planning report 2450/01 16 December 2009 Sites E, G, I-1 & I-2, Brownfield Estate, Brownfield Street, Poplar Tower Hamlets Council Planning application no. PA/09/02100

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

The proposal The demolition of 30 flats on three sites, and the construction of 144 flats and houses on four sites, including a 20-storey tower, and 150 sq.m of community space, together with associated landscaping

The applicant The applicant is Poplar Harca, and the architect is PRP.

Strategic issues This application is the first phase of an estate renewal, and provides an appropriate level of affordable housing, although further information on viability is required. Density and design is generally appropriate, with a tall building proposed within a conservation area, although there are some outstanding issues regarding appearance, landscaping and children’s play space.

The transport and access strategies are generally appropriate, although more information is sought on disabled, electric vehicle and cycle parking and other matters.

Recommendation That Tower Hamlets Council be advised that while the application is generally acceptable in strategic planning terms, the application does not comply with the London Plan, for the reasons set out in paragraph 79 of this report; but that the possible remedies set out in paragraph 81 of this report could address these deficiencies.

Context

1 On 6 November 2009 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 17 December 2009 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan,

page 1 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 Category 1C of the Schedule to the Order 2008: “Development which comprises or includes the erection of a building of one or more of the following descriptions … (c) the building is more than 30 metres high and is 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 application includes four sites located within Poplar comprising: Site E – Willis Street car park and an adjoining area of landscaped open space (3,400 sq.m.), Site G – Former Builders Arms and bed sits (1,500 sq.m.), Site I-1 – Ida Street (575 sq.m.) and Site I-2 – Follet Street (1,120 sq.m.). Site E on the corner of Burcham and Hay Currie Streets is located north east of the other three sites, which are situated in a cluster around Ida Street. All four sites are corner sites.

6 The sites are within the Brownfield Estate, which is within a regeneration area. The wider area is bounded DLR rail line to the west and the A12 and A13 interchange to the east. Langdon Park DLR station is 150m to the north of the northern site boundary. Surrounding development comprises of residential development typically ranging two to four-storey residential development, however larger residential towers exist further to the east, namely Glenkerry House (fourteen-storey) and Balfron Tower (22-storey). The latter forms part of the Brownfield Estate and is Grade-II listed, and part of a Conservation Area in which the dominant built form was designed in the 1960s by modernist architect Erno Goldfinger. Site E also falls within the Conservation Area, and site G is adjacent to its boundary.

7 There are 7 bus services within 400m of the site and All Saints and Langdon Park DLR stations are also located within reasonable walking distance providing frequent services north to Stratford and south to Lewisham. Due to the size of the development area, the site’s Public Transport Accessibility Level (PTAL) ranges from 2 in the east to 4 in the west, on a scale of 1 to 6 where 1 represents the lowest accessibility level and 6a the highest.

Details of the proposal

8 The proposal seeks to re-develop the aforementioned four sites within the Brownfield Estate as follows:

• Site E – Willis Street car park: A twenty-storey residential block providing 112 flats. There will be 1 x one-bed studio flat (Private tenure) 49 x one-bedroom units (44 private and 5 intermediate), 43 x two-bedroom units (30 private and 13 intermediate), and 19 x three-bedroom units (15 private and 4 intermediate), of which 90 will be for private sale and 22 for intermediate rent. A 150sq.m community space will also be provided on the ground floor. The existing public open space would be renewed.

page 2 • Site G – Former Builders’ Arms PH and bedsits: A part four, part five-storey residential block providing 23 flats and maisonettes, (8 x two-bedroom units, 4 x three-bedroom units, 10 x four-bedroom units and 1 x five-bedroom units), all affordable rent.

• Site I-1, Ida Street: A two-storey residential block providing four 4-bedroom houses, all affordable rent.

• Site I-2, Follet Street: A two-storey residential block providing five houses, (2 x four- bedroom units and 3 x five-bedroom units), all affordable rent.

9 In total the proposal will provide 144 units comprised of the following mix: 32 units for social rent, 22 units for intermediate rent and 90 for private sale. This represents a total of 37% affordable housing tenure by unit and 48.5% by habitable room. The housing mix will be 1 studio unit, 49 x one-bedroom units, 51 x two-bedroom units, 23 x three-bedroom units, 16 x four-bedroom units and 4 x five-bedroom units. There would be a loss of 2 private flats and 28 affordable homes, but a net overall gain of housing.

