planning report PDU/2187a&2188a/02 13 May 2009 City Pride and Island Point, Westferry Road in the London Borough of Tower Hamlets planning application no. PA/08/02292/3

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 City Pride – The erection of a part 9, part 62-storey tower comprising 430 residential units, 203- bed hotel with conference facilities, spa, swimming pool, gymnasium, reception and lounge bar.

Island Point – The erection of six buildings ranging in height from 2 to 8 storeys comprising 189 residential units.

The applicant The applicant is Glenkerrin Ltd, and the architect is Fosters and Partners and Darling Associates.

Strategic issues The principle of the redevelopment of both sites to provide residential led developments is in the interest of good strategic planning in London. Further clarification and information has been provided regarding affordable housing, child play space, climate change mitigation and transport. On the basis of this information the applications are consistent with London Plan policy.

Recommendation That Tower Hamlets 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 11 November 2008 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. This was referred to the Mayor under Category 1A of the Schedule to the Order 2008: “”Development which comprises or includes the provision of more than 150 houses, flats or houses and flats.” It is also referable under category 1B “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 in Central London (other than the City of London) with a total floorspace of more than 20,000 sq.m”, and category 1C “Development

page 1 which comprises or includes the erection of a building of one or more of the following descriptions, the building is more than 30 metres high and is outside of the City of London”.

2 On 17 December 2008 the Mayor considered planning report PDU/2187a & 2188a/01, and subsequently advised Tower Hamlets Council the application did not comply with the London Plan, for the reasons set out in paragraph 97 of the above-mentioned report; but that the possible remedies set out in paragraph 99 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 15 April 2009 Tower Hamlets Council decided that it was minded to grant planning permission, and on 30 April 2009 it advised the Mayor of 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 Tower Hamlets Council under Article 6 to refuse the application or issue a direction to Tower Hamlets 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 13 May 2009 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

Affordable housing

5 The stage I report stated that further evidence should be provided to demonstrate that the concentration of affordable housing in the south of the wouldn’t overload the existing social infrastructure. The findings of the independent economic appraisal of the proposed quantum of affordable housing should also be submitted to allow GLA officers to assess whether the proposed quantum of affordable housing represents the maximum reasonable amount.

6 The applicant has submitted a summary of the socio-economic chapter in the environmental statement. This confirms that the if the Island Point development were to be considered in isolation the existing infrastructure provision would be able to absorb the demand generated from the development. However, given the amount of planned redevelopment on the Isle of Dogs the applicant has confirmed they will make S106 contributions towards community facilities, health, education and employment to mitigate the demand on the social infrastructure of the development at Island Point on the Isle of Dogs. The amount is currently being discussed with Tower Hamlets Council. This should prevent the proposal from overloading the existing social infrastructure.

7 The applicant has also submitted a breakdown of housing tenure for , the ward within which the site is located, the surrounding wards of Blackwall and and the borough average. The information was taken from the Tower Hamlets Council census data.

page 2 Ward Tenure Millwall Blackwall & Cubitt Borough Average Town Council 19% 28% 38% RSL 13.4% 11% 15% Mortgage 27.3% 24.6% 19% Outright Own 7% 7.6% 8% Private Rented 29% 24% 15% Shared Ownership 1% 1.7% 2%

8 The census data confirms that Millwall contains less Council and housing association ownership than the surrounding wards and the borough as a whole. The applicant states the proposal will address the under supply of rented accommodation and intermediate housing for this ward.

9 The independent assessment of the financial appraisal of the proposals was submitted to GLA officers for assessment. It appeared to suggest that there might be additional value in the scheme, which could be used to provide additional affordable housing. After raising this concern with the applicant, the applicant submitted additional information to confirm, that there is no additional value. In fact the scheme as it currently stands has a £17 million deficit shown in the toolkit. This is the worst-case scenario for the applicant who is hoping to reduce this deficit as the housing market stabilises. As such the proposed offer of 41% affordable housing is considered to be the maximum reasonable amount. The proposal therefore complies with policy 3A.9 and 3A.10 of the London Plan.

Children’s play space

City Pride

10 The stage I report highlighted a discrepancy over the estimated child population and requested the applicant to submit the methodology used to estimate the child population. Concern was also raised over the quantum of child play space being provided.

11 Following these comments the applicant has submitted the methodology used by the applicant, a breakdown of the calculated child yield and details of the surrounding parks. The applicant has used the Wandsworth child yield model to calculate the estimated child population.

12 The applicant proposes to provide 220 sq.m. of on site child play space for children under 5 years old and to make a S106 contribution to Tower Hamlets Council to cover the provision of up to 60 sq.m. of playspace for 5-11 years olds and 30 sq.m. for 12–15 year olds. The applicant has indicated that there are three parks surrounding the site, the closest of which is Sir John McDougal Park approximately 400 metres away and the furthest of which Poplar recreation ground over 800 metres away.

13 The use of the Wandsworth methodology on which the Mayor’s SPG is based to estimate the child population for the development is acceptable as is the provision of 220 sq.m. of child play space for the under 5s. Given the location of the development and the constraints of the site the provision of off site play space for children over 5 years old is also acceptable. As a result the development complies with policy 3D.13 of the London Plan.

Island Point

page 3 14 The stage I report requested the plans were amended to provide a kick about area for children over 12 years of age.

15 The stage 1 report also stated that there is an under provision of child play space of 517 sq.m. Following this the applicant has confirmed that the inclusion of the semi-private gardens to the east of block C of approximately 566 sq.m. as play space. The proposal will now provide an over provision of play space.

16 Given the proximity and quality of existing play facilities for children over 12 years of age the applicant does not consider there to be a need for an on site kick about area. Instead the applicant proposes to make a financial contribution towards their upkeep. The applicant also states that although some of the play space is not designated as a kick about area it could be used as such. In particular the grass at the north of the site, the incidental play street, the home zone area and the semi-private gardens east of building C. The applicant also states that the Play Association for Tower Hamlets are impressed with the existing proposal for child play space and have presented a clear view that the site would not benefit from a designated kick about area and may act to produce less adequate play provision as it excludes the majority of children. Whilst it is disappointing the indoor kick about area has been removed from the scheme, given the quantum and quality of the proposed child play space and the proximity and quality of the surrounding play facilities for children over 12 years of age the proposal will meet the needs of the residents and complies with policy 3D.13 of the London Plan.

