Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 4 August 2015 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 1A and 3D of the Schedule to the Order 2008:

Category 1A: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats”.

Category 1B(c): “Development which comprises or includes the erection of a building(s) outside Central London and with a total floorspace of more than 15,000 square metres.”

Category 1C: “Development which comprises or includes the erection of a building more than 30 metres high outside the City of London.”

3 Once Tower Hamlets Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

4 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description

5 The site is roughly 2.5 hectares and is located in the East India Dock Estate that is situated between Aspen Way to the south, the A13 (East India Dock Road) to the north and the Blackwall Tunnel approach (A102) immediately to the west. To the north and east the site adjoins other existing office buildings also forming part of the estate. Poplar High street runs to the south-west corner of the site. The southern and western boundaries of the site are formed by a Grade II Listed naval wall.

6 The site is currently occupied by four office buildings – Ancourage House, Capstan House, Lighterman House and Mulberry House – that are arranged around a linear water feature. The buildings are roughly 8-10 stories high with 245 basement car parking spaces accessed via Clove Crescent. Mulberry House in the north-west corner of the site is currently occupied by Tower Hamlets Councils offices and Town Hall.

7 The site falls within the southern portion of the Lower Lee Valley Opportunity Area, within the Blackwall and Leamouth sub-area. It also falls within the northern part of the emerging Opportunity Area, for which a Planning Framework is currently being drafted, which, once adopted, will supersede the LLV OAPF where the geographies overlap.

8 The site is of equal distance between East India and Blackwall (DLR) stations, located approximately 230m to the south-east and south-west of the site respectively. Canning Town station is located approximately 1.1km to the east of the site, which also provides access to DLR and Jubilee line London Underground (LU) services.

page 2 9 Bus route 277 operates through this site with a stop located on Clove Crescent and stand on Saffron Avenue to the east. Route 115 is also accessible from East India Dock Road with bus stops located 200m to the north of the site. The site has a good public transport accessibility level (PTAL) of 4 on a scale from 1 (very poor) to 6 (excellent) and this is confirmed by a manual PTAL assessment undertaken by the applicant. The site is also served by the Mayor’s Cycle Hire scheme, with the nearest docking station on Naval Row, 130m to the south-west of the site, providing access to 19 cycle docking points. Site history

10 There is no significant planning history directly on the site, although prior approval for the change of use from office to residential was refused in July 2014 on the basis that the proposals comprised EIA development. A prior approval application has recently been resubmitted.

11 The East India Dock Estate and the wider area has been, and continues to be, subject to significant regeneration, and with the emerging Opportunity Area Planning Framework, the area is expected to see continued growth.

12 Of note, in 2008 the Mayor considered a scheme at Sites 6 & 8 of the East India Dock Estate (bound by Leamouth Road, East India Dock Road, Sorrell Lane and Saffron Avenue) which lies to the east of the application site (D&P reference: 0181a). This comprised a mixed use development of nine blocks ranging in height from 8 to 37 storeys for 796 dwellings and other uses including commercial, leisure and community space with basement car parking. Subsequently, the Mayor considered a scheme for the redevelopment of the Robin Hood Gardens estate to the west (D&P reference: 2727). Known as the Blackwall Reach regeneration scheme it will provide up to 1,575 new homes and a mix of commercial and community uses including a new school and faith building. In both cases, the Mayor was satisfied with the proposals to allow Tower Hamlets and the London Thames Gateway Development Corporation to determine the applications themselves.

13 Other significant development schemes in the immediate context include: New Providence Wharf (mixed use scheme of 1,000 residential units and 50,000 sq.m of commercial floorspace); Wood Wharf (mixed use development), and; Leamouth Peninsula (mixed use scheme with over 1,500 residential units).

Details of the proposal

14 The application has been submitted as a hybrid application comprising both outline and full detailed proposals, across three development zones. Development zone A is in full detail (which also comprises phase one), and development zones B and C are outline (phases 2, 3 and 4). In total the hybrid application seeks permission for a maximum development threshold of 120,580 sq.m (GIA) of floorspace across residential (up to 1,357 units), business, retail and leisure land uses, and will be limited by the parameter plans.

15 The outline component of the application seeks permission for ‘up to’ the maximum floorspace specified for each land use. The land use figures therefore generate a cumulative floorspace figure that is greater than the total amount for which outline planning permission is sought. The outline planning permission sought will set a maximum total floorspace and the cumulative floorspace of the basket of potential uses to be delivered across the site would not exceed an approved overarching total floorspace figure. Given the long term build programme anticipated (circa 5 years), the applicant requires this flexibility to allow for potential changes in market demand, and respond to uncertainties and risks over the lifetime of the development. The location of non-residential land uses across the site is also not fixed to allow for flexibility.

page 3 Land use Use Class Amount (fixed) Residential C3 37,821 sq.m / 455 units Office (flexible workspace) B1 822 sq.m Leisure D2 300 sq.m Retail A1-A4 275 sq.m Ancillary (cycle parking, entrances, waste storage) 2,491 sq.m 41,709 sq.m Table 1: Full application (development zone A) land use schedule

Land use Use Class Amount (maximum)

Residential C3 73,153 sq.m / 902 units

Office (flexible workspace) B1 1,406 sq.m

Retail A1/A4 389 sq.m

Leisure D2 661 sq.m

Ancillary floorspace (BOH, plant, storage, 9,017 sq.m servicing, sub-stations, car/cycle parking)

Table 2: Outline application (development zones B & C) indicative land use schedule

Image 1: Parameter plan – Development zones (Source: 3D Reid)

page 4 16 The scheme includes up to 155 car parking spaces, of which up to 111 will be blue badge for disabled residents, and up to 2,044 cycle spaces, 474 of which will be provided in development zone A.

