planning report PDU/1336/02 7 February 2012 Mast Pond Wharf, Woolwich

in the Royal Borough of Greenwich planning application no. 11/1584/F

Strategic planning application stage II 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 Redevelopment of the site with a 16-storey building, comprising 100 residential units, new purpose built community facilities for the angling club, associated car parking and amenity space. The applicant The applicant is Mast Pond Wharf Limited, and the architect is Alan Camp Architects

Strategic issues The key issues for consideration at stage 1 related to the principle of development due to the site being within flood Zone 3a/b, provision of housing and in particular affordable and accessible housing, child play space, community use of the angling club urban design, flood proofing, energy, sustainability and transport have been satisfactorily addressed and conditioned. The Council’s decision

In this instance Greenwich Council has resolved to grant permission subject to the signing of a Section 106 legal agreement and relevant conditions and informatives have been imposed on the applicant. Recommendation That Greenwich Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.

Context

1 On 2 August 2011 the Mayor of London received documents from Greenwich Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Category 1C of the Schedule to the Order 2008:

page 1 “1. Development which comprises or includes the erection of a building of one or more of the following descriptions— (c) the building is more than 25 metres high and is adjacent to the River Thames”

2 On 5 September 2011 the Mayor considered planning report PDU/1336/01, and subsequently advised Greenwich Council that the application did not comply with the London Plan, for the reasons set out in paragraph 85 of the above-mentioned report; but that the possible remedies set out in paragraph 87 of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. Since then, the application has been revised in response to the Mayor’s concerns (see below). On 12 January 2012 Greenwich Council decided that it was minded to grant conditional planning permission and on 27 January 2012 it advised the Mayor this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct Greenwich Council under Article 6 to refuse the application or issue a direction to Greenwich Council under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application and any connected application. The Mayor has until 9 February 2012 to notify the Council of his decision and to issue any direction.

4 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

5 At the consultation stage Greenwich Council was advised that the application did not comply with the London Plan, for the reasons set out in paragraph 85 of the above-mentioned report; but that the possible remedies set out in paragraph 87 of that report could address these deficiencies:

 Flood risk: Various issues in relation to flood risk were raised at stage 1, primarily relating to operational matters such as owner occupation of the residential units, and access for people with disability etc; and safety issues such as suitable evacuation should the site flood. Whilst the applicant proposed flood mitigation measures, these needed to be accepted by the environment Agency and secured by condition. Proof of the exceptions/sequential test document was requested, given the site’s Zone 3a/b designation.

 Housing mix: A breakdown of unit size mix by tenure was required.

 Affordable housing: 15% affordable housing was proposed at stage 1. This needed to be evaluated to prove that it was the maximum reasonable amount.

 Accessible housing: An accessibility statement, detailing the exact number of wheelchair accessible units, Lifetime units and adaptable units was required.

 Childrens play space: The child yield was assumed at stage 1, based on the tenure chart within the viability assessment. These figures needed to be clarified by the applicant. The applicant was also advised to provide details of the quantum and nature of private amenity spaces in the proposal. The amount, type and quality of play space provision being created on the fifth floor of the scheme was unspecified at stage 1.

 Design/sustainability: The applicant was advised to consider access improvements to the town centre for the residents, alongside routing for transport facilities and services to

page 2 access the site, due to the site’s isolated location. Access and occupation into the building by less ambulant or disadvantaged groups was also required to be demonstrated in an Access Statement. The Council was advised to look into the car lift proposal. Alternative elevational approaches in design for the lift shaft cladding were required to be demonstrated as the render proposed is bulky in appearance. The inclusion of water filtration, biodiversity enhancements and green wall were welcomed, however a management plan should be incorporated in the proposal. Further, the applicant was advised that the landscaping proposed should have a management strategy in perpetuity.

 Energy: The applicant was required to provide further information on passive measures to avoid cooling of the building. If cooling measures are proposed, the applicant should state how this would be provided. This outstanding information will enable the carbon savings of the scheme to be calculated.

 Transport: A reduction in the number of car parking spaces proposed was recommended at stage 1. Another blue badge parking slot is required on the ground floor for users of the angling club, and developer contributions are sought for two new bridges across the Thames Path parallel to the site to improve pedestrian and cycle access, to compliment the BCS4 route. Contribution is also required towards ‘Legible London’ way finding. Furthermore, the CMP and DSP should be secured by planning conditions, in addition to the Travel Plan secured within the s106 agreement.

Principle of development

6 The agent provided a comprehensive response to the strategic issues that were raised at stage 1 in their letter dated 29 November 2011, with subsequent emails exchanged to verify design related matters. Overall the application is considered to be acceptable and in compliance with the London Plan subject to the various conditions that have been noted in the Council’s committee report. The flood risk matters are addressed below and the open space issue is addressed further in the report, paragraphs 12 and 13.

Flood risk

7 The outstanding sequential/exception test assessment was provided to the Council and examined by the Environment Agency. There are numerous conditions that have been placed on the applicant by the Environment Agency given the site’s location on flood Zones 3a/b. The conditions relate to flood mitigation measures and will form part of the section 106 agreement. The residential element will be built on the upper floors of the proposed angling club redevelopment and thus is in keeping with the requirements of PPS25. This design approach has been secured by condition also.