Climate change mitigation

City Pride

17 The stage I report requested further information to assess whether the proposal complied with the London Plan energy policies. In particular, confirmation of whether there is more room to reduce the demand of energy in the residential units, why the Barkentine district heat network can not provide all of the heat requirement of the development, the alternative energy strategy if use of the dock water or aquifer is not possible and why dock water could not provide direct cooling to the residential element.

18 This information was submitted and a meeting was held between GLA officers, Tower Hamlets Council’s energy officer and the applicant’s energy consultant to discuss the findings. GLA officers are satisfied that the development will provide demand reduction measure beyond the minimum buildings regulations and that there is no room to reduce the demand of energy for the residential units in this instance. GLA officers are content that due to the complexities of returning the water to Barkentine at a constant temperature of 55 degrees centigrade, it is unable to take all of the heat demand of the development from the district heat network.

19 GLA officers also raised concern over the provision of individual heat pumps in the residential units. The provision of individual heat pumps would not comply with London Plan policy. As such the applicant has confirmed they will not be provided and Tower Hamlets Council has included a condition in the draft decision notice to ensure they are not installed.

20 Tower Hamlets Council have also included conditions to ensure the proposed energy centre and strategy is built and maintained in accordance with the agreed strategy. As such the proposal complies with London Plan polices on energy.

Island Point

page 4 21 The stage I report requested further information to assess whether the proposal complied with the London Plan energy policies. The applicant submitted this information and confirmed that the proposals demand reduction measures are acceptable and that the proposal has been ’future proofed’ to allow it to hook up to the Barkentine district heat network if it extends to the southern end of the peninsular in the future. The applicant also confirmed the arrangements for selling electricity from the combined heat and power plant and the detail of the supply, delivery and storage of the biomass fuel. As such the proposal complies with London Plan energy policies. ’s comments

City Pride

22 At stage I TfL raised concerns about traffic impacts, the need to upgrade bus stops, increase bus capacity and provide DLR DAISY information displays and to secure travel plans, delivery and servicing plans and construction logistics plans. The provision of car parking and cycle parking was consistent with the London Plan. Concerns about the pick up and set down arrangements for coaches and the need to bring dropped kerbs up to standard as highlighted in the pedestrian audit have been addressed.

23 TfL had been seeking a contribution towards improvement works at the Upper Bank Street/Aspen Way junction and Preston’s Road roundabout. Following the receipt of further information on traffic impacts, TfL accepts that there is no longer any requirement for a contribution towards these works.

24 Following completion of a bus stop audit a contribution of £20,000 to improve bus stops in accordance with TfL’s Bus Stop Accessibility guidance has been agreed. A contribution of £200,000 has also been agreed to provide additional capacity on local bus services. The applicant will also provide DLR DAISY information displays in communal areas. These will all be secured through the section 106 agreement alongside the submission and implementation of travel plans, a delivery and servicing plan and a construction logistics plan. All these provisions are welcomed and as a result TfL has no outstanding concerns.

Island Point

25 At stage 1 TfL stated that the level of car parking was in accordance with the London Plan although a lower level of parking would be welcomed and sought confirmation that visitor cycle parking would be provided. The developer was asked to carry out a review of walking routes, pedestrian crossings and bus stops. A contribution towards additional bus capacity and provision of DAISY information displays was requested. TfL also requested additional information on servicing and the submission of a travel plan, delivery and servicing plan and constructions logistics plan.

26 In correspondence with the applicant’s transport consultants it has been confirmed that space for 20 cycles will be available for visitors and that a formal cycle route will be provided along the Westferry Road frontage. Further information has been provided on pedestrian routes and crossings and following a review of bus stops a contribution of £20,000 has been agreed to upgrade the two nearest bus stops. A contribution of £113,400 has also been agreed to provide additional bus capacity and the applicant will provide DAISY information displays in communal areas of the building. These will all be secured through the section 106 agreement alongside a travel plan, delivery and servicing plan and construction logistics plan. As a result of these provisions, TfL has no outstanding concerns about the development.

Other comments

page 5 City Pride

27 CABE support the height and massing of the main tower, and welcome the revised massing of the hotel. The principle of providing the affordable component of this development off-site is supported. It feels more work is needed to improve the relationship of the tower to 22 Marsh Wall and the existing pumping station. The revised, horizontally emphasised façade treatment has potential but the articulation of the amenity spaces should be developed so that more contrast is articulated in the long distance views and the design of the top should be reviewed. It has every confidence in the team’s ability to address these concerns.

28 English Heritage does not wish to offer any comments on this proposal.

29 British Waterways does not wish to object but requests a small set back from the adjacent 1920s pumping station to make the development less overbearing and improve the street scene. It seeks the use of water borne transport for the transportation of construction materials and a contribution of £50,000 towards noise mitigation measures for the existing pump house. It also supports the use of the canal water for heating and cooling.

30 Thames Water state that the existing water infrastructure has insufficient capacity to meet the additional demands for the proposed development and have requested a condition to ensure an impact study of the existing water supply infrastructure is submitted and approved by the council.

31 Environment Agency has no objection subject to the inclusion of suggested conditions and informatives to the decision notice.

32 Natural England does not object to the application. However, they suggest the council secures biodiversity enhancements through planning conditions.

33 London Fire and Emergency Planning Authority state the general information provided would indicate that bridge access will be satisfactory, it would also appear that providing existing water supplies are retained, the water supplies for the fire authority will also be satisfactory.

34 National Air Traffic Services has no safeguarding objections to the proposal. and has no safeguarding objection to the proposal.

35 Council object to the proposal due to its height, scale and bulk, which is considered to be detrimental to the local views enjoyed from the within the Greenwich Borough.