17 The layout is based on the three development zones with an area of public open space to the south with new opening in the listed wall connecting the space to Naval Row and Poplar High Street to the west. The scheme includes nine blocks with four tall buildings of up to 120 metres, which are positioned to mark key nodes on the site such as East India DLR station and the access points along the north. The parameter plans set out the allowable massing envelopes, with maximum and minimum ranges. A minimum of 18,587 sq.m of public open space is included with 2,959 sq.m of shared amenity space for residents. 1,071 sq.m of this will be provided in development zone A.

Image 2: Parameter plan – Building heights (Source: 3d Reid)

18 Vehicular access to the site will continue to be from Saffron Avenue through the centre of the site. Bus access will also continue from Saffron Avenue, although passengers will be required to alight and board the bus at a new bus stop at the eastern end of the site adjacent to the lake.

Phasing

19 The following phasing plan is proposed:

 Phase 1 (development zone A): Demolish Anchorage House Retention of existing Anchorage House basement Construction of Phase 1 (detailed application)

page 5  Phase 2 Demolish Capstan House Retention of existing Capstan House basement Construction of Phase 2 (outline application) Development of Phase 2 landscaping (East India Park Area) (outline application)

 Phase 3 Demolish Lighterman House Development of Phase 3 landscaping (East India Park Area) (outline application)

 Phase 4 Demolish Mulberry House Retention of existing Mulberry House basement Construction of Phase 4 building area Development of landscaping (complete works to Central Street Area).

Images 3: View west from East India DLR station

Image 4: View east from public space

Image 5: View of podium from NE tower

page 6 Strategic planning issues and relevant policies and guidance

20 The relevant issues and corresponding policies are as follows:

 Land use principles London Plan;  Housing London Plan; Housing SPG; Draft Interim Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG;  Affordable housing London Plan; Housing SPG, Draft Interim Housing SPG;  Density London Plan; Housing SPG; Draft Interim Housing SPG;  Urban design London Plan; Shaping Neighbourhoods: Character and Context Draft SPG;  Tall buildings/views London Plan;  Heritage London Plan;  Inclusive access London Plan; Mayor’s Accessible London SPG;  Flooding London Plan;  Air quality London Plan;  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change and Energy Strategy; Mayor’s Water Strategy;  Transport and parking London Plan; the Mayor’s Transport Strategy; Draft Minor Alterations to the London Plan;  Crossrail London Plan; Mayoral Community Infrastructure Levy.

21 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plans in force for the area are; the Tower Hamlets ‘saved’ policies of Bromley Council’s Unitary Development Plan, originally adopted on 20 July 2006 with the majority of policies saved in 2009, and; the London Plan (Consolidated with Alterations since 2011). 22 The following are also relevant material considerations:  Naval Row Conservation Area Character Appraisal and Management Guidelines (adopted by Tower Hamlets in March 2007).  Lower Lee Valley Opportunity Area Planning Framework (2007);  Draft Minor Alterations to the London Plan;  The National Planning Policy Framework and National Planning Policy Guidance. Land use principles

Loss of offices

23 London Plan Policy 4.2 encourages local authorities through their local plans to enhance the offer of London’s office locations in terms of physical attractiveness, amenities, ancillary and supporting services, and to coordinate strategies to manage changes in the office market, focussing new capacity where there is strategic as well as local evidence of demand. Whilst the Policy encourages the renewal and modernisation of existing offices, it does not seek to protect existing office space and indeed promote mixed uses, including housing.

24 Tower Hamlets Council’s Proposals Map and Local Plan Policy DM16 deals with the protection and future demand for offices in the borough through a hierarchy. Preferred Office Locations (POL) where the loss of offices is resisted, are identified in Canary Wharf south of the

page 7 site and around the Aldgate and Spitalfields areas close to the City of London in the west of the borough. In Local Office Locations (LOL), redevelopment to provide housing can be accepted provided the existing office floorspace is retained; or if vacant, then it must be demonstrated that; there is a lack of demand through a robust marketing exercise; the site is unsuitable for ongoing employment use; other employment uses have been considered, and; the loss will not compromise the operation and viability of the wider LOL.

25 The application site falls within a LOL. Of the 56,000 sq.m of floorspace across five buildings, the applicant’s Office Market Review confirms that 16,650 sq.m was vacant across two of those buildings, representing a 30% vacancy. The report also confirms that East India Docks represents only 1.75% of office space within the Isle of Dogs, and it is therefore suggested that its loss will have no material impact on the market. The report presents the finding of various analysis carried out to meet local policy requirements, and confirms that agents have been unable to secure new tenants and have received little interest in the site, the office stock is not of the scale or nature of floorspace demanded by the market, and there is already a considerable supply of floorspace within the market which is preferable to that of East India Dock. As such, the loss of office floorspace on this site (which represents only 1.75% of office space on the Isle of Dogs) will not impact materially on the borough’s economic positon or the functioning of the core office market.

26 As noted in paragraphs 10-12, the area is also subject to significant change incorporating a number of high-density residential-led mixed use developments. The LLV OAPF also identifies this sub-area as having the potential to deliver up to 2,580 units in new residential areas. London Plan Policy 3.3 seeks to increase London’s supply of housing and in doing so sets borough housing targets, of which Tower Hamlets’ is the highest at 3,931 additional homes per year between 2015 and 2025. The proposal will deliver up to 1,357 units, and will therefore contribute a great deal to this recognised level of housing need in an opportunity area with significant growth potential. There is no strategic concern with the loss of offices on this site.

Mix of uses

27 London Plan Policy 3.7 encourages large residential developments capable of accommodating over 500 units to consider the provision of social infrastructure within the proposals (health, education and other essential services), as they provide the opportunity to create new neighbourhoods and the critical mass necessary to support such infrastructure.

