planning report D&P/4056/01 7 August 2017 Land at Store Road, North in the planning application no. 17/02106/FUL

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 Proposed development of 163 residential units (comprising 3 houses and 160 flats) up to 15 storeys; associated access, servicing, parking, amenity space and landscaping.

The applicant The applicants are The Hyde Group and Galliford Try, and the architect is BPTW.

Strategic issues summary Land use principle: high density residential development of this vacant site in the and Riverside Opportunity Area is strongly supported. (paragraphs 12-13) Affordable housing: no affordable housing is proposed without public subsidy, which is wholly unacceptable. GLA officers will therefore work with the Council to robustly scrutinise the viability assessment to ensure that the maximum reasonable contribution is secured. Early implementation and late stage review mechanisms should be secured through the S106 agreement, as required by the Mayor’s draft Affordable Housing & Viability SPG. (paragraph 15) Urban design and heritage: the approach to layout, height, massing and residential design is supported as part of this high density residential scheme, and there would be no harm to the setting of heritage assets. (paragraphs 19-22) Flood risk: the applicant should demonstrate how a suitable flood warning system will alert residents and investigate discharging surface water directly into the . (paragraph 24) Climate change: further information regarding overheating, the energy centre and renewable energy is required, and the final agreed energy strategy should be secured by the Council, along with S106 obligations for off-site mitigation. (paragraphs 25-26) Transport: the applicant should reduce car parking to 0.4 ratio. (paragraphs 27-30)

Recommendation That Newham Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 34 of this report. However, the resolution of those issues could lead to the application becoming compliant with the London Plan.

page 1 Context

1 On 6 July 2017 the Mayor of London received documents from Newham 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 16 August 2017 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 the following Categories 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 1C: Development which comprises or includes the erection of a building more than 30 metres high and outside the City of London.

3 Once Newham 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 a roughly rectangular vacant piece of land of approximately 0.38 hectares. The site is surrounded by similar underused/vacant brownfield land, part of which is in use as a Crossrail compound. The site is bound by Pier Road on its southern edge with the River Thames beyond, Store Road on its western edge, TfL highway land adjoining to the east and a Thames Water pumping station to the north. The wider residential neighbourhood extends further north, with the Thames Road and Standard Industrial Estates characterising the land to the west.

6 As well as being within the Royal Docks and Beckton Riverside Opportunity Area, the site also falls within the Safeguarding Zone. It is also close to the northern access to the Woolwich foot tunnel and ferry providing links south of the river. A number of heritage assets are located close to the site, including the Grade II listed entrance to Woolwich Foot Tunnel and former railway station.

7 In terms of transport, King George V is the nearest station, on the (DLR), approximately 550 metres walk to the north of the site, which provides a link to the London Underground Jubilee line at and National Rail services at Woolwich Arsenal. There are bus stops adjacent to the site served by two routes – 473 and 474. Pier Road forms part of the Transport for London Road Network (TLRN) for its importance for the route to / from the . The site records a poor public transport accessibility level (PTAL) of 2 on a scale of 1-6, where 6 is the highest.

Description of development

8 It is proposed to redevelop the site for a wholly residential development of 163 units. The scheme would comprise a perimeter block with two taller elements of 12 and 14 storeys linked by a 7 storey block fronting Store Road and 2 storey mews houses addressing the eastern boundary. Car

page 2 parking would be concealed within a podium with a residential amenity courtyard above, with vehicle access from Store Road. Case history

9 There has been no history of referable planning applications on this site, but the scheme currently under consideration was the subject of pre-application discussions in September 2016 (D&P/4056). GLA officers supported the land use principles and the approach to design, mass and architecture, but requested further work on the ground floor layout, public realm, affordable housing, play space, energy, transport and inclusive access. Strategic planning issues and relevant policies and guidance

10 The relevant issues and corresponding policies are as follows:

• Opportunity Areas London Plan; draft OAPF • Housing and affordable housing London Plan; Draft Affordable Housing & Viability SPG; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG; • Urban design and heritage London Plan; draft OAPF; Character and Context SPG; • Inclusive design London Plan; Accessible London: achieving an inclusive environment SPG; • Sustainable development London Plan; Sustainable Design and Construction SPG; • Transport and parking London Plan; Crossrail SPG