Housing

Housing mix

8 The applicant has increased the housing provision from 93 residential units to 100. The new proposed mix of unit sizes is as follows: 27 x 1-bed flats; 69 x 2-bed flats, with a greater number of larger 2 bed/4 person units and 4 x 3-bed flats. The new unit mix can be seen in the table below. While the proportion of 3-bedroom flats remains very low the Council highlights that families could use the larger 2-bedroom four person flats. Given this and difficulties in accommodating additional amenity space that would be required from a greater proportion of larger units the mix of units is acceptable.

Number Type

page 3 27 1 bed, 2 person

4 2 bed, 3 person flats

10 2 bed, 3 person wheelchair flats

55 2 bed, 4 person flats

4 3 bed, 5 person flats/duplex

Affordable housing

9 The applicant has increased the proportion of affordable housing from 15% to 20%, which is welcomed. The Council is still negotiating the tenure split with the applicant, however, it is seeking 80% shared ownership (intermediate) units and 20% social rent units, which is an improvement on the original offer of 100% intermediate, which is welcomed. The affordable housing toolkit was the subject of an independent examination, which confirmed that it is not viable to provide an increased proportion of affordable or social rented housing. On this basis the tenure split is accepted.

Accessible housing

10 The applicant has also revised the provision of wheelchair accessible units from the original 7 such units out of the 93 residential units that were proposed at stage 1 to 10 x 2 bed, 3 person wheelchair accessible flats. Conditions have been imposed to require submission of details and plans to demonstrate lifetime homes and wheelchair housing compliance. This is welcomed.

Children’s play space

11 The applicant has increased the 5th floor terrace space to 375.7 sq.m, through the relocation of the bicycle parking stands to the ground floor of the development to increase the play space provision for resident children. The extra open/play space now gained from this relocation now achieves compliance with the children’s play space standards specified in the London Plan policy 3.6 and the play space supplementary planning guidance with 22 children to 222.8 sq.m, based on the requirement of 10 sq.m per child.

12 The play/amenity space is accessible with level access via the fifth floor lift. Further, the applicant has identified in a plan (within their post stage 1 response), seven local parks and open spaces of approximately 3.04 ha in total within a 400m radius of the site. These amenity/play space areas meet the requirements at set out in table 7.2 in the London Plan. Given the angling club improvements, fifth floor open space provision and the neighbouring open space provision, it is considered that the application is in compliance with London Plan policy 3.6.

Design

13 To address the issues raised at stage 1, the applicant provided examples of the three different types of cladding materials proposed, and these are considered to be of high quality. The matt gold, bronze and silver colours complement one another well. Further, the semi-mesh design proposed to lighten the appearance of the car park lift has reduced the heaviness of the structures collectively and is an improvement to the massing/scale of the earlier design. The climbing plants proposed in for the car park are described to be evergreen however they are deciduous in nature. A robust management strategy for this planting is necessary to ensure durability; this has been secured by the Council through a planning condition, which is welcomed.

page 4 14 Although the development still represents an incongruous element in the local context, the mitigation is satisfactory subject to suitable conditions and management specifically relating to the maintenance of the landscaping.

Energy/Sustainability

15 The applicant’s energy consultant’s provided a response to the outstanding energy matters raised at stage 1 in their letter dated 21 November 2011. The additional information provided confirmed that no active cooling is proposed for the development, for either the residential units or ground floor angling club. The applicant as part of the passive design strategy will adopt solar control glazing. Shading is also provided to the angling club by the residential podium. This information addressed all the issues raised at stage 1 and thus no further information was required from the applicant.

16 The proposed development will be built to Level 4 of the Code of Sustainable Homes and this is secured by a condition. The angling club will also be constructed to meet BREEAM ‘excellent’ standard.

Transport for London’s comments

17 At stage 1, a number of issues were highlighted in relation to transport matters; reducing the level of car parking, providing an additional blue badge space on the ground floor for use by anglers, for two link bridges to be provided in order to widen the Thames Path at the north of the site, for contributions to be made towards implementing ‘Legible London’ and for a construction management plan (CMP), a delivery servicing plan (DSP) and a travel plan all to be secured by condition.

18 TfL welcomes that the applicant has agreed to the provision of an additional blue badge parking space, the provision of a CMP, DSP and Travel Plan all to be secured by condition. Car parking remains unchanged but is compliant with London Plan standards and therefore considered reasonable by TfL.

19 Greenwich Council is committed towards to the provision of ‘Legible London’ way finding totems but is yet to determine a figure. TfL will continue to work with the Borough to ensure that a contribution of approximately £15,000 is secured to help link the site with transport links including the ferry crossing, Woolwich Dockyard Train Station and the town centre.

20 The applicant has not provided a contribution towards providing two link bridges along the Thames Path citing viability issues. Whilst TfL acknowledges this, Greenwich Council is nevertheless encouraged to upgrade the condition of the path to enable wheelchairs, pedestrians and cyclists to easily navigate along this strategic walking route.

21 In summary the majority of strategic transport issues have been resolved. TfL will continue to work with the Borough to implement ‘Legible London’ around the site and to assist with improvements to the Thames Path as appropriate. On this basis the application is now considered to be in accordance with the London Plan and is acceptable in transport terms.

Response to consultation

22 The application was extensively consulted upon, through a press advertisement, four site notices, and 508 notification letters were sent to occupiers in the vicinity of the development. A second round of consultation was held to consult on the revisions to the scheme. During the second round of consultation, 542 properties were directly notified about the proposal and it was advertised again on four site notices. The increase in letters from 508 to 542 was due to letters

page 5 being sent to residents who had written in at the first stage, becoming aware of the proposal and who had not received letters directly.