28 The applicant has had various meeting with the Council over the past two years and has exhaustively explored the various land uses that could be suitable or necessary for the site, including a school, hotel, retail, office and leisure. Whilst at pre-application stage, GLA officers encouraged the two parties to look at the possibility of including a primary school within the scheme, it is understood that the Council’s education department did not wish to pursue this on this site. A hotel was also discounted being a town centre use and subject to sequential testing. The quantum of residential ensures there is a critical mass to support ancillary uses, and the option to provide a mix of commercial, retail and leisure space, including flexible workspace for SME’s will ensure an active neighbourhood is created. GLA officers require further information before the application is referred back at stage two on the strategy for the SME and flexible workspace, including details on how it will be delivered, marketed, let and managed to ensure there is adequate flexibility and scope for start-ups/SME to lease the space.

Conclusion

29 As noted above, there is no strategic concern with the loss of offices subject to local policy requirements being adhered to, and the mix of proposed land uses broadly meets the

page 8 aspirations of the emerging regeneration of the Blackwall area. However, notwithstanding this support for the scheme in principle, there is concern with the significant quantum of development from this and other emerging proposals, in particular the need to secure the social and physical infrastructure needed to support this significant scale of growth within the Isle of Dogs and South Poplar area.

30 GLA officers are currently working in partnership with the Council on the Isle of Dogs and South Poplar Opportunity Area Planning Framework, which is seeking to identify the social and physical infrastructure requirements triggered by the quantum of emerging development, as well as addressing the issues surrounding place making. GLA officers will work with the Council and applicant to determine whether the density proposed can be successfully integrated into a wider plan, and what measures may be required from the applicant. Further discussions are therefore required before the proposal can be considered acceptable with regards to mix of uses and density. Housing

31 The hybrid scheme will collectively deliver up to 1,357 residential units, with 455 units being delivered within the detailed phase one proposals (development zone A). The open market units will be delivered as private rent (PRS). The unit mix for zones B & C is indicative at this stage. An abbreviated table for the masterplan is included for clarity on page 10.

Phase 1 / Development zone A (detailed) Tenure Unit type No. of units No. of hab rooms % mix Open market (PRS) 1 bed 218 436 59.56% 2 bed 148 444 40.44% 366 880 75.73% Shared ownership 1 bed 10 20 33.33% 2 bed 11 33 36.67% 3+ bed 9 36 30% 30 89 31.56% Social/affordable rent 1 bed 19 38 32.2% 2 bed 12 36 20.34% 3+ bed 28 119 47.45% 59 193 68.44% Phase 1 total affordable 89 282 24.27% Phase 1 total units 455 1162 Phase 2 / Development zone B (outline) Tenure Unit type No. of units No. of hab rooms % mix Open market (PRS) 1 bed 144 288 60.5% 2 bed 94 282 39.5% 238 570 75% Shared ownership 1 bed 6 12 24%

page 9 2 bed 12 36 48% 3+ bed 7 28 28% 25 76 40% Social/affordable rent 1 bed 10 20 29.41% 2 bed 8 24 23.53% 3+ bed 16 70 47.06% 34 114 60% Phase 2 total affordable 59 190 25% Phase 2 total units 297 760

Phases 3 & 4 / Development zone C (outline) Tenure Unit type No. of units No. of hab rooms % mix Open market (PRS) 1 bed 279 558 58.13% 2 bed 201 603 41.88% 480 1161 74.33% Shared ownership 1 bed 10 20 32.26% 2 bed 12 36 38.71% 3+ bed 9 36 29.03% 31 92 22.94% Social/affordable rent 1 bed 31 62 32.98% 2 bed 20 60 21.28% 3+ bed 43 187 45.75% 94 309 77.06% Phases 3 & 4 total affordable 125 401 25.67% Phases 3 & 4 total units 605 1562 Table 3: Unit schedule broken down by phase

Whole masterplan (all development zones / phases) Tenure Unit type No. of units No. of hab rooms % mix Open market (PRS) 1 bed 641 1282 59.13% 2 bed 443 1329 40.87% 1084 2611 74.94% Shared ownership 1 bed 26 52 30.23% 2 bed 35 105 40.70% 3+ bed 25 100 29.07% 86 257 29.44%

page 10 Social/affordable rent 1 bed 60 120 32.09% 2 bed 40 120 21.39% 3+ bed 87 376 46.52% 187 616 70.56% Total affordable 273 873 25.06% Total units 1357 3484 Table 4: Masterplan unit schedule

Affordable housing and tenure

32 London Plan Policies 3.11 and 3.12 require the maximum reasonable amount of affordable housing to be delivered in all residential developments above ten units, taking into account; the need to encourage rather than restrain development; the housing needs in particular locations; mixed and balanced communities, and; the specific circumstances of individual sites. The tenure split suggested by the London Plan is 60% social/affordable rent and 40% shared ownership. The NPPF, the Mayor’s Housing SPG and the London Plan clearly state that to maximise affordable housing in London and provide a more diverse offer for the range of people requiring an affordable home, the affordable rent product should be utilised in the affordable housing offer in residential developments.

33 Tower Hamlets Council’s Core Strategy requires between 35-50% affordable housing to be delivered on all sites of 10+ units, subject to viability, with a preferred tenure split of 70% social rent and 30% intermediate.

34 As detailed in tables three and four, the masterplan scheme is expected to deliver 25% affordable housing (by habitable room) or 20% by unit number, with a broad tenure split of 70:30 in line with the Council’s policy requirement. The affordable offer and unit mix for the detailed application (development zone A) is fixed at that level, and the outline proposals will seek to deliver a balance meeting that level.