11 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Newham Core Strategy (2012) and Detailed Sites and Policies DPD (2016), along with the 2016 London Plan (Consolidated with Alterations since 2011). Also relevant is the working draft Royal Docks & Beckton Riverside OAPF (2016). The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework are also relevant material considerations. Land use principle

12 The site is located within the Royal Docks and Beckton Riverside Opportunity Area (OA) as designated by London Plan. The OA has an indicative capacity of 6,000 new jobs and a minimum of 11,000 new homes over the plan period to 2036. London Plan Policy 2.13 states that development in Opportunity Areas is expected to maximise residential and non-residential densities and to contain a mix of uses. London Plan Policy 3.3 seeks to increase London’s supply of housing and in doing so sets borough housing targets, of which Newham’s annual target is 1,994 additional homes per year between 2015 and 2025, which the proposals will contribute to. Newham’s Detailed Sites and Policies DPD allocates this site for housing.

13 As this is a vacant brownfield site with an allocation for housing within an OA, its redevelopment to provide a high density residential development is strongly supported in principle. Given the relatively remote location within walking distance of an existing small local centre, it is unlikely to be a viable location for retail or commercial uses. As such, a wholly residential scheme is considered to be an appropriate response and this is supported.

page 3 Housing

Housing mix

14 The proposed residential mix is set out in the below table. The scheme would prioritise affordable family housing, which is supported in line with London Plan Policy 3.8.

unit type market sale affordable rent shared total % ownership studio 5 - - 5 3 1 bed 23 15 12 50 31 2 bed 53 7 - 60 37 3 bed 17 23 8 48 29 total 98 45 20 163

Affordable housing

15 The application proposes 65 affordable units, which is equivalent to 40% of the total number of units and 44% of the habitable rooms within the scheme. The tenure split is 70:30 in favour of affordable rent. The applicant has advised that this offer is contingent upon receiving grant funding and that the scheme would not be able to deliver any affordable housing without grant. Given the high density nature of the scheme on a vacant site with a low existing use value, the absence of any affordable housing without public subsidy is wholly unacceptable. The use of a market value assessment to generate a benchmark land value for the site is contrary to guidance in the Mayor’s draft SPG and is a significant concern. GLA officers will robustly interrogate the applicant’s viability assessment in conjunction with the Council to ensure that the maximum reasonable affordable housing contribution is secured. Early implementation and late stage review mechanisms should be secured through the S106 agreement.

Density

16 The scheme has a density of 429 units per hectare and 1,387 habitable rooms per hectare. As described above, the site is currently within a part of the Royal Docks with a relatively undefined character, as it falls between industrial land and residential neighbourhoods. Through the draft OAPF however, it is envisaged that this part of North Woolwich be regenerated as an extended residential hinterland, given its good transport accessibility with the DLR and Woolwich foot tunnel/ferry in close proximity, and within walking distance of a local centre. In its current form, the setting is considered to be ‘urban’ based on the definitions of London Plan Policy 3.4, for which the density matrix suggests a residential density in the region of 200-450 habitable rooms per hectare. However, given the location within an Opportunity Area where densities are expected to be optimised, the future context could be described as ‘central’, where densities up to 650 habitable rooms per hectare are suggested.

17 It is noted that this scheme exceeds the guidance density ranges, even for a high PTAL location. However as noted above, the site is within an Opportunity Area where residential and non- residential densities should be optimised, alongside continuing improvements to public transport. The accessibility of the area will improve significantly with the upgrades programmed to the DLR and the arrival of Crossrail at Custom House. There is therefore no strategic objection to the proposed density in this location. However, as noted in the Mayor’s Housing SPG where high densities are accepted as being appropriately located, schemes will need to be of the highest design quality and this is discussed in more detail in the urban design section of this report.

page 4 Children’s play space

18 The proposals include appropriate provision for children’s play space to meet the requirements of the Mayor’s Providing for Children and Young People’s Play and Informal Recreation SPG for under-12s, which is welcomed. The requirements for 12+ years will be accommodated in nearby parks and the Council should ensure that the application makes an appropriate contribution, if appropriate. Urban design and heritage

