planning report PDU/2415c/01 6 October 2010 Bow Enterprise Park

in the London Borough of Tower Hamlets planning application no. 10/1734

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 Mixed use development for 557 residential units, 6220 sq.m. B1/B1(c) and 490 sq.m. flexible (A1, A2, A3 and A5) uses. The proposals will range from 3 to 20 storeys high.

The applicant The applicant is Workspace Glebe, and the architect is ORMS Architectural Design.

Strategic issues The application is a resubmission of a similar proposal for redevelopment of the existing low density industrial sheds for mixed use residential led development. The application includes a significant proportion of family housing, which is supported. Further consideration of the applicant’s viability work is required to ensure the maximum reasonable amount of affordable housing is being delivered. Other outstanding matters include urban design, energy and transport.

Recommendation

That Tower Hamlets 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 70 of this report; but that the possible remedies set out in paragraph 72 of this report could address these deficiencies.

Context

1 On 1 September 2010, 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 12 October 2010, 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.

page 1 2 The application is referable under Categories 1A, 1B (c) and 1C (c) of the Schedule to the Order 2008:

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

1B (c): “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings Outside Central London and with a total floorspace of more than 15,000 square metres.”

1C (c): “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 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 environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into account in the consideration of this case.

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

6 The development site lies in the northern part of Poplar and is bounded by the DLR to the east, Caspian works to the south (subject of planning application reference PDU/1982), Violet Road to the west and Devons Road to the north.

7 The site is rectangular and at the northern end is Devons Road DLR station. At the north eastern corner is The Widow Son, a grade II* listed public house. The site is currently occupied by Bow Enterprise Park, an industrial estate managed by Workspace Group, with some 30 small single story units of lightweight steel frame construction, and two larger premises sublet to light industrial operators.

8 The surrounding area to the west is predominately established and new residential accommodation, largely under the control of Poplar HARCA and Tower Hamlets Council, and is up to six storeys in height. Within the general area, there are a number of taller residential buildings up to 24 storeys in height. The Docklands Light Railway line acts as a barrier between the site and a large strategic industrial area beyond the DLR to the east.

9 The site is bounded by Devons Road to the north, the DLR alignment to the east, a mix of land uses to the south, and Violet Road to the west. The A12 Blackwall Tunnel Approach Road, which forms part of the Transport for London Road Network (TLRN) is located 600m to the east of the site. There are two bus routes serving the area with bus stops located on both Devas Street and Violet Road. Immediately to the east of the site is Devons Road DLR station and Bromley-by- Bow Underground Station (District and Hammersmith & City lines) is approximately 0.75 kilometres to the north east. The site has a good public transport accessibility level (PTAL) of 4 out of a range of 1 to 6, where 6 is the most accessible.

page 2 Details of the proposal

10 Full planning permission is sought for redevelopment to provide 557 residential units plus 6,220 sq.m. B1/B1(c) use and 490 sq.m. flexible retail/restaurant/cafe use.

11 The residential component of the proposal will be split as follows:

1-bed 2-bed 3-bed 4-bed 6-bed Total

Social rent 27 34 52 6 7 126 (23%)

Intermediate 22 23 0 0 0 45 (8%)

Market 168 177 41 0 0 386 (69%)

Total 217 234 93 6 7 557 (100%)

12 The proposed layout will be as a courtyard block and a separate new public square.

Figure 1 central residential courtyard (source D&A statement ORMS July 2010)

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Figure 2 visual showing station square (source D&A statement ORMS July 2010)

Figure 3 visual showing Violet Road (source D&A statement ORMS July 2010)

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Figure 4 visual looking towards the DLR entrance with Devons Road and the listed pub in the foreground (source D&A statement ORMS July 2010)

Case history

13 The Mayor considered proposals for similar scale and form of development on the previous application at stage 1 in April 2009. At that time the Mayor indicated broad support subject to improved design to the DLR entrance. The application was withdrawn following discussions with Tower Hamlets Council.