36 Council raise no objection.

37 BBC is unsure if the effect of the tower on analogue television are greater than in the environmental statement, although the effects on digital television are likely to be correct.

38 Tower Hamlets Council received 15 letter of objection, one of which contained a petition signed by 729 people. The Mayor also received two letters of objection signed by nine residents associations and one resident. The objections included:

• Overdevelopment • Density • Height • Design and materials • Off-site affordable housing • Loss light and privacy • Traffic congestion • Lack of social infrastructure

page 6 • Loss of the pub • Provision of a hotel • Impact on pedestrian and cyclist movement • Dust, noise, dirt and traffic disruption during construction • More flats will bring the value of existing properties down

Island Point

39 CABE support the principle of providing the majority of the affordable component of this joint development with City Pride at Island Point. It allows for the provision of a greater variety of accommodation and amenity space suitable for families, within this development as whole, than development of City Pride alone could offer. It also supports many of the principles of the application including massing, site layout and residential mix. However, it has raised concern over the 4 and 5-bed ground floor units on Westferry road do not provide quality family accommodation. Tower Hamlets officers have stated in the committee report that the family units in question exceed the council’s residential space standards and meet the daylight/sunlight criteria.

40 English Heritage does not wish to offer any comments on this proposal.

41 London Fire and Emergency Planning Authority are satisfied with the proposal.

42 Environment Agency has no objection subject to the inclusion of suggested conditions and informatives to the decision notice.

43 Thames Water raise no objection to the proposal.

44 Natural England welcomes the inclusion of the proposed biodiversity enhancement measures.

45 Greenwich Council raise no objection to the proposal.

46 Tower Hamlets Council received 219 letters of objection. The Mayor also received two letters of objection signed by nine residents associations and one resident. The objections included:

• Density • Provision of off-site affordable • Tenure mix • Height and bulk • Design and materials • Loss of daylight and privacy • Possible security and policing problems • Location of rubbish bins • Location of pedestrian access • Impact on social infrastructure • Impact on Conservation Area • The site should provide a supermarket • Traffic congestion

47 Tower Hamlets Council also received a statement of support for the proposal signed by 141 people and 37 individual letters of supporting the provision of good quality affordable family housing, the provision of green amenity space and the redevelopment of a derelict site which is an eyesore.

page 7 Response to consultation

48 Loss of privacy, light, localised noise and dust pollution are not strategic planning matters and have been dealt with by Tower Hamlets Council. The devaluation of property is not a planning matter.

49 The issues surrounding off site affordable and the unsuitability of the City Pride site for family sized affordable housing were discussed in the previous report. In short, the provision for more affordable housing at the City Pride site would increase the need for amenity space on the constrained site. The number of family sized units would also be reduced which would in turn reduce the likely hood of receiving of grant funding. In contrast the Island Point development will provide good quality affordable housing with large family units with access to high quality amenity and children’s play space.

50 The issues surrounding the design of the proposals were discussed in the previous report. The City Pride development is a generally well-considered tower within the cluster. It has a slim elegant profile, the articulation of the façade reflects the uses within the building with large triple height amenity spaces being provided at upper levels and it should add positively to the London skyline. The tower is located win the Isle of Dogs opportunity area which is identified as a location for tall buildings development sin the London Plan. GLA and Tower Hamlet officers are satisfied that the revised massing of the tower results in a better relationship with 22 Marsh Wall.

Figure 1: Drawing showing City Pride tower in red within the Canary Wharf Cluster (source: the applicants DAS)

51 The Island Point development is also well considered and sits comfortably between the 2- storey terraces to the north and the 7 to 9-storey flats to the south.

page 8

Figure 2: Model of Island Point development -proposal shown in white (source: the applicants DAS). Article 7: Direction that the Mayor is to be the local planning authority

52 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 that matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

53 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

54 Should the Mayor direct refusal; he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 8/93 (‘Award of Costs in Planning and Other (including Compulsory Purchase Order) Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

55 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

page 9 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.

56 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

57 The principle of the redevelopment of both sites to provide residential led developments is in the interest of good strategic planning in London. Further clarification and information has been provided regarding affordable housing, child play space, climate change mitigation and transport. On the basis of this information the applications are consistent with London Plan policy.

for further information, contact Planning Decisions Unit: Giles Dolphin, Head of Planning Decisions 020 7983 4271 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Colin Wilson, Strategic Planning Manager (Planning Frameworks) 020 7983 4783 email [email protected] Kim Hoffman, Case Officer 020 7983 6589 email [email protected]

page 10

planning report PDU/2187a&2188a/01 17 December 2008 City Pride & Island Point, Westferry Road in the London Borough of Tower Hamlets

planning application no. PA/08/02292/3

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 City Pride – The erection of a part 9, part 62-storey tower comprising 430 residential units, 203- bed hotel with conference facilities, spa, swimming pool, gymnasium, reception and lounge bar.

Island Point – The erection of six buildings ranging in height from 2 to 8 storeys comprising 189 residential units.

The applicant The applicant is Glenkerrin Ltd, and the architect is Fosters and Partners and Darling Associates.

Strategic issues The principle of the redevelopment of both sites to provide residential led developments is in the interest of good strategic planning in London. In broad terms the application complies with London Plan policy but in some circumstances further information is required to ensure compliance. Further information is required on affordable housing; children’s play space, climate change mitigation, air quality and transport.

Recommendation

That Tower Hamlets Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 97 of this report; but that the possible remedies set out in paragraph 97 of this report could address these deficiencies.

Context

58 On 11 November 2008 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 22 December 2008 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 11 59 The application is referable under Category 1A of the Schedule to the Order 2008: ”Development which comprises or includes the provision of more than 150 houses, flats or houses and flats.” It is also referable under category 1B “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 in Central London (other than the City of London) with a total floorspace of more than 20,000 sq.m”, and category 1C “Development which comprises or includes the erection of a building of one or more of the following descriptions, the building is more than 30 metres high and is outside of the City of London”.

60 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.