Layout

19 The simple C-shaped podium perimeter block layout maximises the opportunities to provide strong edges, enclosure to the street and active frontages through individual ground floor entrances, which is supported. The scheme addresses site level changes well and the applicant has responded positively to comments made at pre-application stage in relation to the siting and extent of the vehicle access, bin stores and residential entrances, which is welcomed. The introduction of a low rise mews typology facing the eastern boundary is well considered and will ensure that the scheme appropriately addresses the adjacent vacant site, allowing the flexibility for this to come forward for development or public realm. The scheme layout is of the highest quality and is therefore supported.

Height, massing and architecture

20 The application proposes varied building heights, with two point blocks of 12 and 14 storeys in the north-east and south-west corners respectively, linked by a 7 storey block fronting Store Road. A 2 storey mews of houses completes the perimeter block along the eastern boundary, allowing good light and ventilation into the central amenity courtyard. The siting of the tallest element on the corner of Store Road and Pier Road, opposite the ferry slip road, is well reasoned. The building would incorporate a restrained palette of materials, with two contrasting brick tones, metal balustrades and punched metal panels at ground floor. The approach to elevational treatment is supported, although the simplicity of the design will be reliant on the use of the highest quality materials and detailing. The Council should therefore ensure that these are appropriately controlled by condition.

Heritage

21 The application proposes development which could affect the setting of two listed buildings, the former North Woolwich Railway Station and Woolwich Foot Tunnel entrance (both Grade II listed). These modest buildings are both constructed of red brick and reference the Victorian and Edwardian development of the area. Verified views have been submitted which confirm that the development would be visible in the setting of these two buildings. The scheme would be visible in the background in some views towards the station and above the foot tunnel entrance. However, the high quality of architecture and contrasting grey brick would ensure that the listed buildings are still read as distinct features and the new development would provide an appropriate backdrop to what are essentially urban buildings. As such, having applied the statutory tests for dealing with heritage assets set out in the Planning (Listed Buildings and Conservation Areas) Act 1990 and the guidance in the NPPF, GLA officers consider, having special regard to the desirability of preserving the listed building’s setting, that the proposal preserves the setting of both listed buildings. Furthermore, in views over the river from the Royal Arsenal Conservation Area, the scheme would be seen in the context of other similar sized buildings and in view of the significant separation distance the character and appearance of the Conservation Area would be preserved. As such there would be no harm to the setting of heritage assets as a result of the proposal.

page 5 Residential quality

22 The residential layouts maximise dual aspect flats, with no single aspect north facing units, and ensure that the units overlooking the Thames Water pumping station have their principal aspect to the east and west. All units would meet or exceed the national space standard requirements, as well as the private amenity space requirements of the Mayor’s Housing SPG. There would only be two cores within the scheme, meaning that on the second to fifth floors each core would effectively serve nine units. However, the five units in the 7 storey link block would be accessed from an open deck that is connected to each of the cores. All of these units would be dual aspect and a sense of ownership would be created in light of the separation from the main cores. The residential quality of the scheme is therefore considered to be high. Inclusive design

23 In relation to the residential units, a commitment has been made to design all the new homes to meet the Building Regulations M4(2) standards and at least 10% to meet the M4(3). The accessible units are split between floors, unit type and tenure to maximise choice for disabled people. The design of the public realm, circulation and amenity spaces within and around the scheme has been well considered having regard to the site levels changes and would provide gently sloping routes and level access to buildings, which is supported. Flood risk

24 The site is within Flood Zone 3 although is protected by the Thames Tidal Flood Defences. Whilst the failure of these defences during an extreme tidal storm event is considered unlikely, there is a residual risk that a breach or overtopping of the defences could result in flooding on the site. The strategy for dealing with a breach event is to evacuate residents above ground floor level and therefore above the maximum flood level. Duplex units are proposed on the lower floors to enable this. There is however a concern that the Environment Agency flood warning system would not be appropriate and the applicant should demonstrate how a flood warning will be delivered to occupants of the scheme. It is proposed to discharge surface water from the scheme into the Thames Water sewer. Given the proximity to the River Thames, the applicant should investigate the potential to discharge directly into the river. If it is necessary to discharge into the sewer, further details should be provided on the extent of green roofs and volume of storage associated with these elements, along with maintenance information for SUDS features. Climate change

25 A range of energy efficiency measures are proposed. An overheating analysis should be carried out and the applicant should set out measures taken to avoid overheating and minimise cooling demand. The applicant has identified the Royal Docks district heating network within the vicinity of the development and has designed the development to enable future connection. The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install photovoltaic panels. This is welcomed, but the applicant should demonstrate that roofspace has been fully utilised for this purpose.