23 Twenty-three letters of objection and a petition with 59 signatures against the development were received from members of the public, alongside 30 letters of support.

24 The objections related to, deficiencies on consultation, overlooking, impact on daylight/sunlight, height, density, impact of construction, traffic, loss of community facilities, impact on ponds and other heritage assets, absence of affordable housing, impact on social infrastructure, impact on protected species, increased crime, impact on Thames Path.

25 The Greenwich Conservation Group object to the design, height, overdevelopment of site and impact on heritage assets. The provision of community facilities is supported as are the sustainability proposals although Code Level 5 or 6 should be achieved. The Westcombe Society objected to the scheme, being too overbearing, too high and complex in its design.

26 Those objections relating to strategic matters have been addressed in either this report or the Stage I report. Local issues have been addressed in the Council’s Committee report and conditions or section 106 agreement proposed, where appropriate. Other objections relating to loss of view, likely price of new flats, availability of other sites, vacancy of other private developments and impact of immigration are not planning matters.

Statutory responses to the consultation

27 Eleven statutory responses were received to the proposal in addition to those raised by the Mayor.

 The Environment Agency is satisfied with the proposal subject to a number of mitigating conditions being imposed on the applicant.

 Natural England note that bats and crested newts may be affected but conclude permission could be granted because ecological enhancements have been demanded and relevant conditions imposed.

 English Heritage (Listed Buildings) raised similar objections to the height of the proposal and the cladding of the car park as the Mayor, these matters have been revised by the applicant and necessary conditions placed.

 English Heritage (Archaeology) archaeological works and foundation design matters have also been conditioned.

 Thames Water recommended conditions and informatives relating to ground water discharge and water pressure. These have been noted in the list of conditions.

 The Metropolitan Police asked for a condition relating to ‘secured by Design’ to be imposed, which the Council has secured.

 The London Fire Brigade asked for a private fir hydrant to be installed to the south of the site and numbered, which the Council has secured.

 The London Fire and Emergency Planning Authority recommended further fire safety requirements, which will be addressed by Building Regulations and Building Control.

 London City Airport recommended conditions for a construction programme, which the Council has secured.

page 6  The Port of London Authority (PLA) raised concerns about the PLA Link (part of its navigation system), which will need to be diverted for attenuation purposes and fear of further degradation. The applicant will be required to fund this through a s106 agreement and a condition has been recommended.

 The Council for British Archaeology raised concerns about the development causing damage to the listed ponds, however this is not the case and the development will not impact on the historical importance of the site, which is being retained and enhanced ecologically. Article 7: Direction that the Mayor is to be the local planning authority

28 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission with conditions and a planning obligation, which satisfactorily addresses the matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

29 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. The Mayor must also have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction under Articles 6 or 7. Financial considerations

30 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

31 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.

32 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so). Conclusion

page 7 33 The principle of development/flood risk issues has been addressed and a sequential/exception test provided. A number of conditions have also been imposed on the developer by the Environment Agency and thus this matter is satisfactorily resolved. The issues relating to housing mix, affordable housing and accessible housing have also been addressed Further information has also been provided on the children’s play space, design-materials, car park and planting proposals. Matters relating to energy and sustainability have been resolved since stage 1 and the majority of strategic transport issues have been resolved. TfL will continue to work with the Borough to implement ‘Legible London’ around the site and to assist with improvements to the Thames Path as appropriate.

34 Overall the development proposal will enhance the listed docks through ecological improvements and the site’s designation as a Community Open Space will not be lost. The development will be fully mitigated against flooding and any impacts on the River wall, provide an environmentally sustainable scheme with revamped angling facilities for the community, which will also serve an educational function; and appropriate housing mix for local people.

page 8

planning report PDU/1336/01 5 September 2011 Mast Pond Wharf, Woolwich in the London Borough of Greenwich planning application no.11/1584/F

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 erection of a building of between six and sixteen stories comprising 93 residential units, associated car parking and replacement community facilities for Woolwich Dockyard Angling Club.

The applicant is Mast Pond Wharf Limited and the architect is Alan Camp Architects. Strategic issues The key issues for consideration are the principle of development due to the site being within flood zone 3b. The provision of housing and in particular affordable and accessible housing needs to be clarified. Further details of child play space and community use of the Angling Club is needed. Further information and discussion is needed on urban design, flood proofing, energy, sustainability and transport.

Recommendation

That Greenwich Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 85 of this report; but that the possible remedies set out in paragraph 87 of this report could address these deficiencies.

Context

1 On 2 August 2011 the Mayor of London received documents from Greenwich 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 September 2011 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.

The application is referable under Category 1C of the Schedule to the Order 2008:

1. Development which comprises or includes the erection of a building of one or more of the

page 9 following descriptions— (c) the building is more than 25 metres high and is adjacent to the River Thames

2 Once Greenwich 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.

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

4 The 0.6 ha site, referred to as Mast Pond Wharf, is located on the South of the River Thames, adjacent to the Woolwich Dockyard housing estate. It is surrounded by a mix of residential properties of varying heights and ages. The site comprises two listed graving docks and structures which are separated by a rectangular strip of land running north to south down the middle. This contains a redundant building formerly used as a clubhouse for the South East Aquatics Centre. The docks and part of the former clubhouse are now used by the Woolwich Dockyard Angling Club (WDAC) for storage purposes.

5 The site boundary to the north has railings to enclose the docks for security, preventing direct access to the water. Beyond the railings is the Thames path, which is bordered on the other side by a brick flood defence wall. The wall separates the docks and the surrounding residential areas from the Thames, and keeps the docks hidden from the east, west and south.