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

62 The proposal comprises two sites. The first, the City Pride site at 15 Westferry Road is located to the west of West India Dock South. The site is bounded by the A1206 Westferry Road to the west, Marsh Wall to the east, a pump house to the north and 22 Marsh Wall, a new high-rise residential development, to the south. The A1261 Aspen Way, which forms part of the Transport for London Road Network, is approximately 680 metres to the north.

63 The site is well served by public transport with Heron Quays DLR station 250 metres to the east and Canary Wharf DLR station 400 metres to the north-east. Canary Wharf underground station () is 520 metres to the east and South Quay DLR is 420 metres south-east of the site. Five bus routes: 277, D3, D7, D8, 135 and N50 are accessible from the site. Correspondingly, the public transport accessibility level of the site is 5 (on a scale where 6 is high and 1 is low).

64 The second, the Island Point site at 443-451 Westferry Road, is located towards the southern tip of the Isle of Dogs on the northern side of Westferry Road, west of Millwall Park. The site fronts directly onto the A1206 Westferry Road and is bounded by residential developments off Chapel House Street to the north and west. Residential apartments around Lockesfield Place lie immediately to the east of the site. The area is characterised by 2-storey dwelling houses and taller flatted developments.

65 The site is served by two DLR stations; Mudchute station, 450 metres north-east of the site and Island Gardens station, 500 metres to the east. The site is well served by buses with three bus routes running along Westferry Road and two other routes serving stops on Spindrift Avenue and East Ferry Road. Other public transport infrastructure includes Canary Wharf Underground station 1.7 kilometres to the north, Greenwich National Rail station 1000 metres to the south and Masthouse Terrace Pier, 500 metres west of the site. Correspondingly, the public transport accessibility level of the site is 3 (on a scale where 6 is high and 1 is low).

Details of the proposal

66 The proposal is for the development of both sites. The proposal for the City Pride site comprises a part 9, part 62-storey building providing 412 residential units and a 203-bed hotel with conference facilities, spa, swimming pool, gymnasium, reception and lounge bar with associated car and cycle parking. The Island Point site will provide the majority of the affordable housing for the City Pride development.

67 A breakdown of the residential units for City Pride is shown below.

page 12 Private Social rented Intermediate Total % Studio 57 0 0 57 13 1 bed 158 0 4 162 38 2 bed 168 0 14 182 42 3 bed 29 0 0 29 7 Total 412 0 18 430 % 96 0 4

68 The proposal for Island Point comprises six buildings ranging in height from 2 to 8 storeys providing 189 residential units with associated car and cycle parking.

69 A breakdown of the residential units for Island Point is shown below.

Private Social rented Intermediate Total % 1 bed 8 18 10 36 20 2 bed 12 9 28 49 27 3 bed 3 29 10 42 23 4 bed 0 44 0 44 24 5 bed 0 18 0 18 6 Total 23 118 48 189 % 12 62 26

70 Overall, across both sites, the residential breakdown is shown below.

Private Social rented Intermediate Total % Studio 57 0 0 57 9 1-bed 166 18 14 198 32 2-bed 180 9 42 231 37 3-bed 32 29 10 71 12 4-bed 0 44 0 44 7 5-bed 0 18 0 18 3 Total 435 118 66 619 100 % 70 19 11

Case history

71 In July 2008 the applicant applied for the erection of a 62-storey tower and 14-storey podium at City Pride, comprising 430 residential units, a 209-bed hotel, 18 serviced apartments together with ancillary restaurants, conference facilities, health club and associated car and cycle parking. Permission was also sought for the erection of six buildings ranging in height from 2 to 8 storeys to

page 13 provide 189 residential units with associated car and cycle parking. These applications were withdrawn by the applicant and to allow for the alteration to the podium at City Pride (a reduction in height from 14 to 9 storeys and a revised footprint).

72 The current proposal is an amendment to the earlier withdrawn proposal. Strategic planning issues and relevant policies and guidance

73 The relevant issues and corresponding policies are as follows:

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

74 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 Tower Hamlets Unitary Development Plan 1998 and the London Plan (Consolidated with Alterations since 2004).

75 The Tower Hamlets Core Strategy issues and options document and the interim Core Strategy are also relevant material considerations. Principle of use

76 The City Pride site is located in the Isle of Dogs opportunity are, which is identified in the London Plan as being capable of accommodating at least 10, 000 additional dwellings and states that “conversion of surplus business capacity south of Canary Wharf could add to this, helping to meet London’s strategic housing need and support a wider mix of services for residents, workers and nearby communities” (para 5.15). Mixed-use developments and densities which support the Isle of Dogs interdependence with central London and the Central Activities Zone (CAZ) are also supported. The principle of a mixed-use redevelopment of the site is therefore acceptable in strategic planning terms in accordance with policy 5G.3 of the London Plan.

77 Tower Hamlets Council should consider limiting the occupation of hotel rooms to 90 days in accordance with the London Plan Housing SPG (November 2005) and Greater London Council (General Powers) Acts 1973 and 1983, through a suitably worded planning condition and thus ensure accommodation for business travellers and tourists is safeguarded.

78 The provision of residential accommodation on the Island Point site is supported by policy 3A.1, which seeks to increase London’s supply of housing. Policy 3A.3 seeks to ensure that development proposals achieve the maximum intensity of use compatible with the local context, the design principles in policy 4B.5 of the London Plan and with public transport capacity. The principle of residential accommodation on this site is therefore acceptable.

page 14 79 This application will help contribute to meeting the minimum housing targets as set out in table 5C.1 of the London Plan as well as contributing to objectives set out in London's Economic Development Strategy with regards to the delivery of healthy sustainable, high quality communities and urban environments. Density

80 London Plan policies 4B.1 and 3A.3 outline the need for development proposals to achieve the highest possible intensity of use compatible with local context, the design principles of the compact city, and public transport accessibility. Table 3A.2 of the London Plan provides guidelines on density in support of policies 4B.1 and 3A.3.