35 Whilst this offer is welcome, as noted in paragraph 30 the London Plan approach to affordable housing delivery is for maximum reasonable; the offer also falls short of local policy requirements. The applicant has therefore submitted a financial viability appraisal to the Council and its consultant for independent scrutiny. The planning statement confirms that in line with the appraisal, the 25% offer is the maximum reasonable amount of affordable housing that the scheme can deliver without impacting its viability and deliverability. The Council and/or its independent consultant should scrutinise the toolkit appraisals to determine whether this is the case. GLA officers will require both reports to be submitted prior to the application being referred back at stage two.

36 The affordable housing offer, tenure split, and type of products proposed, should aim to meet both local and strategic needs, whilst also maximising the overall provision. As noted in paragraph 36, in order to maximise affordable housing delivery and provide a more diverse offer for those requiring an affordable home, the GLA encourage the use of the affordable rent product, although within Tower Hamlets GLA officers note that affordability of units at higher rent levels can be problematic. Nonetheless, it is recommended that the financial viability assessment include various scenario tests, including a policy compliant test with affordable rent to indicate what the difference in affordable quantum would be. Details of rent levels, and any discussions with the Council’s preferred registered providers should also be provided prior to the application being referred back at stage two.

page 11 37 Given the expected five year delivery and phasing of the scheme, GLA officers would welcome the inclusion of a review mechanism in the section 106 agreement. This should be worded to require the developments finances to be re-tested at a later stage to allow any additional financial surplus to be captured prior to implementation/between phases, that may be generated by an uplift in sales values. Such a mechanism would need to be designed so as to ensure an appropriate proportion of any financial surplus would be awarded to the Council, and ring-fenced for the delivery of additional affordable housing units.

Mixed and balanced communities

38 London Plan Policies 3.8, 3.9 and 3.11 and the Mayor’s Housing SPG all accord priority to affordable family housing in new residential development, promote housing choice and seek a balanced mix of unit sizes and tenures in new developments in order to promote mixed and balanced communities. This can be achieved by providing a mix of tenures and unit sizes across the development and ensuring that the scheme is tenure blind.

39 Whilst the scheme includes a good mix of unit sizes, it has a fairly low provision of family sized units (those with three or more bedrooms) at 8.25%. This is significantly lower than the Council’s policy target of 30% family sized units. The applicant asserts that the high density nature of the scheme lends itself better to smaller units, and more specifically, that the PRS market generally has a greater demand for the smaller units. GLA officers also recognise that the ‘bought’ portion of a larger shared ownership unit in this location would be unaffordable and fall outside of the GLA’s income thresholds. Nonetheless, officers recognise that the low proportion of family sized units in the scheme are predominantly earmarked for affordable tenures - 78% for social/affordable rent and 22% for shared ownership – and this is welcome. The inclusion of four bedroom social rent units is also welcome.

40 The floor plans show that for development zone A (detailed application), the affordable units will be located within the north and north-west portion of the building from first to ninth floors; within zone B, across both buildings on floors 1-5; and for zone C within the north and north-west portion of the building on floors 1-9. There is an adequate spread of affordable units across the site, and being part of the same perimeter buildings, there will be consistent design quality across tenures, ensuring a tenure blind, mixed community.

Residential quality

41 London Plan policy 3.5, Table 3.3 and Annex One of the Housing SPG set out requirements for the quality and design of housing developments, including minimum space standards for new development. The application documents demonstrate that the minimum floor space and floor-to- ceiling height standards would be met or exceeded, together with compliance with the Lifetime Homes standard, which is welcomed and should be secured by condition.

42 The Mayor’s Housing SPG states that new residential development should generally not provide more than eight units per core, in order to promote a sense of community and ownership over one’s home. In addition, in order to achieve a quality internal environment in terms of light and cross-ventilation, the SPG states that dual aspect units should be maximised and single aspect units facing north should be avoided altogether.

43 The residential quality of the scheme as indicated on the plans raises strategic concern, with there being a very high proportion of single aspect units and in many cases in the region of 20 or more units per core. This is discussed in greater detail in the urban design section of this report.

44 Private amenity space will be provided for each unit by way of balconies with shared podium amenity space in addition to a public realm area to the south, which is supported.

page 12

Density

45 London Plan policy 3.4 requires development to optimise housing output for different locations taking into account local context and character, design principles set out in London Plan Chapter 7 and public transport capacity. Table 3.2 provides the density matrix in support of this policy. Based on the characteristics of the location set out in paragraphs 5-8, the site can be regarded as being on the cusp of a ‘central’ and ‘urban’ setting. The immediate area is predominantly characterised by high-density development with some tall buildings, is within 800m of a Major town centre (Canary Wharf), although the character becomes a lot more ‘urban’ just to the north. It is important to consider the emerging context as well when considering what density and setting is appropriate, including schemes at Blackwall Reach and Leamouth Peninsula.

46 For a ‘central’ setting with a PTAL rating of 4, the matrix suggests a residential density in the region of 650-1,100 habitable rooms per hectare.

47 The application documents confirm that the scheme has a density of 1,173 habitable rooms per hectare. It therefore falls just outside of the ‘central’ range. While the policy seeks to optimise housing output and realise the optimum potential of sites, it also acknowledges that the density matrix should not be applied mechanistically, as other factors such as the surrounding context, layout and residential quality will also inform the appropriate density range. The emerging context suggests that such a density is appropriate to the setting, and certainly the generous proportion of public open space included within the scheme is to be commended. However, as noted in paragraph 43, there are strategic concerns with the residential quality of the scheme, which gives an indication of overdevelopment and this is discussed in greater detail in the urban design section.