14 Directly to the south of the site is Caspian Works. The Caspian Works site has been subject to a number of planning applications by Berkeley Homes. Planning consent has been granted for redevelopment of Caspian Works for a residential led development with 580 residential units. Strategic planning issues and relevant policies and guidance

15 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, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft  Affordable housing London Plan; PPS3; Housing SPG, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft  Density London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing SPG EiP draft  Urban design London Plan; PPS1  Mix of uses London Plan  Regeneration London Plan; the Mayor’s Economic Development Strategy  Transport London Plan; the Mayor’s Transport Strategy; PPG1  Employment London Plan; PPS4; Industrial Capacity SPG

page 5  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the spatial needs of London’s diverse communities SPG; Diversity and Equality in Planning: A good practice guide (ODPM)  Tall buildings/views London Plan; RPG3A, Revised View Management Framework SPG  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Historic Environment London Plan; PPS5

16 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 2010 Core Strategy, the 1998 Tower Hamlets Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004).

17 The following are also relevant material considerations:  The draft replacement London Plan, published in October 2009 for consultation.  The Lower Lea Valley Opportunity Area planning framework (January 2007). Regeneration

18 The regeneration objective remains as set out in the previous report considered by the Mayor on 1 April 2009 (Paragraph 18-21 of report PDU/2415/01). The site lies within the Lower Lea Valley Opportunity Area planning framework area. The Framework does not designate the site as Strategic Employment Location but designates the site as a ‘locally significant industrial area’. The planning framework does, however, acknowledge the potential for land use change and associated industrial land release where adequate public transport and highway capacity is available or provided for and with a suggested residential density of between 110 and 340 dwellings per hectare, or 325 – 875 habitable rooms per hectare. The Council’s recently adopted Core Strategy further encourages a local neighbourhood centre at Devons Road.

19 The land use approach includes provision of employment uses B1 and B1(c) and will increase the number of persons employed on the site by approximately 200. This is achieved through the retention of small and medium sized enterprises as an integral feature of the design which therefore protects, to an extent the local employment designation. Furthermore it would not, in this instance erode the strategic employment location identified to the east of the proposal site. The land use approach is broadly consistent with the land use aspirations for the site as identified within the Lower Lea Valley Framework and is consistent with the objectives of the London Plan to deliver housing as part of mixed use development. Housing

Affordable housing

20 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-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

page 6 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.

21 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.

22 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 recently adopted the 2010 Core Strategy. Here a strategic target for affordable housing is set and 50% of which 70% should be social rented and 30% intermediate.

23 The affordable housing offer is set out in habitable rooms below and by bedroom size mix in table 1:

Habitable rooms %

Social rent 450 28

Intermediate 113 7

Market 1,031 65

Total 1,594 100

24 The quantum of affordable housing proposed will therefore be 35%, split as 80% social rent and 20% intermediate. Regarding quantum, the proposed offer will need to be supported by evidence to meet the policy test set out in 3A.10 regarding the maximum reasonable amount. This information should be submitted to the GLA and may require further independent scrutiny.

25 Regarding affordable housing split, as above, the London Plan sets a target split of 70/30, social/intermediate. The draft replacement London Plan proposes a target of 60:40 social rented/intermediate provision. The Council has negotiated a significant proportion of social rented family units in this case. As set out in table 1 these range from 3-bed to 6-bed. Whilst the approach does not reflect the emerging strategic approach to affordable housing split, the approach is consistent with current policy in terms of meeting identified need within the borough and contributing to the London wide need for larger family units within the social rented sector. The evidence presented at the examination in public into the Core Strategy further underpins the borough wide objective and local importance meeting the need for larger family housing.

page 7 Density

26 London Plan Policy 3A.3 outlines the need for development proposals to achieve the highest possible intensity of use compatible with the local context, the design principles within Policy 4B.1 and public transport capacity. Table 3A.2 of the London Plan provides guidelines on density in support of policies 3A.3 and 4B.1. The draft replacement plan moves away from maximising site capacity to optimising development potential with a stronger focus on local context in particular.