Case history

10 The proposal represents a revised version of a previous application (PDU/2217) that proposed much larger, regeneration-led development of the area. The application was withdrawn in September 2008 as a direct result of objections to, and comments from Council officers. The principal objections related to the loss of open space at Jollies Green and the height of the proposed Willis Street Tower (22 storeys). The current application does not include all of the development sites as previously proposed and a scheme for Phase 2 is currently being prepared, which will include the refurbishment of Balfron Tower. Design work is progressing on the remaining sites, which will be submitted as separate applications.

11 Pre-application meetings regarding the current application were held with GLA officers in June and October 2009.

Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

• Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, draft Housing Strategy, draft revised housing SPG • Affordable housing London Plan; PPS3; Housing SPG, draft Housing Strategy • Density London Plan; PPS3; Housing SPG • Tall buildings/views London Plan; View Management Framework SPG, draft Revised View Management Framework SPG • Urban design London Plan; PPS1 • Transport London Plan; the Mayor’s Transport Strategy; PPG13 • Parking London Plan; the Mayor’s Transport Strategy; PPG13 • Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Wheelchair Accessible Housing BPG; Planning and Access for Disabled People: a good practice guide (ODPM) • Sustainable development London Plan; PPS1, PPS Planning and Climate Change Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG

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13 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 1998 Tower Hamlets Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004). The Tower Hamlets Core Strategy (pre-submission stage) and draft replacement London Plan are also a material considerations.

Housing and affordable housing

14 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mixed-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements.

15 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified.

16 Where borough councils have not yet set overall targets as required by Policy 3A.9, they should have regard to the overall London Plan targets. It may be appropriate to consider emerging policies, but the weight that can be attached to these will depend on the extent to which they have been consulted on or tested by public examination. Tower Hamlets has set an overall borough target of 25% affordable housing provision in its UDP, and 50% provision within the emerging core strategy.

17 Paragraph 20.3 of the Housing SPG notes that in order for a development to achieve 100% replacement of demolished social rented units, development at significantly increased density may be necessary to generate sufficient value from market development to support replacement of affordable housing provision or to achieve a mixed and balanced community objective. In this instance it is important to note that there will be no net loss of affordable social rented housing.

18 Three of the sites contain homes that will be demolished, incorporating 15 rented studio flats, 13 rented one-bedroom units and 2 private one-bed units. The development will provide 48.5% affordable housing (43.9% once demolition is taken into account). This overall figure is higher than the Council’s current provision. There is a high tenure mix across the estate, and although there will only be no net gain or loss of social rent affordable housing, there will be a gain in the number of habitable rooms. The net gain in the number of affordable units will be intermediate tenure (22 units), and this increase is supported by officers. Additional social rented units will be provided in future phases. Officers wish to inspect the scheme’s viability appraisal with regard to the level of affordable housing provision, as well as the wider benefits proposed by the scheme.

page 4 19 Of the new affordable homes, there will be a tenure split of 60% social rented and 40% intermediate. This split is acceptable and is compliant with the levels recommended within the draft replacement London Plan.

20 The proposed dwelling mix is appropriate and responds to local needs. 20 of the 114 units will be four- or five-bedroom homes. A further 23 will be three-bedroom homes. The combined figure of 43 units represents 38% of unit numbers as family homes.

Density

21 The densities of the site are: Site E (tower): 894 habitable rooms per hectare (hr/ha); site G (flats): 687hr/ha; sites I-1 and I-2 (houses): 223hr/ha. The London Plan density matrix suggests that densities within urban sites with good transport links should be within the range 450-700hr/ha. Problems with density are normally manifested through poor design, and inadequate play space and parking. In this case, the design appears generally appropriate to the context, and there are no problems manifested on a large scale. As such, the density of the scheme is acceptable.

Children’s play space

22 Policy 3D .13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 100 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child play space to be provided per child, with under-5 child play space provided on-site. As such the development should make provision for 1000 sq.m. of play space. The applicant’s model on child yield uses a mix of GLA and borough figures to produce a realistic assessment.