48 In addition, whilst it is recognised that the emerging character of the area may be suitable for high-density developments, as set out in paragraphs 29 and 30 of this report, there is strategic concern regarding the need to address potential barriers to the delivery of high density housing within the Isle of Dogs. The applicant should be mindful of the strategic priority, as established in London Plan Policy 3.4, paragraph 1.3.41 of the Mayor’s Housing Supplementary Planning Guidance with regard to high-density development, which states that “such proposals must also be assessed in terms of their bearing on the capacity of existing local amenities, infrastructure and services to support the development”. It is also important, as set out in the Mayor’s SPG, that high density proposals be tested rigorously with regards to their contribution to local place shaping.

49 The provision of social infrastructure is critical, and consequently further discussions with the applicant and the Council are required to ensure that the development appropriately mitigates its density and contributes appropriately to the delivery of necessary social infrastructure.

Children’s play space

50 Children and young people need free, inclusive, accessible and safe spaces offering high- quality play and informal recreation opportunities in child-friendly neighbourhood environments. Policy 3.6 of the London Plan states that development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.

51 Applying the methodology within the Mayor’s Play and Informal Recreation SPG (2012), and based on the unit types and tenures set out in table four, the development will generate a child yield of 326 children requiring approximately 3,261 sq.m of playspace – 1,271 sq.m of which is required as doorstop playspace for the under-five age group, 1,142 sq.m for 5-11’s and 880 sq.m for the 12+ age group. These figures differ quite significantly from those quoted in the applicant’s planning statement where it is suggested that a far lesser amount is required (which it is

page 13 also noted doesn’t include a figure for the under-five’s). Clarification is required on this matter. The design and access statement confirms that 19,139 sq.m of public realm open space will be provided including the new East India Park and pedestrian priority circulation space. Two indicative play areas are indicated in the park space with a further two indicated within the shared resident’s amenity garden within the perimeter block podiums. It is unclear however how much space would realistically be dedicated to safe children’s play. There are relatively few local parks and recreation spaces in the vicinity of the site, and the majority are accessed via relatively unfriendly pedestrian routes. Further detail is therefore required on the strategy for addressing the needs of the different age groups. This is a crucial aspect of the scheme’s residential quality and social sustainability, given the proposed density and high child population, which must be adequately addressed before the scheme is referred back to the Mayor at Stage two. Urban design

52 The design of the proposed scheme has been discussed extensively at pre-application stage, and officers set out that the overall layout and height of the scheme could be acceptable subject to a strong set of design codes that secure a very high residential quality and an active public realm, given the high density. Officers are concerned that the proposed design codes are not robust enough to secure these aspects of the design, and the indicative plans illustrate a scheme which would not be in line with the aspirations of the Mayor’s draft Housing SPG.

53 The applicant is advised to reconsider the residential quality section of the design codes to better reflect the draft Housing SPG. Officers do not consider that the five bullet points in the Design Codes document are sufficient to secure the quality necessary for a development of the 1,357 units proposed. It is particularly important to set out the need to limit the number of units that can access each core on each floor to eight, and limit the number of single aspect units to below 50% on the lower floors. This can be achieved by designing in dual aspect through units at the end of each corridor, which should be illustrated in the indicative plans. Clear floor to ceiling heights should also be set to no less than 2.6m for at least 80% of the floor area, as should the maximum depth for residential units. The minimum width for communal circulation corridors should be set at 1.8m and there needs to be an explicit promotion of naturally lit and ventilated cores. Given the scale and density of the proposal, these and other aspects that ensure residential quality need to be simply and clearly stipulated in the design codes, illustrated in the indicative plans and adhered to in the detailed aspects of the application. Further work on all of this is required for the schemes design to be acceptable. This concern is compounded by the fact that the detailed proposals for development zone A fail to include the residential quality measures noted above, and communicated at the various pre-application meetings.

54 The ground floor layout of the scheme is generally welcome in both the indicative drawings and the detailed section of the submission. However, a clearer stipulation is required on the extent of inactive frontages and how these will be distributed throughout the scheme. This should include a maximum percentage, maximum continuous length, and a requirement to have main entrances at specified distances from each other.

55 These aspects need further work for the schemes overall design to be considered acceptable. The applicant is advised to work with GLA officers to address these issues before the application is referred back to the Mayor at stage two. If these issues are not addressed, GLA officers would not recommend support of the scheme to the Mayor.

56 Notwithstanding the concerns above, as advised at pre-application stage, GLA officers are broadly satisfied with the overall height, layout and massing of the scheme, which has the potential to deliver a high quality scheme with a generous and active public realm. The site is not subject to any strategic views and is in an area undergoing significant change where it has been established that high densities and tall buildings can be accommodated. The composition of the towers, the

page 14 indicative architectural treatment and the way in which the buildings hit the ground and animate the streets is promising, and will be subject to more detailed local scrutiny by the Council.

Heritage

57 The site is bound by a Grade II listed naval wall that runs from the north-west tip of the site following its boundary down the south-east where it meets the East India DLR station. This wall historically formed the perimeter of the East India Docks and now marks the edge of the Naval Row conservation area. Naval Row takes its name from a small terrace constructed in c.1782. Although the last of the original houses was demolished in 1945, the southern edge of the street is lined with historic buildings of interest including the listed hydraulic pumping station, now in residential use. It is the group value of these buildings and the naval wall which is safeguarded by the conservation area designation.