27 The residential density is based on 1,594 habitable rooms on an area of the site less the commercial uses. The commercial floorspace comprises approximately 12% of the floorspace and therefore approximately 88% of the site area is applied to the residential density calculation. This provides a density of 993 habitable rooms per hectare. The site is in an urban location and has a public transport accessibly level of 4. The London Plan guides a density range in this type of location between 450 and 700 habitable rooms per hectare. The proposed density is therefore above the guidance set out within the London Plan.

28 A higher density may be considered acceptable in cases where there are other strategic benefits associated with the application. The scheme should deliver an exceptional design, make generous contributions to affordable housing and family housing and deliver an exceptional approach to sustainability. Additionally, there should be open and amenity space and clear consideration to encouraging biodiversity and sustainable transport. In this case there is a significant contribution to family accommodation, private and public amenity space and high quality design. The approach to sustainability is also broadly supported and the proximity to Devons Road DLR results in suitable access to sustainable modes of transport. Having regard to the particular circumstances of this case, the density is broadly acceptable in this instance.

Housing mix

29 The housing mix caters for a range of family accommodation, in particular in the social rented sector where provision is made for 6-bedroom units. Whilst the majority of the private units fall within the smaller sized accommodation, the social rented components of the scheme will provide over 50% of units as family (3-bed or larger) units. Urban design

30 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 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 buildings, built heritage, views, and the Blue Ribbon Network.

31 As previously reported, the overall the general principles of site layout, massing and urban design are supported for this scheme. It appears to successfully respond to a range of complex site constraints including the listed pub building, incorporating light industry and commercial with residential activities, and providing a range of unit types and residential settings within the site.

Setting of listed building

32 The adjacent public house (The Widow’s Son) is listed grade 2*. The listing relates mainly to the internal features, which retain almost completely the 1870’s fittings. The listing also relates

page 8 to the history of the original owner and the hanging of buns and a sailors hat over bar which refers to the legend of The Widow's Son.

33 The building is in poor state of repair generally. In terms of the setting, it will be significantly improved from the original setting within the industrial sheds. The test is therefore met in that there will be a clear improvement that would enhance the setting of the existing listed building. The introduction of a new population is likely to support its function, which in turn may protect its continued viability as a public house and lead to improved upkeep and repair to the external facade.

Layout

34 GLA officers previously raised concern regarding the scale of the public square and the potential for it to become a vast and poorly used windswept public space. GLA officers suggested bringing vehicles through the square to provide animation to the space, given the size of the space and the need for large volumes of footfall to make it successful. This option has not been pursued. Instead the square is now scattered with street furniture, which does not necessarily address the issue of the scale of the space and its intended function. This requires further discussion.

35 The Mayor made previous comments on the detailed design of the DLR entrance elevation and overhang. At that time the Mayor suggested consideration of a more exciting and inspiring design solution to the DLR entrance. The design remains unchanged. A public art brief is suggested in the design and access statement to fill the space below the overhang, however, it remains unclear how this is intended to be progressed or delivered or whether there will be community involvement. This matter requires further discussion.

Flat layouts and space standards

36 The Mayor’s Draft Housing SPG and the Mayor’s Housing Design Guide both provide guidance on the detailed design including flat layouts and space standards. It is unclear how the proposals fit within the guidance and therefore the applicant should provide further information regarding the flat sizes related to bedroom size mix and undertake an assessment of the design principles having regard to the guidance contained in both documents above. Further discussion is required on this matter.

Tall buildings

37 London Plan Policy 4B.9 Tall buildings – location, seeks the development of tall buildings where they, amongst others, create attractive landmarks, provide coherent location for economic clusters, act as a catalyst for regeneration and are acceptable in terms of design and the impact on their surroundings. Policy 4B.10 Large-scale buildings – design and impact, requires all large scale buildings, including tall buildings to be of the highest quality design, in particular, being suited to their context, attractive, demonstrate sustainable design and construction methods, provide high quality spaces with a mix of uses and give consideration for transport requirements.