23 This development provides 1,235 square metres of play space on site. The majority of this will be new provision within site E, and will be in addition to the existing landscaped space to the east of the proposed tower, which will be renewed. In addition, there would be semi- private and communal space to be provided within a narrow strip at the rear of the buildings on site G, which will be directly overlooked by adjacent dwellings.

24 The application does not specifically provide local equipped areas of play (LEAP spaces) for younger children. The nearest existing space is approximately 360m from the centre of the site. It would appropriate to provide a new space to ensure that all residents of the estate were within five minutes’ walk of a LEAP space, as required by the supplementary planning guidance. The application notes that such spaces are available, but it is unclear whether these will be onsite or provided for within a future development phase. The applicant is requested to provide further information on this matter.

Urban design and tall buildings

25 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 (‘Design principles for a compact city’) sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale

page 5 buildings, built heritage and views. The draft replacement London Plan reinforces these principles, with new development required to have regard to its context, and reinforce or enhance the character, legibility and permeability of the neighbourhood (policy 7.1) and conservation area (policy 7.8).

26 London Plan policies 4B.8 and 4B.9, which relate to the specific design issues associated with tall and large-scale buildings, are of particular relevance to the proposed scheme. These policies set out specific additional design requirements for tall and large-scale buildings, which are defined as buildings that are significantly taller than their surroundings and/or have a significant impact on the skyline and are larger than the threshold sizes set for the referral of planning applications to the Mayor.

27 The overall layout, scale and form of the proposed buildings are well considered and would successfully respond to the existing context and future development in the area. The aims of the overall estate regeneration masterplan are to retain the original street pattern, remove ambiguity between fronts and backs of properties, and create clear delineations between private and public space. The new buildings and layout will also seek to incorporate some of the modernist architectural principles used by Goldfinger within the eastern part of the estate, thereby unifying the eastern and western parts of the estate with a common design theme, decades apart. The contextual studies undertaken by the architect are sound, with the new buildings taking cues from existing design and also seeking to ensure that they are appropriate in terms of visual and neighbour amenity.

Site E

28 The building is similar to other buildings on the estate, in that it is a self-contained, free- standing structure surrounded within an open setting. Although it is tall, it is not particularly bulky, and in long views will be an appropriate addition to the area. In shorter-range views, the building will have an immediate impact, created mainly as a result of its height, but its freestanding nature, surrounded by open space, ensures that the impact is acceptable.

29 The building will form part of the panorama as seen from the Greenwich Park viewpoint within the London Views Management Framework. It will be a similar height to other buildings in the vicinity and background, and appear smaller than buildings adjacent and within the foreground, especially Canary Wharf and the North Greenwich power station chimneys. The building will not be detrimental to the panorama and will be an acceptable addition to the view.

30 The proposed height of the twenty-storey tower on Site E (Willis Street car park site) is considered appropriate and its form and appearance will generally be in keeping with the other nearby tall buildings such as Glenkerry House and Balfron House elsewhere on the estate. The tower has been rearranged from an earlier ‘L’ shaped arrangement, which better reflects the footprint and arrangement of buildings elsewhere in the estate, and will result in the creation of a larger amenity space. The building is sufficiently removed from the other taller buildings so as to not interfere with their setting, and Balfron House will remain the tallest and most striking building on the estate. With regards to the setting of the conservation area, the new building will provide a modernist form that draws elements of siting, footprint and scale from the earlier buildings, without resorting to pastiche, and will be an appropriate addition.

31 The location of the lobby space in the centre of the building is supported. There are active frontages around the ground floor of the building, and the entrances are denoted by vertical design features within the facade of the building. From the street entrance the design of the building will enable glimpses of the landscaped spaces to the rear of the building. The location of two units at ground level will allow for increased passive security of the lobby,

page 6 entrance and amenity areas therefore limiting the scope for antisocial behaviour in the vicinity. These units will have raised garden terraces to retain their privacy.

32 The cluster core arrangement of the units and terrace balconies proposed are welcomed. Five or six flats will be located on each floor, with four lifts to serve the central core. This level of provision is appropriate. Although some of the units within the building are single-aspect, none are north facing. These are limited to one-bedroom flats and there are a maximum of two per floor.