58 The wall will be predominantly preserved by the proposals, although some alterations are proposed to it at the south-west corner of the site. The existing doorway access points through the wall are not optimally positioned for local permeability and the proposals include interventions to improve this situation by closing an existing entryway and creating two new openings with a gentle ramp in the line of sight from Poplar High Street into the site and beyond to East India DLR station. The architects have investigated a number of options for how best to achieve this opening whilst preserving the integrity of the wall, and GLA officers are satisfied that this approach is most suitable. Inclusive design

59 The aim of London Plan Policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and inclusion. Inclusive design principles if embedded into the development and design process from the outset help to ensure that all of us, including older people, disabled and deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity.

Residential units

60 The design and access statement generally demonstrates how the development responds to the principles of inclusive design, in terms of access points, thresholds, levels and routes and includes typical floor plans showing how the design of the residential units meets the Lifetime Home standards. However, neither the design and access statement nor the planning statement confirms the number of units that will be designed to be wheelchair accessible/adaptable. This should be confirmed before the application is referred back at stage two, and a plan included showing where these units will be located and what unit types will be provided.

Marketing

61 The future marketing of the private wheelchair accessible homes should ensure that prospective purchasers are aware of the accessibility and adaptability of these units. Specific marketing to the disabled community and to older people’s organisations can help to ensure that the people who will benefit from their accessible design are made aware of their existence.

Public realm

62 Extending the Lifetime Homes concept to the public realm can help to ensure that the parking areas, the routes to the site and links to adjacent public transport and local services and facilities are also designed to be accessible, safe and convenient for everyone, particularly disabled and older people.

page 15 63 The design and access statement includes details showing how disabled people access each of the entrances safely, and includes adequate information on levels, gradients, widths and surface materials of the paths and how they are segregated from traffic and turning vehicles etc, and how any level changes on the routes will be addressed. The access statement also details how wheelchair users will access the podium level amenity space on level one.

64 The access statement notes that the site is generally level, with little change across the site. However, of the four key entry points, one involves opening a new access point through the Grade II Listed Naval Row wall, and comprehensive details of the strategy of this access are included. Steps are currently located at this corner to provide access to the site and pedestrians or cyclists requiring step free access currently walk along Naval Row to the level access point further east. Through various pre-application meeting it is clear that the applicant has investigated various means of gaining suitable access whilst conserving the historical integrity of the listed wall. It was concluded that a ramp would be impractical, as the length required necessities a large number of ramps or switchbacks. The current proposal includes the retention of steps at this point, with the addition of an external lift. Access will then be provided along Naval Row, as is currently the case with a gentle ramp within the site to deal with the remaining one metre level difference. This is a suitable compromise between ensuring access for all whilst ensuring the historical integrity of the wall and the character of the south-west corner of the site.

Parking

65 The application documents confirm that 155 car parking spaces will be provided, 111 of which are for disabled users. Whilst this is welcome, as noted in paragraph 57, GLA officers require further details of the number of wheelchair accessible/adaptable units to be provided in the scheme to determine whether the blue badge parking provision is acceptable. The applicant is required to indicate which spaces will be designed to be accessible and include a plan showing the location of these spaces to ensure travel distances have been minimised to the corresponding wheelchair units.

66 The provision and future management of the blue badge parking bays for the residents should be in line with the advice in the Lifetime Homes standards and the Wheelchair Housing Design Guide. A parking management plan should identify how bays will be allocated to residents of the wheelchair accessible units and should include a mechanism to ensure that the supply and demand of the blue badge bays are regularly monitored and the provision reviewed. This ensures that the provision going forward equates to the demand from disabled residents and visitors, and also ensures that the bays are effectively enforced. Flooding

Flood risk

67 The site is within Flood Zone 3a and a Flood Risk Assessment has been submitted with the application conducted by Odyssey Markides. The FRA confirms that the site is within Flood Zone 3a but that the finish floor levels of the ground floor will be above the flood level estimated up to 2100 and that the ground floor will be constructed using flood resilient materials/techniques. While this is welcomed, the FRA does not appear to consider how the risk to the basement levels will be managed, including whether there are potential impacts on the utilities servicing the buildings. If such utilities are located at basement level, they should be designed to remain operational during any flood by ensuring that they are flood proof or located within a flood proof enclosure/room.

Sustainable drainage

page 16 68 The FRA sets out that the drainage strategy will be to ensure that the redevelopment achieves a 3 x greenfield run-off rate. This will be achieved through green roofs and tanked attenuation with flow limiting discharges.

69 Given the nature and location of the proposals, this approach is compliant with London Plan Policy 5.13 on sustainable drainage and should be secured via an appropriate planning condition. Air quality

Construction phase

70 Dust and emissions during the construction phase have been assessed using the Institute of Air Quality Management (IAQM) guidance. There was found to be a high risk of construction dust effects and mitigation measures are recommended accordingly. However, the London emission standards for non-road mobile machinery (NRMM) were not discussed, and it is recommended that these should be applied.

Operational phase

71 The development is predicted to result in a reduction in vehicular traffic in the vicinity of the site. The CHP and eight boilers proposed as part of the scheme are predicted to increase the annual mean nitrogen dioxide (NO2) concentration by up to 4 μg m-3. These impacts are considered to be moderate adverse in the Environmental Statement (ES). However, the ES chapter was produced before the new IAQM guidance “Land-Use Planning and Development Control: Planning for Air Quality” was published. Had the significance criteria in this guidance been used, the development would have been predicted to have significant adverse impacts. It should therefore be clarified whether Appendix 7.7 includes emission velocities or volumetric flow rates.

72 Due to the emissions from the CHP and boilers, the development building emissions are predicted to be over ten times the relevant air quality neutral benchmark. The development is also predicted not to be air quality neutral for transport emissions. It is therefore recommended that measures to reduce the impact of the boiler/CHP emissions, so that the development is air quality neutral for building emissions, are provided by the applicant. Further mitigation or off-setting should also be considered with respect to transport emissions. Climate change mitigation and adaptation

Overview of proposals

73 The applicant has broadly followed the energy hierarchy and submitted sufficient information to understand the proposals as a whole. Further revisions and information are required in order to verify the carbon savings claimed and ensure compliance with London Plan Policies.