38 As previously reported, the proximity of the building is at its closest to the DLR station and bus interchange. The height scale and massing is supported as making a positive contribution to the skyline. There is no impact on strategic views. The building will be visible from certain local views, but this will contribute to identifying Devons Road DLR station and improve legibility within the area. The architecture is high quality and is set in the context of other similar scale buildings in the vicinity of the development.

39 Overall the principles of the materials and elevations proposed are supported.

page 9 Children’s play space

40 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 234 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 2,340 sq.m. of playspace.

41 The landscape and open space strategy remains fairly robust as previously submitted and allocates play space for each of the age groups identified within the SPG. The total formally designated play areas accords with the target of 2,340 sq.m. In addition, there will be 6,000 sq.m. private amenity space and 5,400 sq.m. public amenity space set across the central courtyard and public square. The actual use of these spaces needs to be further considered as identified above in the urban design section of the report. This includes the extent of public access through the more private central courtyard. Notwithstanding the use of the public square, the approach to play space is consistent with London Plan policy 3D.13.

Access

42 Policy 3A.5 of the London Plan requires all new housing to be built to ‘Lifetime Homes’ standards and 10% of all new housing to be designed to be wheelchair accessible to meet the full range of housing needs. London Plan Policy 4B.5 ‘Creating an inclusive environment’ states: “Design and access statements should be submitted with development proposals explaining how the principles of inclusive design, including the specific needs of disabled people, have been integrated into the proposed development, and how inclusion will be maintained and managed”.

43 As previously reported, the site is relatively flat and therefore where there are changes in level these have been designed to integrate into the landscape and pavements through gentle slopes, limiting the use of steps. This approach is supported and in particular at the new entrance to the DLR. All flats have been designed to meet the Lifetime Home standards and 10% of flats will be wheelchair accessible or adaptable. Plans have been provided to illustrate this approach. Climate change mitigation

44 London Plan policies 4A.4 and 4A.7 require the submission of an energy demand assessment along with the adoption of sustainable design and construction methods, demonstration of how heating and cooling systems have been selected in accordance with the Mayor’s hierarchy and how the development will minimise carbon dioxide emissions, maximise energy efficiencies, prioritise decentralised energy supply, and incorporate renewable energy technologies, with a target of 20% carbon reductions from on-site renewable energy.

Energy efficient design

45 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Features include mechanical ventilation with heat recovery (MVHR), low specific fan powers and energy efficient lighting.

46 The development is estimated to release 1,292 tonnes of total carbon dioxide emissions per annum after the application of passive design and energy efficiency measures. Based on the information provided, the proposed development is unlikely to achieve any carbon savings from energy efficiency alone compared to a 2010 Building Regulations compliant development. The

page 10 residential elements of the scheme, however, which account for 75% of the development’s carbon emissions, are projected to achieve a 20% reduction in regulated carbon emissions through energy efficiency alone compared to a 2006 Building Regulations compliant development. Expressed on the same basis, commercial areas would achieve a 16% reduction.

47 Using 2010 Building Regulations compliance software, the applicant should investigate additional measures that could be adopted to enable the development to exceed 2010 Building Regulations compliance through energy efficiency alone. The applicant should also provide an estimate of the regulated emissions after energy efficiency measures have been applied.

Heating and cooling

48 The applicant has provided a commitment to installing connection points to allow the development to be linked to external district heating networks in the future. No information, however, has been provided on existing and planned district heating networks in the vicinity of the development. The applicant should provide details of district heating networks in the surrounding area and, where existing networks exist, investigate connection.

49 The applicant has committed to a heat network linking the residential units on the development, served from a single energy centre. The commercial units will also be heated from the single energy centre. The applicant should provide a schematic showing the route of the heat network. A detailed drawing showing the location and size of the energy centre should also be provided.

50 The lead heat source for the network will be combined heat and power with an electrical capacity around 200kW. The sizing of the combined heat and power unit has been optimised to supply a proportion of the space heating demand as well as the domestic hot water requirements and load profiles have been provided to support the sizing.