6 Woolwich Church Street (A206), which forms part of the Strategic Road Network (SRN), is located approximately 200m to the south of the site and can be accessed via Leda Road. The nearest Transport for London Road Network (TLRN) is the A205 John Wilson Street which is approximately 400m south-east of the site.

7 Five bus services are within acceptable walking distance of the site and operate along Woolwich Church Street. Woolwich Dockyard, which is the nearest railway station, is located approximately 550m south-west of the site, while Woolwich Arsenal station which offers both National Rail and DLR services is 1.1km away within Woolwich town centre. The Woolwich ferry service is also located approximately 900m east of the site.

8 The public transport accessibility level (PTAL) rating of this site is 3 out of a 1-6 range where 6 is the most accessible. This equates to a moderate accessibility level.

Details of the proposal

9 The development proposal will be located on the strip of land between the two graving docks and is for 93 residential units comprising 27 one bed flats, 45 two bed flats and 21 three bed flats, along with new community facilities for the WDAC beneath.

10 It is proposed that 15% of the total residential contribution will be affordable housing as 100% shared ownership; 22.5% of the development will comprise family accommodation and 10% of the units will be wheelchair accessible, with their own designated car parking space.

11 The principal bulk of the residential building would be between 10 and 12 storeys in height with a smaller element to 16-storeys.

page 10 12 60 parking spaces would be provided on four levels in a linked five storey building to the south. It would have a communal amenity area at roof level and a green wall extending for the full height of the structure. The main vehicular access would be from Europe Road.

13 Part of the ground and mezzanine floor will be occupied by WDAC, with a residential entrance to the north of the site. Vehicle and pedestrian entrance will be to the south. Further roof level terraces are provided at the twelfth and fourteenth floors. Case history

14 A pre-planning application meeting was held at the GLA on 5 May 2011 and an advice note was issued on 19 May 2011.

Strategic planning issues and relevant policies and guidance

15 The relevant issues and corresponding policies are as follows:

 River Thames/flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B  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  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Childrens play space London Plan; PPG17, draft PPS Planning for a Natural and Healthy Environment  Community facilities London Plan  Tall buildings/views London Plan; RPG3A, Revised View Management Framework SPG  Urban design London Plan; PPS1  Energy London Plan  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  Transport London Plan; the Mayor’s Transport Strategy; PPG13;  Parking London Plan; the Mayor’s Transport Strategy; PPG13

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 Greenwich Unitary Development Plan, adopted in July 20061, and the 2011 London Plan.

17 The pre-submission Core Strategy with Development Management Policies DPD is a relevant material consideration.

1 which has been ‘saved’ by the Secretary of State until such time as they are replaced by the Council’s emerging LDF documents.

page 11 Principle of development

18 This site is located in an Opportunity Area and an Area for Regeneration as set out in the London Plan and as such an application for residential use in the is area is supported in principle. The application site is designated as Community Open Space and the application has been advertised as a departure from this policy. However, the two docks, which make up the majority of the Community Open Space are being retained and enhanced with water filtration and biodiversity features, and an angling club is being provided on the ground floor. The Council should ensure that the residential proposal does not compromise the use of docks as Community Open Space. Flood risk

19 The applicant sets out that the Environment Agency has confirmed that the site must generally be classified as being located within flood zone 3b but that the existing buildings can be considered to be within flood zone 3a. PPS25 sets out that residential development is not permitted in zone 3b. The comments set out below are on the basis that the proposed residential buildings are within flood zone 3a and this will need to be confirmed with the Environment Agency. 20 Within flood zone 3a residential development may be acceptable provided that the sequential/exception test as set down in Annex D of PPS25 is met. The planning statement refers to a Sequential/Exception test report that was agreed with the Council and the Environment Agency. This should be submitted as part of the application and forwarded to the GLA. As such it must be proved that the development provides wider sustainability benefits for the community, is located on previously developed land and that the development will be safe without increasing floodrisk elsewhere and preferably reducing flood risk overall. The applicant has made a number of provisions in the development to deal with flood risk. As such the residential use is situated on the upper floors, the angling club is the only ground floor use and this is designed to be floodable, the buildings have been designed such that there is no loss of flood storage capacity or impediment to flood flows on the site, a small section of the flood wall will be relaligned to create a safe dry escape route, provision of an evacuation plan and implementation of a surface water drainage strategy. 21 The applicant should also provide further information on the operation of lifts during a flood (this is of particular importance, given that it the lift may be necessary for disabled user to escape the building during a flood); whether the building will remain structurally sound under tidal inundation conditions; how the building will be repaired following a flood if necessary and the applicant should confirm that the electrical, water, telecoms and gas supplies will be fitted in a flood proof manner. 22 The Council should ensure that the Environment Agency is satisfied that this form of development is satisfactory in this location and all the appropriate mitigation measures are conditioned. Surface Water Run-off

23 The applicant proposes to discharge the surface water directly into the adjacent dock areas. This is welcomed and in line with London Plan policy 5.13. Construction Materials

24 Given the site’s riverside location, it should be phased and programmed to maximise the use of river transport for the removal of demolition/exaction and delivery of building materials in line with London Plan policy 7.26.