81 The proposed residential density for the City Pride site is 4,172 habitable rooms per hectare. This exceeds the guidance in table 3A.2, which provides a guidance range of 650-1,100 habitable rooms per hectare for central sites with a public transport accessibility rating of 6. However the site is relatively small and most of its ground floor area is developed over, this combined with its height produces a relatively high density. Subject to the design, residential quality and open space issues and given the predominance of studio, 1 and 2-bedroom market units, this density is not out of context with the character of surrounding development and the site’s Canary Wharf location.

82 The proposed residential density for the Island Point site is 545 habitable rooms per hectare. This meets the guidance in table 3A.2, which provides a guidance range of 450-700 habitable rooms per hectare for central sites with a public transport accessibility rating of 4. Affordable housing

83 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 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.

84 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

85 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.

86 The original target of 25% affordable housing as set by the Tower Hamlets UDP was not saved by the Secretary of State in September as part of the saved policies exercise.

87 The Mayor’s Housing supplementary planning guidance states “Consideration should normally only be given to off-site provision where an alternative site or sites have been identified which would enable affordable housing provision more appropriate to the identified needs to be set and

page 15 where the project is deliverable prior to the on site market development being completed. Agreements for off-site provision should be financially neutral in terms of the benefit to the applicant relative to on-site provision requirements

88 The applicant has submitted an affordable housing statement and economic appraisal to explain the rational behind and benefits of the provision of off site affordable. In summary, the appraisal states it will allow a greater quantum of affordable housing, a better mix of affordable housing, a better range of affordable housing unit types, including terraced housing and better quality affordable housing. The applicant is also keen to stress that the Island Point site will provide an exemplar development, providing well-designed large family units, good access to amenity and children’s play space, which will not be possible at City Pride.

89 Tower Hamlets Council has issued two letters dated 21 February 2008 and 31 July 2008 stating that the principle of off-site affordable housing is likely to be acceptable.

90 The applicant has demonstrated the benefits of providing off site affordable housing for the City Pride site, and has also provided additional justification for the concentration of social rented on the Isle of Dogs. The applicant has also submitted some information on the impact of the proposal on the existing social infrastructure. This concludes that the proposal would have an adverse cumulative effect unless S106 contributions are made. However, there is no evidence to back up the findings or the level of the adverse effect. Further information should be provided mapping the location and availability of primary healthcare and educational services/facilities and the level of future demand. The applicant should prove that the proposal wouldn’t overload the existing social infrastructure.

91 The proposal provides 40% affordable housing. The applicant has provided a 3 Dragons toolkit appraisal and economic appraisal to justify the quantum of affordable housing. The applicant has also paid for this assessment to be independently assessed by Atis Real who have been commissioned by Tower Hamlets Council and will be reporting the finding of their assessment to the Council. At present they are unable to complete their review of the toolkits until information on existing use value of the sites, as opposed to purchase price is made available. As such it is impossible to assess whether the proposed quantum of affordable housing represents the maximum reasonable amount.

92 Across both sites the proposal provides an affordable housing ratio split of 64% social rented and 36% intermediate units.

93 The Mayor’s Housing SPG provides a London-wide target for the mix of unit sizes within developments. The table below compares the proposed mix of units against the targets within the SPG.

Overall Social rented Intermediate Market SPG Scheme SPG Scheme SPG Scheme SPG Scheme 1 bed 32% 41% 19% 15% 66% 21% 25% 51% 2/3 bed 38% 49% 39% 32% 0% 79% 75% 49% 4 bed + 30% 10% 42% 53% 34% 0 0 0

94 The proposal will provide a large number of family sized dwellings across all tenures, with 77% of social rented units with three or more bedrooms. Tower Hamlets Council should ensure it is content with the proposed mix and that that it meets the needs of the registered social landlords and the residents of the borough.

page 16 Urban design

95 The Pride development is a generally well considered tower within the Canary Wharf cluster. It has a slim elegant profile, the articulation of the façade reflects the uses within the building with large triple height amenity spaces being provided at upper levels and it should add positively to the London skyline . Although in its own terms a very dense scheme it would not appear out of place in its context. The applicant should however consider providing more of this amenity space as play space as set out in paragraphs 43 to 45 of this report. There is little space at the ground floor of the building, although it has been stepped back both at lower and upper levels from the neighbouring Landmark development at 22 Marsh Wall (which is currently under construction). The ground floor space that does exist is sandwiched between the car access point for the Landmark development and the main loading bay for the hotel and therefore has limited amenity value.

96 The Island Point scheme comprises a relatively dense housing scheme with a mix of flatted development and terraced housing with rear gardens. The mix of house types is welcomed as is the provision of a good proportion of dual aspect flats of a number of regular cores to access those flats and the avoidance of due north facing single aspects. A number of open spaces have been provided through the development, which is welcomed, and the schemes relationship to the layout of surrounding streets and homes is well considered as is the definition of public and private space.

97 In terms of height mass and bulk the terrace house rise to three storeys and the flats from 4 to 8 storeys. The scale of surrounding development varies form 2 storey terraces to the north of the site to taller riverside developments to the south and the massing of the development follows this general pattern with the housing located on the north side of the scheme with the higher flatted accommodation to the south. As well as the park spaces a series of green roofs and communal and private roof terraces are proposed which are all welcome aspects of the scheme. The architectural treatment is relatively simple and contemporary with the material finishes comprising a mix of brick, terracotta, metal panels and timber. The visualisations of the elevations show these applied in a relatively calm and orderly manner, with the use of balconies and insets giving the elevations depth and animation.

98 Although playspace is provided for younger children and Millwall Park is within walking distance the scheme lacks any provision for a kick around space for older children and in a scheme of this density this needs to be addressed. This has been discussed at some length with the applicant at pre application stage when a number of options were debated. Whilst it is recognised that in high-density developments noise from older children playing can be a major source of nuisance simply not providing for such activity is not considered to be an adequate way of addressing the issue. Access

99 Policy 4B.5 of the London Plan expects all future development to meet the highest standard of accessibility and inclusion. This, together with the London Plan’s supplementary planning guidance ‘Accessible London: achieving an inclusive environment’, underpins the principles of inclusive design and the aim to achieve an accessible and inclusive environment consistently across London. 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.