51 A reduction of 271 tonnes of carbon dioxide emissions will be achieved through combined heat and power compared to the emissions after energy efficiency measures are applied. A 20% reduction in emissions will be achieved through this second part of the energy hierarchy. The applicant should provide an estimate of the regulated emissions after combined heat and power has been applied.

52 A range of passive design features are being used to avoid the need for active cooling in the residential elements. These include high performance glazing, shading devices and use of thermal mass. The design aim is to avoid the need for active cooling in the commercial areas. However, if active cooling is required in the commercial areas this will be provided using ground source heat pump (GSHP) technology.

Renewable energy

53 A 250 sq.m. photovoltaic array with a peak output of circa 25kWe is proposed for the development. This will reduce carbon emissions by a further 1.4%. An indicative drawing has been provided to illustrate the area available for PV taking into account other uses of the roof area and overshadowing.

54 Should the GSHP technology be required, the applicant estimates that a further carbon reduction of 2.3% would be achieve from renewable energy.

Summary

page 11 55 The applicant should provide an estimate of the regulated carbon emissions of the development per annum after the cumulative effect of energy efficiency measures, combined heat and power and renewable energy has been taken into account. The tonnes of carbon dioxide per year reduction compared to a 2010 Building Regulations compliant development should be provided, along with the overall percentage reduction in regulated emissions Climate change adaptation

56 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 contribution to heat island effects, minimise solar gain in summer, contribute to flood risk reductions, including applying sustainable drainage principles, minimise water use and protect and enhance green infrastructure. Specific policies cover overheating, living roofs and walls and water.

57 The proposals have been designed to reduce carbon dioxide emissions beyond building regulations through energy efficiency measures alone. This includes the use of natural ventilation and techniques to minimise the risks of overheating. Green roofs will be including within the proposals and should be conditioned by Tower Hamlets Council. A commitment to minimising the use of water will should also be conditioned by the Council, in accordance with London Plan policy 4A.16 Transport for London’s comments

58 It is disappointing that, following previous requests, the level of car parking has not been reduced to a level which reflects the good level of access to public transport. Nevertheless, the proposed 141 residential parking spaces, which equates to 0.25 spaces per unit, complies with the maximum standards set out in London Plan Policy 3C.23 ‘Parking Strategy’ and draft replacement policy 6.13 ‘Parking’. The applicant has confirmed that, by way of condition, future occupants of the development will be exempt from eligibility for on-street car parking permits, which is welcomed.

59 TfL also notes that 14 car parking spaces will be dedicated for blue-badge holders, and 5 spaces will be provided for the commercial units, which is considered appropriate. In line with draft replacement London Plan policy, 20% of the total residential car parking should be provided with electric vehicle charging points, with a further 20% for passive provision in order to future proof the development.

60 TfL welcomes the provision of 590 residential cycle parking spaces, which is compliant with TfL’s minimum standards, and those contained with draft replacement London Plan policy 6.13 ‘Parking’. The provision of an additional 28 cycle parking spaces, for dedicated use by staff and visitors to the commercial and retail elements of the scheme, is also considered acceptable.

61 The development is likely to generate additional bus trips equivalent to the capacity of an extra peak hour bus, when the existing local bus network suffers from capacity constraints. TfL therefore requests a section 106 contribution of £660,000 to mitigate the impact of the development. This represents the total cost of providing an additional bus over three years and would ensure consistency with London Plan Policy ‘Matching Development to Transport Capacity’ and draft replacement London Plan Policy 6.2 ‘Providing Public Transport Capacity and Safeguarding Land for Transport’. TfL would welcome further discussions with the applicant and Tower Hamlets Council in this respect.

62 As with the previous application, TfL understands a number of changes would be made to the local highway layout, with the primary aim of improving pedestrian movements. They include

page 12 signalising the Devons Road/Violet Road junction, and TfL is currently assessing the likely impact of this on smoothing traffic flow and bus journey times. TfL will continue to engage with the borough as highway authority and the applicant in this respect, before taking a view of the acceptability of the proposals.