33 The simple modernist architecture appears to be well suited to the nature and function of the residential block and the context. The balance of solid, vertical wall and horizontal elements reflect and complement Goldfinger’s design rationale on the surrounding towers without directly replicating it. The recessed balconies with infill panels set back from the primary structure provide a visually appealing solution while retaining the crucial solid elements. Officers will, however, require more information on the palette of materials to be used on the building to ensure that the chosen approach will be appropriate.

34 The applicant’s environmental statement notes that although there will be some slight increases in local wind levels, with the greatest effects in winter on the street to the north of the building. However the effects would not cause sustained discomfort to pedestrians.

35 The applicant’s overshadowing anaylsis indicates that the Burcham Street homes adjacent to the site would be detrimentally affected by the proposed development through loss of direct sunlight for two to three hours in the mid-afternoon (based on an analysis of the equinox dates). This is unfortunate, and needs to be balanced against the regeneration benefits of the scheme.

Other sites

36 The three-storey residential blocks proposed at sites I – I and I – 2 are of a similar shape and scale so as to be in keeping with the existing blocks to which they adjoin, while the new block at Site G will provide a prominent solution to the Brownfield Road street frontage. The scale of the new buildings is considered appropriate. All buildings will be located on block perimeters, reinforcing existing streets and creating new private spaces to the rear.

37 The massing and appearance of block G is different to other buildings around the estate, existing and proposed. Officers have expressed concern that the building may be at odds with other buildings, especially those within the adjacent conservation area, which have detailed modernist facades. Officers therefore request further design justification as to the design approach of this building in terms of massing and appearance, as the design and access statement does not make this clear.

38 Dwellings will be double-aspect. Internal arrangements are considered to be appropriate and the houses on sites I-1 and I-2 will be appropriate additions to the street. Externally, there would be a good balance between public and private space, although the plans indicate that there will be side access to back gardens, through seemingly uncontrolled and non-overlooked pathways. Officers will require more information regarding the purpose and treatment of these routes, whether they will have restricted access (and if so, how access will be restricted), and whether there is potential for additional surveillance.

39 Of particular concern is the Ida Street elevation of block G, which will have a blank facade with minimal overlooking from other dwellings in the street. The applicant is urged to reconsider this facade, adding some visual interest, and if possible, window openings from which

page 7 some surveillance of the street will be possible. In common with site E, officers will require further information on materials for all buildings, to ensure that they will retain an appropriate and durable appearance within the street scene.

40 Room and dwelling sizes within the scheme are on average lower than the standards within the draft London Housing Design Guide and draft replacement London Plan. It is understood that the pre-application process for this phase of the scheme pre-dates both of these. However the GLA would wish to see an assessment of the future phases of the development against the provisions of these documents.

Landscaping

41 Areas of landscaping include the areas around the tower, the area of existing open space that is to be improved to the east of the tower, gardens and common space around site G, and gardens and a small portion of Ida Street around sites I-1 and I-2. New street trees will be provided where there is adequate verge space.

42 Landscaping information is limited, although information pertaining to materials has been submitted, and these are appropriate. Further information should be provided regarding desire lines across the new space to the east of the tower – for this to be an active space, its layout should reflect desire lines, which it does to a degree. Officers noticed when visiting the site that there was a propensity for pedestrians to cross the site from the north-east to the south-western corners; this is not reflected in the layout.

43 Additionally more information should be submitted pertaining to landscaping potential for mitigating against microclimate changes, and its robustness, as recommended within the applicant’s environmental report; as well as whether improvements will extend to the area of existing open space to the east of the tower. This space may require further thought, in particular how the area interacts and sympathises to the residential block along 2-24 Burcham Street. Officers would also appreciate information, if it is available at this stage, regarding the wider landscaping programme within the streets and spaces around the estate, and what improvements are proposed. Landscaping information should also denote which of the existing trees on the site will be retained.

44 The amenity space at the rear of the buildings on sites G, I-1 and I-2 may require further information, in regards to the aforementioned access pathways.

Transport and parking

45 Transport for London (TfL) accepts the results of the trip generation assessment undertaken and due the small uplift in units (a net gain of 114 dwellings), TfL considers it unlikely that the development will have a significant impact on the transport network.