page 12 Housing

25 The proposal includes the provision of 93 residential units, 15% of which will be shared ownership. The proposed mix of units, sizes is as follows: 27 x 1-bed flats (30%); 45 x 2-bed flats (48%) and 21 x 3-bed flats (22%). The applicant states that the development will provide a range of 1, 2 and 3 bed units with 33% of the total residential floor space to be family accommodation. However the applicant has assumed that 2 bed 4 person units are family housing. Clarification is required as to the tenure split of the unit mix. Housing mix

26 London Plan 2011 Policy 3.8 encourages a full range of housing choice. This is supported by the London Plan Housing SPG, which seeks to secure family accommodation within residential schemes, particularly within the social rented sector, and sets strategic guidance for councils in assessing their local needs. Policy 3.11 of the London Plan 2011 states that within affordable housing provision, priority should be accorded to family housing. Recent guidance is also set out in the London Plan Interim Housing SPG (April 2010). Also relevant is Policy 1.1, part C, of the London Housing Strategy, which sets a London-wide target of 42% of social rented and 16% of intermediate homes need to be three bedroom units or larger. 27 The numbers provided for the unit mix vary in the documents provided - the Planning Statement, the Viability Assessment and the Schedule, these need to be clarified. Furthermore, these documents do not specify the number of units that are to be shared ownership and the number that are to be private. This information should be provided before the application is referred back at stage two. Affordable housing

28 London Plan Policy 3.12 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 current and future requirements for affordable housing at local and regional levels, its own overall target for affordable housing provision, and the need to encourage rather than restrain residential development. Policy 3.11 states that borough targets should take account of matters including current and future housing requirements, the strategic targets and priority accorded to affordable family housing, the need to promote mixed and balance communities, and the viability of future development, and that within those targets 60% of affordable housing should be for social rent, and 40% for intermediate rent or sale.

29 The strategic policy does not currently reflect the recent shifts in affordable housing, particularly the amendments to the definitions of affordable housing to include affordable rent products, and changes to funding priorities. 30 15% intermediate units are proposed and a further discussion is needed regarding increasing the affordable rented element. A financial viability assessment has been submitted in support of the planning application. Both the viability assessment and the Planning Statement provided state that the viability assessment results indicate ‘that the scheme would not be able to meet Greenwich Council’s 35% target, as the residual land value would fall well short of the site’s existing use value’. They further state that ‘even with a reduced provision of 15% affordable housing, the appraisal indicates that at current sales values the scheme would be unviable.’ The viability assessment will need to be further interrogated before it can be said that the maximum reasonable amount of affordable housing has been provided. Further discussion will also be needed regarding provision of some affordable rented housing.

page 13 Accessible housing

31 London Plan Policy 7.2 ‘An inclusive environment’ seeks to ensure that proposals aim for the highest standards of accessibility and inclusion (not just the minimum), and that the design process has considered how everyone, including disabled and deaf people, older people, children and young people, will be able to use the places and spaces that are proposed. The GLA strongly recommends that the Council requires an accessibility management plan to be secured by condition, in order to ensure the development meets the highest standards of inclusive design, and is appropriately managed and maintained in terms of access and inclusion.

32 The applicant is proposing to provide seven wheelchair accessible units (7.5%) (10% habitable rooms) and all units will meet Lifetime homes standards. The applicant should increase the number of wheelchair accessible units. There is a discrepancy about the number of accessible units between the Planning Statement and Design and Access Statement and the actual provision should be confirmed.

Childrens play space

33 London Plan 2011 Policy 3.6 advises that “development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” The Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ sets a benchmark of 10 s.q.m. of useable child play space to be provided per child, with under-5 child play space provided on-site.

34 Confirmation is needed of the unit mix in order to calculate child yield accurately based on the mix set out in the preferred option in the viability assessment the child yield is 18. This equates to the provision of 180s.q.m of play space. If the mix changes in accordance with other comments provided in the housing section of the report, then the child yield and corresponding area of play space will increase.

35 Given the constrained nature of the site, the outdoor amenity space at fifth floor level will include a children’s play area. The amount of play space provision being created, and the type and quality of this is unknown.

36 Note has been made of an existing play area within the adjoining Woolwich Dockyard Estate, which is in close proximity of the site, however the level and type of play space provision needs to be clarified and whether it would benefit from improvement. It may be appropriate for a Section 106 contribution to be sought by Greenwich Council to improve this facility.

Community facilities

37 The Planning Statement (paragraph 9.13) states that ‘while the scheme will deliver a relatively low amount of outdoor amenity space on a per unit basis, the development will offer residents a unique living experience in a development where the entire ground level comprises community angling facilities’. However it is also stated in the various application documents that the residents will have to join the club and be members to make use of the angling facilities.

38 The onus is on the applicant to demonstrate using the above methodology within the Mayor’s supplementary planning guidance that its children’s play strategy accords with policy 3.6 of the London Plan. At this stage it cannot be determined whether or not the application complies with the London Plan 2011.

page 14 Tall buildings / views

39 London Plan (2011) policy 7.7, which relates to the specific design issues associated with tall and large-scale buildings, are of particular relevance to the proposed scheme. This policy sets 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.

40 The proposed development would not detrimentally affect any of the protected views as set out within the revised London View Management Framework. It would be set against an emerging context of tall riverside buildings, although it would be in close proximity to existing, low and medium-rise development. The dock isolates the building from its immediate surroundings and provides a useful buffer that sets it apart from existing development. Visualisations provided by the applicant suggest that there would be no unreasonable harm to more distant views, such as across the river from North Woolwich.