100The design and access statements confirm that both proposals will provide 10% wheelchair accessible units and all units will meet ‘Lifetime Homes’ standards. The hotel in the City Pride proposal will meet the London Plan requirement for 5% wheelchair accessible bedrooms.

page 17 101For the City Pride site the applicant is encouraged to consider the LDA's Tourism Action Plan 2006-2009, which endorses a vision for London that is more accessible for everyone and promotes compliance with the National Accessible Standards. The proposed hotel should comply fully with Part M of the Building Regulations (2004 edition) and British Standard BS8300:2001, and meet or exceeds provision for disabled people defined by the NAS standards. Amenity and children’s play space

102Policy 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.”

City Pride

103As well as providing private balconies for each residential unit, the proposal provides 1,421 sq.m. of public amenity space on floors 33, 40, 60 and 61. Of this space 220 sq.m. is proposed as children’s play space.

104Using 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 51 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 510 sq.m. of playspace. Of this 300 sq.m. should be provided for children under the age of five.

105The applicant states in the design and access statement that the proposed figure of 220 sq.m. of child play space for children under the age of five was calculated using the Mayors SPG. However, these calculations differ to those of GLA officers and should therefore be submitted for assessment. If the applicant has miscalculated this provision, additional provision should be made within the overall total of amenity space (which stands at 1,421 sq.m.). If the applicant is unable to provide 100% of the children’s play space on site a play strategy should be submitted detailing the surrounding parks, open spaces the residents will be expected to use. The strategy should detail the size, capacity, accessibility and suitability of the open space for play and recreation. It may also be necessary for the applicant to contribute towards improvements to the park or amenity space and its up keep. This should be explored with Tower Hamlets Council.

Island Point

106In line with Tower Hamlets guidance for amenity space, the proposal provides 20% of the site as both private and public amenity space. Within this 1,623 sq.m is provided as children’s play space. The applicant has also provided a children’s play strategy which details four surrounding parks 400 metres from the site that residents of the development will be able to use.

107Using the above-mentioned methodology it is anticipated that there will be approximately 214 children within the development. As such the development should make provision for 2,140 sq.m. of playspace.

108There is therefore a shortfall in the provision of play space of 517 sq.m. Whilst, the proposal provides good quality play space for children under 11 years of age, there is no provision for a kick about area for children over the age of 12. Given the development will have a child population of 214 children, some provision for children over the age of 12 should be made. At the pre- application meeting the applicant proposed to provide 139 sq.m. of community space, the possibility of using this as a managed indoor kick about area was discussed. However, the applicant has confirmed that the community space has been removed from the proposal; the submitted

page 18 application is for residential dwellings only. The applicant should make provision for a kick about area and should consider re-instate the community space and its use as an indoor kick about area. With proper management this could provide a workable solution for the site. Climate change mitigation

109The London Plan climate change policies as set out in chapter 4A collectively require developments to make the fullest contribution to the mitigation of and adaptation to climate change and to minimise carbon dioxide emissions (policy 4A.1).

City Pride

Be lean

110Baseline emissions have been calculated using suitable software (2,983 tonnes of carbon dioxide per annum) and total energy has been accounted for. The baseline emissions are representative of a development that complies with Building Regulations 2006. A series of energy efficient measures have been considered and modelled for both the hotel and residential units. Overall, the measures have been estimated to reduce carbon dioxide emissions by around 4.2% for the residential units and 9.8% for the hotel. The applicant should confirm whether there is more room to reduce the demand of energy in the residential units, and specifically whether the thermal insulation of the building envelope be improved beyond what is currently being proposed.

Be clean

111The applicant has proposed two possible energy systems, either of which would be welcomed. However, policy 4A.6 of the London Plan priorities the connection to existing distribution networks. The first option involves connecting to the Barkentine district heating network, although a final arrangement with the operators of the Barkentine network is yet to be reached. The applicant proposes to utilise heat from the Barkentine network to supply part of the heating requirements of the development, along with water source heat pumps, an on-site gas fired CHP and absorption chillers. The applicant needs to clarify that the Barkentine heat network is not able to provide all of the heat requirements of the development. The second option proposes to provide a 400 Kwe gas fired fuel cell, water source heat pumps and absorption chillers.

Be green

112As the renewable element of the development, the applicant is proposing to use water source heat pumps for the residential units, either aquifer or dock water. This would provide a further 10% or11% reduction in carbon dioxide emissions. The applicant has also stated that the use of the water from the cooling towers as the source from the residential heat contribution could save a further 9% in carbon dioxide emissions. Though this could, in principle, be considered a suitable measure, it is not a renewable contribution itself. The applicant also proposed to provide 100 sq.m. of photovoltaic panels to displace 0.3% of the developments carbon dioxide emissions.

113Given that the use of dock water or aquifer water is uncertain at this stage, the applicant should develop an alternative renewable energy strategy as a back up. The applicant has stated that the passive design measures adopted should allow natural cooling of the residential units. However, the applicant has based a great deal of the proposed energy strategy on providing active cooling for the residential element. The applicant should therefore clarify why dock water could not be used to provide ‘direct’ cooling to the residential element.

Island Point

page 19 Be lean

114The applicant has used suitable modelling to calculate the baseline emissions. The baseline emissions are representative of a development that complies with the current building regulations (approximately 630 tonnes per annum). In addition, the applicant has accounted for total energy, both regulated and unregulated energy usages have been accounted for. A range of energy efficient design measures have also been proposed, including improved levels of air tightness beyond building regulations 2006 minimum requirements and energy efficiency lighting and access to day lighting. These will reduce carbon dioxide emissions by 15%.

115The applicant is asked to specify, for the residential element, the U-values proposed for the buildings facade and what other site specific measures will be required to achieve this reduction.

Be clean

116The applicant proposes a site-wide heat and power network. The applicant has investigated the possibility to connect with Barkentine heat network, but a letter included in the energy strategy from the operator explain that at this stage it would be unrealistic to extend the network to the site as this would require 1000 metres of pipe network. A connection to a nearby development at the Forge has also been considered as disregarded as the it does not have the space capacity to allow for connection nor the physical space in the energy centre to accommodate the extra heat generating capacity.