Energy efficiency standards

74 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by Building Regulations. Other features include low energy lighting and mechanical ventilation heat recovery.

75 The demand for cooling will be minimised through external shading from balconies and solar control glazing. The applicant has undertaken a dynamic overheating assessment following CIBSE TM52 and TM49 guidance, including using future weather files. The assessment

page 17 demonstrates that the CIBSE criteria can be met for current and potential future climate conditions. The applicant should provide details of the ventilation strategy for single storey ground floor units (where windows will unlikely be open at night due to security concerns) and whether these dwellings are also expected to meet the CIBSE criteria.

76 The development is estimated to achieve a reduction of 153 tonnes per annum (9%) in regulated carbon dioxide (CO2) emissions compared to a 2013 Building Regulations compliant development.

District heating

77 Following discussions with the local authority the applicant has investigated connection to the Excel district heat network (DHN), approximately 1.5 miles from the site, connection to neighbouring buildings and the potential for using waste heat from the neighbouring data centres. The applicant has contacted Excel about the expansion although no details of the network expansion have been provided. The applicant should confirm the timescales for the potential network expansion as currently understood. The applicant has also contacted the neighbouring site (Blackwall Reach/Robinhood Gardens) and provided heat load information to the energy consultant. At this stage there is no confirmation of whether the energy centre can accommodate the additional loads from the application site. The applicant will, however, continue to investigate connection opportunities as the design progresses. Evidence of correspondence so far has been provided.

78 The applicant has also provided a commitment to ensuring that the development is designed to allow future connection to a district heating network should an alternative one become available and community connection to Excel DHN/Blackwall Reach not be possible.

79 While the installation of a site heat network is welcome, the applicant should confirm that all apartments and non-domestic building uses will be connected to it, and provide a drawing showing the route of the heat network linking all buildings on the site. The site heat network will be supplied from a single energy centre and will be located in the basement of phase one which is acceptable.

Combined heat and power (CHP)

80 Should connection to the Blackwall Reach energy centre not prove feasible then the applicant is proposing to install a 740 kWth gas fired CHP unit as the lead heat source for the site heat network. The CHP is sized to provide the domestic hot water load, as well as a proportion of the space heating (75% of the total heat load). A reduction in regulated CO2 emissions of 529 tonnes per annum (32%) will be achieved through this second part of the energy hierarchy.

Renewable energy technologies

81 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 143kWp of photovoltaic (PV) panels on the roof of the development. An indicative roof layout plan demonstrating the proposed location the panels has been provided. A reduction in regulated CO2 emissions of 64 tonnes per annum (4%) will be achieved through this third element of the energy hierarchy.

Overall carbon savings

82 A reduction of 746 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected, equivalent to an overall saving of 45%. The carbon dioxide savings exceed the target set within Policy 5.2 of the London Plan, although

page 18 the comments above should be addressed before compliance with London Plan energy policy can be verified. Transport for London

Car parking

83 There are currently 245 basement spaces on site and the applicant is proposing up to 111 blue badge only spaces and 44 general spaces to accommodate vehicles under the Council’s permit transfer scheme (PTS). A further five car club parking spaces will be provided at street level.

84 56 of the blue badge spaces will be provided at first occupation during phase 1. The implementation of the remaining 55 will be considered with the Council as the latter phases of the application are progressed. The existing basements will be retained and therefore TfL requests clarification on how the remaining basement will be used should the other 55 blue badge spaces not be implemented.

85 Whilst the quantum of parking is acceptable in strategic terms, TfL require confirmation that 20% of all spaces will be fitted with active electric vehicle charging points (EVCPs) with an additional 20% of spaces fitted with passive infrastructure in accordance with London Plan Policy 6.13. TfL also welcomes that a car parking management plan is proposed and this should be secured by planning condition.

Cycle parking

86 A total of 476 cycle parking spaces will be provided for phase 1, located below the podium amenity space, although this area can accommodate up to 914 cycle spaces. Accordingly, a proportion of cycle parking for the latter phases will be located within the phase 1 cycle parking area. The distance between the cycle parking and the occupiers of those phases will need to be clarified as TfL would discourage any proposals which would locate cycle parking remotely from the end user.

87 Any cycle parking provided should be in accordance with the London Cycle Design Standards and shower and changing and facilities are required for all staff employed on site.

Impact assessment

88 The applicant has undertaken a multi-modal impact assessment; however TfL considers the methodology adopted to be flawed and has recommended amendments in separate detailed advice to the Council.

Walking and public realm

89 TfL welcomes that the layout of the proposed development will improve permeability through the area, however, to assist with wayfinding TfL recommends that the Council allocate appropriate CIL funding towards the provision of Legible London signage in accordance with London Plan Policy 6.10.

Buses

90 Upon receipt of a revised impact assessment, TfL may request the provision of additional capacity on the local bus network. The applicant is proposing to remove the bus route through the site and replace it with a turning circle and stop to the east on Saffron Avenue/

page 19 Lane. TfL has no objection to this in principle, although the applicant should confirm what the impact of these proposals will be on the existing bus standing facilities on Saffron Avenue as visibility may be a concern.

91 Given the proposed changes, this presents an opportunity to improve bus standing facilities and accordingly TfL requests bus driver toilets are provided. Such facilities would need to be provided at a peppercorn lease to TfL and this needs to be discussed further and secured appropriately within the section 106 agreement.