26 An on-site reduction of 66 tonnes of carbon dioxide per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected. This is equivalent to an overall saving of 35%. The carbon dioxide savings fall short of the zero-carbon target within Policy 5.2 of the London Plan. The applicant should make an appropriate contribution to the borough’s carbon offset fund through the S106 agreement.

page 6 Transport

Trip generation

27 The assumptions in the Transport Assessment (TA) are considered reasonable. Approximately 72% of trips will be via public transport and almost 19% will be by car. No adverse impacts on the capacity of local public transport services are expected and the scheme is considered compliant with London Plan policy 6.3.

Car parking

28 A total of 70 car parking spaces will be provided on site, 17 of which will be Blue Badge in accordance with London Plan standards. The proposed parking ratio is 0.42 spaces per unit, should be reduced to 0.4 in accordance with London Plan policy. A parking permit restriction should be secured through the S106 agreement. The provision of Electric Vehicle Charging Points (ECVPs), including those for Blue Badge spaces, should be secured by condition to meet London Plan standards.

Cycling and walking

29 A total of 271 long stay and 5 short stay cycle spaces will be provided as part of the application. The spaces have been spread out across the application site and will provide convenient access to cycle parking for residents, which is supported. The cycle parking arrangements are in accordance with London Plan’s minimum standards.

Travel planning, construction and delivery management

30 A full construction logistics plan, delivery and servicing plan and parking management plan should be secured by condition. In accordance with London Plan Policy 6.3 a travel plan and all agreed measures therein should be secured, enforced, monitored and reviewed as part of the S106 agreement. Local planning authority’s position

31 The Council are supportive of the proposed design and are in the process of appointing a viability consultant. Legal considerations

32 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

33 There are no financial considerations at this stage.

page 7 Conclusion

34 London Plan policies on Opportunity Areas, housing, urban design, heritage, inclusive design, flood risk, climate change and transport are relevant to this application. The application does not comply with the London Plan, however the resolution of the following issues could lead to the application becoming compliant with the London Plan:

• Affordable housing: no affordable housing is proposed without public subsidy, which is wholly unacceptable. GLA officers will work with the Council to robustly scrutinise the viability assessment to ensure that the maximum reasonable contribution is secured. Early implementation and late stage review mechanisms should be secured in the S106 agreement, in line with London Plan Policy 3.12 and the Mayor’s Draft Affordable Housing and Viability SPG.

• Flood risk: the applicant should demonstrate how a suitable flood warning system will alert residents and investigate discharging surface water directly into the River Thames, in order to comply with London Plan Policies 5.12 and 5.13.

• Climate change: the energy strategy does not fully accord with London Plan Policies 5.2, 5.7 and 5.9. Further information regarding overheating, the energy centre and renewable energy is required. The final agreed energy strategy should be appropriately secured by the Council, along with S106 obligations for off-site mitigation.

• Transport: to ensure that the scheme accords with London Plan policies 6.3, 6.9, 6.13 and 6.14 the applicant should reduce car parking to 0.4 ratio. The provision of electric vehicle charging points, construction logistics plan, delivery and servicing plan, parking management plan and travel plan should be secured by condition or S106 agreement.

for further information, contact GLA Planning Unit (Development & Projects Team): Juliemma McLoughlin, Assistant Director – Planning 0207 983 4271 email [email protected] Sarah Considine, Senior Manager – Development & Projects 020 7983 5751 email [email protected] Shelley Gould, Strategic Planning Manager (Development Decisions) 020 7983 4803 email [email protected] Nick Ray, Senior Strategic Planner, case officer 020 7983 4178 email [email protected]

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