Urban design

41 Good design is central to all objectives of the London Plan (2011) and is specifically promoted by the policies contained within chapter seven which address both general design principles and specific design issues. London Plan Policy 7.1 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 and World Heritage Sites, views, the public realm and the Blue Ribbon Network. New development is also required to have regard to its context, and make a positive contribution to local character within its neighbourhood (policy 7.4).

Layout / principles 42 The development is acceptable in strategic design terms, even though the location is not one that would naturally sustain a building, in that it is isolated from surrounding buildings and has an individual set of constraints and opportunities by virtue of this isolation. However the location will offer residents a unique living experience and the building uses this to its advantage, through appropriate dwelling orientation, design of the lower floors and integration of existing river-based uses.

43 The development is in the vicinity of listed buildings/features but is respectful of their setting. The ponds on either side of the proposed building would be retained, and the upgraded facilities for the Angling Club are welcomed. The integration of the existing community use within the building at ground floor level is strongly supported, and will help to create vitality at the ground floor level of this otherwise physically isolated building. Other references to the river location within the building’s design will be welcomed, such as the proposed information panels.

Design and biodiversity

44 The preservation of views between the ponds is supported and will help to preserve the historic relationship between the two. Although the species within the ponds are introduced, the local biodiversity would be maintained by the continuing location of the Angling Club. The inclusion and effective management of a water filtration and oxygenating system would be strongly supported. If possible, this should extend to ensuring that surface debris is regularly cleared. The applicant should confirm whether such features have been incorporated within the proposal.

page 15 Scale and massing 45 The currently proposed mass and scale of the main part of the building appears appropriate. At the pre-application stage, officers raised the possibility that the site could potentially support a taller building than the one presently proposed, subject to limiting of amenity impacts on existing residential development. However, it is recognised that given the constrained proportions of the site, the current scheme represents the most achievable in terms of both build- cost and engineering viability. There are concerns about the mass of the rear (car parking) elements of the building, but these could be mitigated through changes to the appearance, and are discussed within the relevant section below.

Access 46 The integration of the building into the existing urban fabric is of high importance, in terms of both the physical (recognised as a challenge, given that the application site is almost an island) and the social (with the existing surrounding estate). The improvement to existing routes, such as the Thames Path, is welcomed. However, access to the town centre requires improvement, and the Council should ensure that the development would provide an appropriate solution for its residents in negotiating a route to transport facilities and services. Access into the building appears appropriate. The applicant should confirm however that the proposed car lift would not cause unacceptable levels of noise or disturbance for surrounding residents, and that their location and operational ability is suitable, based on flood risk.

47 The details of the accessibility of the public realm including the ways in which less ambulant or disadvantaged groups would approach and occupy the development should be provided.

Appearance 48 The building’s proposed appearance is interesting, with the double-storey external expression working well within the proposed massing. Proposed colours are similar to those of older, surrounding buildings, and while the render materials are not perhaps of the quality that one would expect in this environment, are given relief by the two-storey elements and areas of glazed facade.

49 Officers are concerned about the appearance of the car parking element of the proposed building, specifically the car park itself and the lift tower. Although the appearance of the car park itself, when covered by vertical landscaping, would be reasonably attractive, it is doubtful whether the lush appearance shown in the visualisation could be sustained or managed appropriately in the long-term, especially in a riverside environment. Failure of the landscaping would lead the car park to appear as a mesh-covered, dark and bulky structure, which would be completely incongruous in this location. As such, the applicant should either consider a redesign of the elevations of the car park, or supply a robust strategy to ensure that the landscaping would be suitably managed in perpetuity.

50 The car park lift tower is clad in the same render that is used on the main building, but without relief, with the result that it looks bulky. This is not a successful element of the scheme and it is unclear whether alternative elevational approaches have been tested.

Residential standards 51 The majority of flats would be dual-aspect dwellings, in accordance with the guidelines. Balconies would be provided to all flats, which is also welcomed. Space standards comply and in

page 16 some cases exceed the standards stated in London Plan policy 3.5 Quality and design of housing developments.

Energy BE LEAN

Energy efficiency standards

52 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Energy efficient lighting is also proposed.

53 Before applying the benefit derived from combined heat and power (CHP), the development will be compliant with the 2010 Building Regulations and this is supported.

BE CLEAN

District heating

54 The applicant states that there are no suitable existing or proposed heat networks within the vicinity of the proposed site. The nearest multi-user district heating network is around 1km away.

55 An on-site community heating system is proposed to provide both the ground floor Angling Club and all residential apartments with heating and hot water served from a single energy centre and this is acceptable.

Combined Heat and Power

56 A 25kWe gas-fired CHP unit is proposed as the lead heat source for the community heating system with backup high efficiency condensing gas fired boilers.

57 A reduction in regulated carbon dioxide emissions of 23 tonnes per annum (12.5%) will be achieved through this second part of the energy hierarchy.

Cooling

58 The applicant should provide further information on passive measures to minimise the need for active cooling. If active cooling is provided the applicant should clarify where and how this will be provided.

BE GREEN

Renewable energy technologies

59 25 kWp of photovoltaic panels are proposed for the development at both floor 15 and 10. Roof drawings have been provided.

60 A reduction in regulated carbon dioxide emissions of 8 tonnes per annum (5.4%) will be achieved through this third element of the energy hierarchy.

page 17 OVERVIEW

61 The estimated regulated carbon emissions of the development are 78 tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures, CHP and renewable energy has been taken into account. This equates to a reduction of 31 tonnes per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 28%.

62 The energy strategy is broadly in line with London Plan policy. Further information is needed on the cooling strategy before it can be stated that the energy strategy is in line with London Plan policy.