92 The applicant should confirm within which development phase the turning facility and bus stop will be delivered. Furthermore, a condition should be imposed requiring detailed design of the facility to be agreed in consultation with TfL, before implementation. In addition, TfL requires the turning facility and bus stands to be provided before the loss of the existing turning facility.

Cycling

93 Cycle access to the site will be from cycle superhighway CS3. New signage and blue paving markers are proposed to raise awareness of the route which is supported in principle, however further clarification is required on whether the routing will be altered.

94 To minimise conflict with vehicular traffic, TfL requests that a segregated two way route is provided running from Naval Row to the proposed bus turning facility; a right turn lane should then run adjacent to the traffic island onto Saffron Avenue. TfL would expect the amendments to CS3 to be secured by condition and no existing infrastructure should be lost until a new route is provided.

95 Notwithstanding this, TfL are undertaking a feasibility study on the provision of a cycle ramp at the south-west corner of the site. This would allow CS3 to be re-routed from the current alignment to run adjacent to the Blackwall Tunnel Approach and East India Dock Road. This work is ongoing and TfL will update the applicant on timescales once known. Following completion, the proposals may need to be modified to accommodate that re-routing. Should this not prove feasible then TfL would expect the two-way cycle route outlined above to be implemented.

DLR

96 Before TfL can consider the impact on the DLR network, the trip assessment should be revised in accordance with TfL’s recommendations.

Cycle hire

97 The local cycle hire network is well utilised and therefore upon receipt of a revised trip assessment TfL may request funding towards the provision of additional cycle hire capacity in accordance with London Plan Policy 6.9.

Travel planning

98 TfL supports the submission of a framework travel plan and it is welcomed that individual travel plans will be prepared for each of the respective land uses post consent. The travel plans and all agreed measures therein should be secured, enforced, monitored and reviewed as part of the section 106 agreement.

Freight

page 20 99 All loading and unloading activity of delivery and servicing vehicles associated with the proposed development would take place off-street and this is supported. A framework delivery and servicing plan (DSP) has been provided and reviewed and TfL consider the content to be acceptable. The final document should be secured by condition.

100 A framework construction logistics plan (CLP) has been provided which is welcome, and TfL would expect the full document to be secured by condition. Further discussion is required however on the impact on CS3 during the construction period as additional infrastructure may be required to minimise conflict between freight traffic and cyclists.

Crossrail and CIL

101 The site falls within the 1km charging zone of Canary Wharf station, where section 106 contributions for Crossrail will be sought in accordance with London Plan Policy 6.5 and the Mayor’s guidance ‘Use of planning obligations in the funding of Crossrail, and the Mayoral Community Infrastructure Levy’ SPG (2013). However, as there is a net loss of chargeable floorspace TfL can confirm that no contribution is required. The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly policies 6.5 and 8.3 toward the funding of Crossrail. The rate for the borough of Tower Hamlets is £35 per square metre. Local planning authority’s position

102 The applicant has had a programme of pre-application meetings with Tower Hamlets Council officers, and it is understood that the principle of the scheme is broadly supported. The Council’s formal position on the planning application is unknown at this stage.

Legal considerations

103 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

104 There are no financial considerations at this stage. Conclusion

105 London Plan policies on land use principles, housing, urban design, inclusive access, flooding, sustainable development and transport are relevant to this application. The application does not comply with these policies and cannot be supported in principle at this stage.

page 21 Further information is needed in order to fully comply with the London Plan. The potential remedies to issues of non-compliance are set out below:

 Land use principles: There is no strategic concern to the loss of offices in this location, and the mixed use nature of the scheme including the provision of residential units, retail, leisure and flexible B1 workspace is supported. Further discussion required on social infrastructure mitigation to support the principle of high density development.  Housing: While the indicative affordable housing offer of 25% is welcome, together with the tenure split and the inclusion of PRS units in the private element, the applicants’ viability appraisal needs to be independently verified in order to confirm that the maximum reasonable amount of affordable housing will be delivered. Further detail is also required on rent levels and a review mechanism is required given the phasing. Given the high density, further discussion is required with the applicant and the Council to ensure social infrastructure is considered to support the density and mix of uses proposed.  Urban design: While the layout, massing, height and inclusion of generous amount of public realm are all supported, the residential quality and the provision of children’s play space raises significant concern and this must be addressed before stage two given the high density nature of the scheme. The heritage impact is acceptable.  Inclusive access: Broadly acceptable subject to conditions and confirmation on the number of wheelchair accessible units to be included, their location and relationship with blue badge parking spaces.  Flooding: Broadly acceptable subject to conditions, and confirmation of how the basement areas will remain safe in respect of the residual flood risk to the site.  Air quality: Further information required in relation to: the London emission standards for non-road mobile machinery (NRMM) and clarification on whether Appendix 7.7 includes emission velocities or volumetric flow rates; measures to reduce the impact of the boiler/CHP emissions so that the development is air quality neutral for building emissions, and; further mitigation or off-setting should also be considered with respect to transport emissions.

 Climate change: A reduction of 746 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected, equivalent to an overall saving of 45%. The carbon dioxide savings exceed the target set within Policy 5.2 of the London Plan, although the comments above should be addressed before compliance with London Plan energy policy can be verified.  Transport: TfL does not consider the applicant’s impact assessment to be sufficiently robust and requests that this is re-submitted in accordance with TfL’s advice. Upon receipt, TfL may request mitigation on the local public transport network. In addition, conditions are required to secure details of CS3 and bus standing, stopping and turning facilities. In addition, a DSP, CLP and travel plans should be secured by condition or section 106 agreement as appropriate. for further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email: [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email: [email protected] Natalie Gentry, Senior Strategic Planner – Case officer 020 7983 5746 email: [email protected]

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