117The applicant proposes to install a 65kWe combined heat and power plant to supply 66% of the annual thermal load of the development. This would offer a 25% carbon dioxide saving. The applicant should clarify the arrangement to be put in place for selling the electricity generated from the plant. The applicant should also specify of the dwellings will be provided with active cooling and if this is the case how this would be provided.

Be green

118A biomass boiler supplying 25% of the thermal load is proposed, reducing the carbon dioxide emissions by a further 12.9%. Details of the supply, delivery and storage of the biomass should be submitted. The applicant is advised that the practical integration of both biomass and combined heat and power within small developments such as the Island Point proposal can prove to be difficult.

119The renewable solution as proposed falls short of the 20% carbon dioxide reduction target as set out it the London Plan. The applicant has acknowledged that an extra 8.5% of carbon dioxide savings could be made with the use of roof-mounted photovoltaic panels, but that this would be too expensive for this development. Further evidence on financial viability of the panels should be submitted.

Further details of the location and size of the energy centre should be submitted; it should take into consideration space requirements for biomass fuel, the boiler, the thermal store, the combined heat and power plant and any top up boilers. Air quality

120Policy 4A.19 of the London Plan seeks to ensure that at the planning application stage, air quality is taken into account among with other material considerations, and that formal air quality assessments are undertaken where appropriate, particularly in designated air quality management areas.

page 20 121The applicant has submitted an air quality assessment, which concludes that the proposed biomass boiler would have a negligible impact upon the air quality of the site and the surrounding area. Climate change adaptation

122The 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 reduction, including applying sustainable drainage; minimise water use; and protect and enhance green infrastructure. Specific policies cover heating, living roofs and wall and water.

123In line with policy 4A.10 of the London Plan particular attention should be paid to the use of passive design and natural ventilation. The proposals for both sites incorporate passive design measures including increased insulation, air tightness, low energy lighting and vegetation on buildings.

124Policy 4A.14 seeks to ensure that surface water run-off is managed as close to its source as possible, and sets out a hierarchy of preferred measures to achieve this. The City Pride site is unable to provide traditional sustainable urban drainage techniques because of its tight footprint. However, rainwater harvesting, a brown roof and permeable paving will be used to maximise water attenuation. The Island Point proposal incorporates more traditional sustainable urban drainage techniques in the form of soft landscaping and permeable paving.

125Policy 4A.16 of the London Plan seeks to ensure that new development has proper regard to the impact of those proposals on water demand and existing capacity by minimising the use of treated water and maximising rainwater harvesting opportunities. The applicant has confirmed that low flow equipment, standard sized baths grey water recycling and dual flush toilets will be provided in both developments to ensure water consumption is no greater than 105 litres per person per day. The applicant is also proposing 100% water metering across both developments. Comments from Transport for London

City Pride

126TfL recommends the modal split estimate for the residential part of the development is revised as TEMPRO data is not suitable. The trip rate estimate should be revised with reference to the Isle of Dogs Cordon Survey (2007), the Canary Wharf Employee Survey (2007) and 2001 Census data. TfL also requests clarification over the methodology used to estimate the modal split for the hotel, restaurant and conferencing facilities of the development.

127TfL does not consider the overall increase in traffic from the residential development to be significant. However, the increase in taxi and servicing trips from the development would contribute to the impact on the already congested Transport for London road network Upper Bank Street / Aspen Way signal-controlled junction and Preston’s Road roundabout. Hence, TfL requests a financial contribution of £250,000 to part fund improvement works of the aforementioned junction and Preston’s Road roundabout.

128Thirty car parking spaces are proposed for the residential units. This level of car parking provision is consistent with the London Plan and is therefore supported by TfL. However, a reduction would be welcomed to further support London Plan Policies 3C.17 and 3C.23. It is also recommended that future residents are made ineligible for car parking permits to curb overspill parking.

page 21 129The level of cycle parking is supported. All 470 spaces should be easily accessible to encourage cycling and comply with London Plan Policy 3C.22. Shower and changing facilities should be provided for employees cycling to work for the hotel and conferencing land uses. TfL notes the inclusion of an on-site bike pool scheme and supports that maintenance and replacement of these bicycles will be met through the overall site maintenance charge. All of the cycle parking should comply with TfL Cycle Parking Standards (2006).

130TfL welcomes that footpaths will be widened on the site frontage to provide attractive and welcoming pedestrian areas. However, the PERS assessment highlighted that a number of the dropped kerbs found along Westferry Road are in poor condition and are not flush with the carriageway or BV165 compliant. A financial contribution is sought to rectify these problems as the lack of even one dropped kerb can render a route inaccessible to some pedestrians. This would help support London Plan Policy 3C.21.

131In view of the increased number of bus passengers generated by the development, the applicant should assess the condition of all bus stops within 400 metres of the site against TfL’s bus stop accessibility guidance and identify any works needed to bring bus stops and crossings up to standard. Depending on the outcome of this review, a contribution of up to £60,000 may be required.

132Additionally, as the development will result in increased use of the local bus services, and, on a cumulative basis, help create the demand for new ones, the developer should contribute £258,000 towards improving local bus services. This would be in line with other developments in the area and would comply with London Plan Policy 3C.20.

133The coach provision in the loading areas of the development is noted. However, TfL is concerned that no provision has been made for a specific facility to pick up and set down passengers. A facility within easy access of the hotel entrance, either on or off the highway would be strongly preferred.

134TfL recommends provision of real-time transport information to users of the different land uses within the site. This should include DLR DAISY (Docklands Arrival Information System) boards, which should be secured as an obligation in the consent for the development. This would comply with London Plan Policy 3C.13.

135TfL notes that provision has been made for construction, delivery and servicing within the Transport Assessment. However, TfL would prefer these articulated in a construction logistics plan and a delivery and servicing plan, referring to the London Freight Plan (2007). The developer should also investigate the potential for water-based freight in the construction phase. This would comply with London Plan Policy 3C.25.