Sustainability

63 London Plan climate change policies, set out in Chapter 5, collectively require developments to make the fullest contribution to the mitigation of, and adaptation to, climate change, and to minimise carbon dioxide emissions. London Plan Policy 5.2 sets out an energy hierarchy for assessing applications, London Plan Policy 5.3 ensures future developments meet the highest standards of sustainable design and construction, and London Plan policies 5.9-5.15 promote and support the most effective climate change adaptation measures including passive thermal regulation, urban greening, and water management.

Water Efficiency

64 The applicant is proposing for the development to reduce water consumption by less than 90 litres per person per day, in order to exceed the Code Level 4 requirements within the Code for Sustainable Homes. Water meters will be installed in each dwelling and for the Angling Club so that each tenant and user is charged for their individual consumption. The dwellings will include taps with flow restrictors, installation of efficient kitchen water appliances and WCs will have dual flush systems.

Urban greening-green walls and biodiversity enhancements

65 London Plan Policy 5.10 seeks to promote and support urban greening, such as new planting in the public realm, and green infrastructure, to contribute to the adaptation to, and mitigation of, the effects of climate change. The applicant has proposed to incorporate low maintenance green living walls to the outer edges of the four storey car park walls to cover the steel mesh cladding with natural climbing plants. This complements the natural element of the proposal-the two ponds and the biodiversity enhancements proposed. It also softens the nature of the proposal, and will contribute towards the mitigation of its contribution to the urban heat island effect. Biodiversity measures are also being explored for the ponds to have species introduced, so to enhance the ecological value of the natural features.

66 For design reasons further information has been requested regarding the nature of the green walls and their maintenance.

Transport

Car Parking

67 A total of 60 car parking spaces are proposed for the 93 residential units. Excluding the 2 spaces to be used by a car club provider, this therefore equates to a provision of 0.6 spaces per unit. Although in line with the London Plan parking standards, TfL would encourage the applicant

page 18 to consider reducing this provision further given the already congested nature of the highway, particularly the Woolwich ferry roundabout.

68 TfL welcomes the provision of eight blue badge parking bays, split equally over four storeys. However, TfL would request the provision of a further blue badge parking bay at ground level for use by angling club members. Additionally, TfL requires electric vehicle charging points (EVCP) to be provided at a ratio of 20% active, plus 20% passive in line with London Plan EVCP standards.

69 Confirmation of the above will ensure conformity with London Plan Policy 6.13 Parking.

Cycling

70 TfL welcomes the provision of 123 cycle parking plus eight visitor spaces which ensures compliance with the London Plan standards.

71 The development is situated close to the proposed Route 4 of the Barclays Cycle Superhighway (BCS) which would run along the A206 Woolwich Church Street. The development should therefore secure improvements to the local cycle network to complement the BCS Route 4 and further promote cycling in conformity with London Plan Policy 6.9 Cycling. TfL considers that this would be best achieved by particularly improving access along the Thames Path. Consequently, TfL requests the developer to fund the improvement of the existing pedestrian / cycling links through the construction of two new bridges across the Thames Path parallel to the site. This route would enhance the existing cycling / pedestrian environment, including linkages to Woolwich town centre and provide a safer and quieter route between the Woolwich Ferry Roundabout and Frances Street where the Woolwich Dockyard rail station is located.

Walking

72 TfL requests that a contribution to ‘Legible London’ wayfinding is made to connect the site with Woolwich Town Centre and Dockyard stations. Discussions should take place with the London Borough of Greenwich and TfL to determine the suitable locations and design of the posts so that an appropriate contribution can be secured through the s106 agreement. Confirmation of the above will ensure compliance with London Plan Policy 6.10 Walking.

Bus Network Development

73 TfL is satisfied that this development will have a negligible impact upon the operation of the local bus network and therefore considers the proposals to be in conformity with London Plan Policy 6.3 Assessing effects of development on transport capacity.

Servicing and Delivery

74 TfL welcomes the applicant’s commitment to the production and submission of a Delivery Servicing Plan (DSP). This is to be formalised through planning conditions.

Construction Impact

75 Similarly, TfL welcomes the production and submission of a Construction Management Plan (CMP) and is satisfied with the details provided at this stage. Given the site’s location, the use of the river is expected to be maximised during the construction phase. TfL requests that the submission of the proposed CMP, including the potential use of the river, be formalised by condition to ensure conformity with London Plan Policy 6.14 Freight.

page 19 Travel Plan

76 TfL welcomes the submission of a full travel plan and requests this to be secured through the s106 agreement. A wide range of green travel planning measures should be included, monitored and funded through the travel plan. Those could consist of subsidised Oyster cards, cycle vouchers/free bicycles, subsidised car club membership, marketing and promotional events, etc. An appropriate figure, to fund their provision should be agreed with TfL and secured within the s106 agreement. The above will ensure conformity with London Plan Policy 6.3 Assessing effects of development on transport capacity.

Olympic Route Network

77 The A206, Woolwich Church Street is part of the Olympic Route Network (ORN). Therefore, the applicant should be aware that the operation of the highway will be altered during the time the ORN is in operation. Any works planned during this period that will affect the ORN must be stated in the CMP.

78 The ORN and Paralympic Route Network (PRN) will operate during the Olympic and Paralympic Games period, between June and September 2012. During this period, there will be an impact on construction works, utility works and highway licensed activities (for example, skips and building materials) if they affect the roads designated as a part of the ORN/PRN and some of the surrounding streets. Other routes might also be affected and will also be required to be clear of any kinds of obstruction.