46 TfL supports the proposals for a car free development for Site E and the applicant’s willingness to remove eligibility for residents to apply for on-street parking permits, secured by way of a S106 agreement with Tower Hamlets Council. TfL notes that the parking levels for site G are compliant with parking standards as outlined within London Plan policy 3C. 23, ‘Parking Strategy’ (Annex 4) and draft replacement London Plan policy 6.13, ‘Parking’ and is therefore acceptable. The proposal to allocate 20 car parking spaces for sites I-1 and I-2 is also accepted given that parking will be removed on Ida Street. However, TfL recommends that in recognition of the site’s good PTAL, occupants’ rights to parking permits for the wider estate should also be removed.

page 8 47 TfL requires the developer to provide adequate disabled parking across the estate in line with London Plan policy 3C.23 ‘Parking Strategy’ and draft revised London Plan policy 6.13, ‘Parking’.

48 TfL supports any proposal to operate a car club scheme from the site and encourages the developer to provide electric car charging spaces for 20% of all residential parking, compliant with draft replacement London Plan policy 6.13, ‘Parking’. An additional 20% of spaces should be allocated as passive provision. For passive provision the developer is expected to demonstrate that the additional spaces or points can be provided at the time of implementation or at some time in the future.

49 TfL welcomes the proposal to provide 147 cycle parking spaces for Site E and G, however an additional 18 cycle parking spaces should also be provided for site I, to ensure compliance with cycle parking standards as set out in London Plan policy 3C.22 ‘Improving conditions for cycling’ and draft replacement London Plan policy 6.9, ‘Cycling. TfL support the proposals to locate 117 cycle parking spaces in the basement of site G. TfL however, seeks clarification of where the additional 30 spaces proposed to service sites E and G will be located and requires the developer to reflect the appropriate location of cycle parking within an estate wide travel plan.

50 There is a lack of accessible cycle routes to the south of the development site. To ensure compliance with London Plan Policy 3C.22 ‘Improving conditions for cycling’ and draft revised London Plan policy 6.9 ‘Cycling’, TfL requests consideration for the introduction of a cycle route along the eastern fringes of East India Dock Road and Cotton Street.

51 TfL suggests due to the proximity to two Docklands Light Railway (DLR) stations, the majority of trips from the development will originate on DLR services. Due to the size of the development site, TfL highlights that the demand should be split between the two stations. However TfL believes that the DLR network can accommodate the additional demand from this development, due to the ongoing three car upgrade programme and the opening of Langdon Park DLR station.

52 Pedestrian links to and from both stations are considered to be poor. In line with London Plan policy 3C.3, ‘Sustainable transport in London’ and policy 3C.21 ‘Improving conditions for Walking’ (draft revised London Plan policies 6.1 ‘Walking’ and 6.10 ‘Strategic Approach’); TfL recommends a contribution is sought for pedestrian improvements along Ida Street and Hay Currie Street.

53 TfL encourages the applicant and Tower Hamlets Council to investigate the removal of guard railings across the estate to increase the permeability of walking routes. As the site is within 900m of two DLR stations, TfL recommends the developer should adopt a way finding and signage strategy that incorporates the principles of ‘Legible London’.

54 TfL also encourages the development to make provision for DLR real time information using the DAISY (Docklands Arrival Information System) in communal areas. A sum of £20,000 should be set aside for its installation and should be secured by a S106 agreement.

55 TfL requires a full travel plan to be submitted to support this application, to ensure compliance with London Plan policy 3C.3, ‘Matching development to transport capacity’ and draft revised London Plan policy 6.3 ‘Assessing transport capacity.’

56 TfL expects the development to be supported by a construction logistics plan and a delivery and servicing plan in line with London Plan policy 3C.25, ‘Freight Strategy’ and draft replacement London Plan policy 6.14 ‘Freight’. Both of these plans should be secured by way a

page 9 Section 106 agreement with Tower Hamlets Council. During the construction phases of sites E, G and I, consideration needs to be given to bus route 309, to minimise disruption, avoiding diversions where possible. This should be included within the construction and logistics plan.

57 Subject to the applicant addressing the above matters, TfL considers the development would be in accordance with the transport policies in the London Plan and consider the principle of the development acceptable.