63 The proposed development includes the relocation of two bus stops, to provide more convenient access for residents to public transport. TfL requires further details of the layout and accessibility of these bus stops, including drawings which show the swept paths of bus movements. The applicant should ensure that any proposals for relocating bus stops are consistent with TfL London Buses best practice guidance BP1/06 ‘Accessible Bus Stop Design Guidelines’. The full cost of relocating bus stop flags, posts and shelters should be met by the developer, while detailed design will need to be agreed and approved by TfL.

64 As requested in connection with the 2009 proposals, TfL seeks a section 106 contribution of £172,172 towards enhancing the capacity of the DLR services at Devons Road station. This takes account of the scale of the development and likely high levels of patronage expected at the station, as well as the cumulative impact of development in the area. This is consistent with London Plan Policy ‘Matching Development to Transport Capacity’ and draft replacement London Plan Policy 6.2 ‘Providing Public Transport Capacity and Safeguarding Land for Transport’. Furthermore, in order to encourage sustainable travel to and from the development site, the developer should allow up to £20,000 towards the installation of Docklands arrival information system (DAISY) screens in communal areas of the proposed development.

65 Considering the alterations proposed to enhancing the public realm and entrance to Devons Road DLR station, full details of the design of the station entrance should be submitted to TfL to ensure that these are consistent with DLR’s station design guidelines. A clause should also be included within the section 106 agreement which requires the testing of the impact of the proposed buildings on DLR’s radio communications. Should a signal booster be required to mitigate this impact, the cost of this should be borne by the applicant.

66 A framework travel plan has been submitted as part of the planning application. The targets and objectives set in the travel plan are realistic, particularly considering the accessibility of the site and the range of travel plan initiatives suggested. The responsibilities of the travel plan champions and coordinators have been clearly set out, and there is a good level of detail of the measures to be implemented. The applicant should however ensure that adequate funding is available for the implementation and monitoring of the plan. It should be secured, monitored, enforced and reviewed as part of a section 106 agreement. The applicant has committed to providing a delivery and servicing plan and construction logistics plan, which will be secured by condition. Local planning authority’s position

67 The officer recommendation is unknown. Legal considerations

68 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

page 13 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

69 There are no financial considerations at this stage.

Conclusion

70 London Plan policies on are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Affordable housing (non-compliant): Currently it is not clear that the proposals will provide the maximum reasonable amount of affordable housing. The financial appraisal requires scrutiny to ensure the quantum proposed represents the maximum reasonable amount of affordable housing in this case (London Plan policy 3A.10).  Urban design (non-compliant): The report identifies some detailed design matters that require further consideration (London Plan policy 4B.1). These include the delivery and design approach to the entrance to the DLR, the scale and function of the square and the test against design and space standards.  Access (compliant): Broadly consistent with the London Plan (policy 4B.5 and 3A.5).  Energy (compliant): The approach is broadly compliant subject to further clarification set out in this report (policy 4A.7). This is set out in the energy summary at Paragraph 55 of this report.  Climate change (compliant): Broadly consistent with the London Plan, subject to suitable conditions (policies 4A.9, 4A.10, 4A.13, 4A.14, 4A.16).  Transport (non-compliant): The report identifies a number of detailed transport matters that require further consideration. These are set out in Paragraph 58 –66 of this report. 71 Whilst the application is broadly acceptable in strategic planning terms, on balance, the application does not comply with the London Plan.

72 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan.  Affordable housing: Further discussion and testing is required regarding the affordable housing quantum.  Urban design: Further discussion is required regarding the use of the public square, the design rationale and delivery mechanism for public art at the entrance to the DLR and an assessment against the Mayor’s Housing SPG and Housing Design Guide.  Transport: TfL require further discussion regarding a financial contribution towards buses; the design of the Devons Road/Violet Road junction; further details of the layout and accessibility of new bus stops; financial contribution towards DLR services and Docklands arrival information system (DAISY); and full details of the design of the station entrance.

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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] Matthew Carpen, Case Officer 020 7983 4272 email [email protected]

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