79 Given the above, highway works and licences could therefore be affected on occasions during the Games period. Requests to utility providers to provide any additional water, gas, electricity or telecommunications connections should also be made sufficiently well in advance of this period.

80 These comments are for information only and is provided without prejudice to the legal rights of the ODA or any other relevant authority whether under the London Olympic Games and Paralympic Games Act 2006, planning, traffic or highway legislation or otherwise. Further information and the latest news on the ORN and PRN can be found on the London 2012 website at http://www.london2012.com/olympic-route-network/home.html

Summary

81 Before it can be said that the application is in line with London Plan policy the number of car parking spaces proposed needs to be further reduced, a contribution should be committed to towards ‘Legible London’ way finding and contributions should be committed to assist improvements to the Thames pathway and cycle links to compliment the BCS4 route. Furthermore, the CMP and DSP should be secured by planning conditions, in addition to the Travel Plan being secured within the s106 agreement. Local planning authority’s position

82 Undecided at present. Legal considerations

83 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

page 20 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

84 There are no financial considerations at this stage. Conclusion

85 London Plan policies on flood risk, housing, affordable housing, accessible housing, children’s play space, tall buildings/views, design, energy, sustainability and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Principle of development/ flood risk: Various operational and safety issues have been raised in paragraphs 19-24 of the report in relation to flooding at this site. Whilst mitigation measures are proposed, no commitment to their implementation is made. The various points raised should be addressed as these flood risk issues are of an order which may mean that the Mayor may direct refusal unless appropriate assurances can be given. The Council will need to also verify whether the development proposal will provide sufficient compensatory provision at this site in light of the fact that this site is designated as a Community Open Space within the Greenwich UDP proposal map.

 housing: The applicant is proposing to provide 15% affordable housing units at 100% shared ownership, with the remaining housing to be private accommodation. No social rented or affordable rented provision is being provided. This needs to be reconsidered. The numbers provided for the housing unit mix vary in the various documents provided. The number of units to be in shared ownership and those which are to be private are not specified and thus the calculations for unit mix haven been assumed and based on the viability assessment numbers.

 affordable housing: The Planning Statement and the viability assessment indicate that the reduced provision of 15% affordable housing would still make the scheme unviable at current sales values. This needs testing to prove it is the maximum reasonable amount.

 accessible housing: The applicant has failed to provide an accessibility statement which details the exact number of wheelchair accessible units, Lifetime units and adaptable units. The adaptations being proposed in order to make some rooms accessible is unknown.

 childrens play space: Due to the uncertainty in housing unit mix and numbers to be in shared ownership and private, the child yield has been assumed based on the tenure chart within the viability assessment. These figures needs to be clarified. The applicant is also advised to provide details of the quantum and nature of private amenity spaces in the proposal. The amount, type and quality of play space provision being created on the fifth floor of the scheme is unknown

page 21  design/sustainability: Due to the site’s isolation, the applicant should explore access improvements to the town centre for the residents, alongside routing for transport facilities and services to access the site. Access and occupation into the building by less ambulant or disadvantaged groups should be demonstrated in an Access Statement. Greenwich Council should explore further the car lift proposal. Alternative elevational approaches in design for the lift shaft cladding should be demonstrated as the current render appears to be bulky. The inclusion of water filtration, biodiversity enhancements and green wall should be maintained and a management plan for these incorporated in the proposal. Further, the landscaping proposed should have a management strategy in perpetuity.

 energy: The applicant is required to provide further information on passive measures to avoid cooling of the building. If cooling measures ate proposed then the applicant should state how this will be provided. This outstanding information will enable the carbon savings of the scheme to be calculated.

 transport: A reduction in the number of car parking spaces proposed is recommended. Another blue badge parking slot is required on the ground floor for users of the angling club, and developer contributions are sought for two new bridges across the Thames Path parallel to the site to improve pedestrian and cycle access, to compliment the BCS4 route. Contribution is also required towards ‘Legible London’ way finding. Furthermore, the CMP and DSP should be secured by planning conditions, in addition to the Travel Plan secured within the s106 agreement.

86 On balance, the application does not comply with the London Plan.

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

 Principle of development/ flood risk: The exceptions/sequential test document needs to be provided. The various flood mitigation measures need to be agreed by the Environment Agency and secured by the Council.

 housing: Independent testing of the toolkit is necessary. Consideration of other forms of tenure is also required.

 affordable housing: The applicant needs to clarify housing figures and units mixes etc so that it is possible to make an assessment as to whether the maximum reasonable amount of affordable housing is being provided in accordance with policy 3.12

 accessible housing: The applicant is required to produce an access statement clarifying the above mentioned outstanding matters.

 children’s play space: The applicant needs to demonstrate using the methodology within the Mayor’s supplementary planning guidance that its children’s play strategy accords with policy 3.6 of the London Plan. At this stage it cannot be determined whether or not the application complies with the London Plan 2011. The Play Strategy should also be provided.

 design/sustainability: Particular attention should also be given to the comments raised in the urban design section and sustainability sections of this report.

 energy: The applicant should address the outstanding energy issues raised to allow for a carbon savings rating to be calculated for the scheme.

page 22  transport: The various outstanding transport issues raised in the transport section of this report and above conclusion should be addressed. Relevant conditions and S106 agreements will need to be devised by Greenwich Council.

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] Sukhpreet Khull, Case Officer 020 7983 4310 email [email protected]

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