Access

58 For internal circulation, all residential units are intended to meet the Lifetime Homes standard, with 10% of the total either adapted or adaptable to wheelchair accessible standards. Seven units have been designed as fully accessible and are distributed across different types of accommodation. Site G includes four three-bedroom wheelchair apartments and one five- bedroom wheelchair apartment, along with two lifts for the dwellings on the upper floors. Two four-bedroom person wheelchair houses are located on Follet Street.

59 The two flatted buildings will contain lifts. All residents within site G will have access to two lifts, with a total of four in the building. Site E will have two lifts that will be accessible to residents using the eastern core of the building (the five-storey element). External areas around the sites have also been designed to Lifetime Homes standards.

60 As mentioned within the previous section, an accessible parking strategy should be planned for the site.

Sustainable development

61 The London Plan climate change policies as set out in chapter 4A collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising decentralised energy supply, and incorporating renewable energy technologies with a target of 20% carbon reductions from on-site renewable energy. The policies set out ways in which applicants must address mitigation of and adaptation to the effects of climate change.

62 Policies 4A.2 to 4A.8 of the London Plan focus on how to mitigate climate change, and the carbon dioxide reduction targets that are necessary across London to achieve this. Chapter 5 of the draft replacement London Plan sets out the approach to climate change and requires developments to make the fullest contribution to minimising carbon dioxide emissions.

63 The applicant has broadly followed the energy hierarchy in Policy 4A.1. Sufficient information has been provided to understand the proposals as a whole and to verify carbon dioxide savings in principle. However, further information is required to fully assess the application.

Be lean

64 The baseline emissions have been modelled using suitable methods. The baseline emissions have been estimated to 401 tonnes of carbon dioxide per annum, including emissions due to non-regulated energy use. The community space usage has been estimated using benchmarks, this is considered acceptable in this instance due to the relatively small space of community space compared to domestic space.

page 10 65 A range of energy efficiency measures is proposed for the development, including high performance glazing, improved U-values for building envelope compared to building regulations 2006 requirements, improved air tightness and energy efficient lighting and lighting controls. These measures would enable the development to exceed the requirements of building regulation 2006 Part L by 10-20% for the various dwellings, and reduce the baseline emissions by 8% for the residential elements. The reductions would be 20%, compared with the baseline carbon dioxide emissions for all elements based on an estimate for the communal areas.

Be clean

66 The use of district heating has been investigated and is proposed for the tower block. Provision would also be made to be able to connect an older community heating scheme for 50 units on Burcham Street. To this end, pipes would be installed to the street from the energy centre in the new tower at site E. This may also enable an opportunity to connect Balfron Tower and Carradale House in the future. The distance currently prohibits a connection. Gas-fired CHP has been investigated and found not feasible for the development. This is acknowledged.

67 Space in the energy centre has been allocated for the future expansion of the communal heating scheme. The applicant should show indicatively that enough space has been allocated for the proposed systems as well as the space allowing for future expansion.

68 The proposals for the houses on sites I-1 and I-2 are individual heating systems, but it is not clear what these individual systems are. The applicant needs to provide information regarding all energy supply strategies on site.

69 The proposals do not contain any information about cooling requirements. The applicant should confirm there are no cooling requirements and that overheating risk has been investigated and mitigated. Alternatively, if there would be cooling requirements, the applicant should describe how this demand has been minimised first.

Be green

70 The proposals include two strategies for renewable energy; the provision of a 105 kW biomass boiler for the tower block with communal heating, and 24 kW electrical output of photovoltaic panels for the houses. The carbon dioxide reductions over and above the energy efficiency measures are 20%.

71 Considering the whole of the London Borough of Tower Hamlets is an Air Quality Management Area, it is unlikely that the small biomass boiler is suitable. Therefore a backup approach to renewable energy should be provided. Further information will be provided to the applicant.

72 Regarding the photovoltaic panels, the applicant should provide information on the location of the panels. The applicant should compare the savings of the photovoltaic panels with solar thermal panels.

Climate change adaptation

73 The London Plan promotes five principles in policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribute

page 11 to heat island effects; minimise solar gain in summer; contribute to flood risk reduction, including applying sustainable drainage; minimising water use; and protect and enhance green infrastructure. Specific policies cover overheating, living roofs and walls and water.

74 In line with policy 4A.10 of the London Plan particular attention should be paid to use of passive design and natural ventilation. The pre-assessment report for the Code for Sustainable Homes predicts that code level 3 will be achieved.

75 Policy 4A.14 of the London Plan seeks to ensure that surface water run-off is managed as close to its source as possible, and sets out a hierarchy of preferred measures to achieve this. Policy 4A.11 seeks major developments to incorporate living roofs and walls where feasible. Policy 4A.16 of the London Plan seeks to ensure that new development has proper regard to the impact on water demand and existing capacity by minimising the use of treated water and maximising rainwater harvesting opportunities. Although low-flow appliances will be fitted within homes, there is no information as to whether the scheme will incorporate features such as greywater recycling, roof water runoff and green or brown roofs in locations where PV panels will not be fitted. Officers would appreciate information from the applicant regarding the feasibility of incorporating these measures.

Local planning authority’s position

76 It is understood that Tower Hamlets Council supports the principle of the scheme but has concerns relating to matters including the tall building and impact on the conservation area, the quality of design and material, and further information regarding the wider estate regeneration benefits.

Legal considerations

77 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 stateme nt 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. 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

78 There are no financial considerations at this stage.

Conclusion

79 London Plan policies on housing and affordable housing, density, tall buildings/views, urban design, transport and parking, access and sustainable development are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

page 12 • Housing and affordable housing: 43.9% of the development will be affordable housing, once demolition is taken into account, although no viability assessment has been submitted. No local equipped areas of play (LEAP spaces) have been provided. Density and dwelling mix is generally acceptable. • Urban design: The approach is mostly acceptable, but there is insufficient justification on the massing approach of block G, and there are also concerns regarding the treatment of its side elevation. There is limited information regarding the choice of building materials. The treatment and purpose of the routes to rear of blocks G and I-1 and I-2 are questioned, as are the landscaping issues outlined in paragraphs 42 and 43. • Transport and parking: There is unlikely to be a significant impact on the transport network, but certain improvements should be considered, as should the submission of a travel plan. There are concerns regarding parking, namely the absence of provision for disabled parking. Electric charging parking points and additional cycle provision should also be considered.

• Access: There is no provision for disabled parking.

• Sustainable development: The approach to energy provision and carbon dioxide reductions are acceptable in principle, but there are outstanding concerns, especially in relation to the provision of a biomass boiler and its effect on local air quality. The application makes no mention of the provision of climate change adaptation measures such as the provision of grey water recycling, roof water runoff collection and green and brown roofs.

80 Whilst the application is broadly acceptable in strategic planning terms, on balance, the application does not comply with the London Plan.

81 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

• Housing and affordable housing: A viability appraisal should be submitted with regard to the level of affordable housing provision, as well as the wider benefits proposed by the scheme. LEAP space(s) should be provided. • Urban design: Further work or justification for the massing approach of block G is required, including the treatment of side elevation. More information on building materials should be submitted, as should more information on the treatment and purpose of the routes to rear of blocks G and I-1 and I-2. The comments regarding pedestrian routes to the east of the tower and relationships between the open space and existing homes should be considered and improvements made where possible. • Transport and parking: Occupants’ rights to parking permits for the wider estate should be restricted. A disabled parking strategy and electric parking spaces should be provided. Clarification on cycle parking is required, and the introduction of a new cycle route on East India Road and Cotton Street should be considered. Improvements to local pedestrian routes are requested, including the upgrading of routes and removal of guard rails. Introduction of a real-time DLR notification system is requested, as is the submission of a travel plan, construction logistics plan, and delivery and servicing plan.

• Access: A disabled parking strategy is required.

page 13 • Sustainable development: The applicant should show indicatively that enough space has been allocated for the communal heating scheme as well as allowing for future expansion, and should provide information for energy strategies in buildings on sites G, I-1 and I-2. Further information on cooling requirements is needed, as is information on the proposed photovoltaic panels and biomass boilers, especially with regards to air quality. Information should also be submitted regarding the justification for not incorporating grey water recycling, roof water runoff collection and green and brown roofs into the scheme.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Glen Rollings, Case Officer 020 7983 4315 email [email protected]

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