136A full residential and full workplace travel plan should be submitted with the planning application, as the land uses of the site are known. The objectives need to be more site-specific, and how the travel plans are to be funded needs explanation. Baseline, one-year, three-year and five-year travel surveys should follow the relevant TfL guidance. This would help support London Plan Policy 3C.2.

Island Point

137Parking provision has been reduced to 95 car parking spaces from a previous level of 102. TfL would support a further reduction to 0.4 spaces per unit in view of the location and parking levels for other contemporary residential developments on the Isle of Dogs with a similar public transport accessibility level. Lower parking levels would encourage the use of more sustainable modes in accordance with London Plan Policies 3C.23 and 3C.17. To minimise the potential for overspill

page 22 parking to disrupt bus operations, TfL asks that Tower Hamlets Council excludes all occupiers of the development from eligibility for on-street parking permits.

138TfL welcomes the level of cycle parking provision but would like assurances that twenty visitor cycle parking spaces will be provided and that they will be sheltered and secure. All cycle parking should adhere to TfL’s cycle parking standards. TfL would also like the developer to provide a formal cycle route as part of the site frontage along Westferry Road in keeping with London Plan Policy 3C.22.

139In order that the trip generation assessment is robust TfL advises that more relevant survey data should be used. The assessment should therefore be revised with all of the public transport accessibility level six sites excluded.

140TfL notes the intention of the developer to design the home-zone style shared spaces to account for the visually impaired. TfL would like the developer to consider the quality of the walking routes between the proposed site and nearby bus stops and identify the potential need for enhancements, in particular the provision of new crossings and widening of existing pedestrian crossings. This would adhere to London Plan Policy 3C.21 and Policy 3C.20.

141TfL supports the commitment from the developer to undertake a review of the bus stops and the agreement in principle to contribute a capped contribution of £10,000 per bus stop for the two bus stops being considered as part of the s106 contributions.

142The nearest bus stop for route D8 is located over 800 metres from the northwest corner of the site assuming the walk route is via Chapel House Street and East Ferry Road. If there is no direct pedestrian access to Chapel House Street, the walk distance is even longer. This is a greater distance than the 640 metre that public transport accessibility level accepts as the maximum walk distance to a bus stop and therefore route D8 should not be included in the public transport accessibility level assessment.

143As the development of the site will result in increased use of the local bus services and possibly help create the demand for new ones the developer should contribute £113,400 towards improving the local bus services. This would be in line with other developments in the area and support London Plan Policy 3C.20.

144TfL welcomes the developer’s willingness to set aside £20,000 towards the installation of DAISY boards for the DLR. Providing real time information will promote the use of public transport and comply with London Plan Policy 3C.13. It is recommended that DAISY boards are placed in public entrances and exits of the proposed building; these should be secured through the s106 agreement and they should be provided prior to occupancy.

145TfL requires the submission of a delivery and servicing plan which should seek to rationalise servicing with the aim of avoiding peak traffic periods on the road network and reducing the total number of trips made in accordance with London Plan Policy 3C.25. TfL notes that there are stated to be safe and legal loading off-street provision for delivery vehicles but there are no detailed drawings or plans supplied with this application. Submission of more detailed plans and vehicle swept paths could help ascertain if turning circles for larger vehicles such as those used for refuse or deliveries are feasible. Similarly, in order to minimise the impact of construction traffic, a construction logistics plan should be submitted for approval.

146TfL notes and accepts proposals within the travel plan but expects that it will be secured within a section 106 agreement and not as a planning condition. Comments from the LDA

page 23 City Pride

147The LDA’s comments on the principle of the development, tourism and the occupation of hotel rooms have been included in the main body of this report.

148Policy 3A.18 of the London Plan requires that community facilities and social infrastructure needs be assessed, including healthcare and childcare. It states that the provision of facilities including childcare can secure a route out of poverty and tackle health inequalities. Many women suffer restrictions in accessing job opportunities due to the lack of affordable childcare, which particularly affects lone parent family households. The social and economic impact report submitted by the applicant identifies a need for childcare facilities resulting from the proposed development. The LDA would therefore encourage the Council to consider the scope for requesting a financial contribution to address community needs, including healthcare and childcare facilities, as a means of tackling barriers to employment, and reducing disparities in labour market outcomes between groups.

Island Point

149Tower Hamlets Council should be satisfied that there will not be an overall deficiency in community facilities as a result of the number of households this proposal will deliver in accordance with policy 3A.18 (Protection and enhancement of social infrastructure and community facilities). Should there be a need for additional social facilities as a result of this proposal; the developer should be asked to contribute to the provision of any additional infrastructure required as part of any section 106-agreement negotiations. The location and design of social infrastructure and community facilities must be made suitable for the needs identified by local equality and diversity groups as well as other socially excluded groups and communities with in the local area in accordance with London Plan policy 3A.17.

Both sites

150Policy 3B.11 of the London Plan aims to improve the skills and employment opportunities for Londoners. Local residents and businesses should benefit from the creation of jobs resulting from the construction phase. The proposal has the ability to provide additional opportunities to local people and improve skills. The LDA encourage the setting of targets, and consider initiatives such as how jobs will be advertised to benefit local people (construction and operational phases), through an employment and training strategy, to ensure such initiatives are genuine and effective. London's Economic Development Strategy encourages sustainable procurement in a way which can maximise the benefits of success to London enterprises, including developing local supply chains, and building capacity of local, small and medium-sized enterprises to bid for and secure contracts. Procurement contracts particularly resulting from the serviced apartments also have the opportunity to benefit local businesses including small and medium size enterprises, which could also be included as part of an employment and training strategy. The LDA would welcome a discussion with Tower Hamlets Council with regards to the above issues as and when appropriate. Local planning authority’s position

151The application is likely to be considered by the Council’s planning committee in January 2008. Legal considerations

152Under 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

page 24 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

153There are no financial considerations at this stage. Conclusion

154London Plan policies on density, affordable housing, children’s play space, climate change, and transport are relevant to this application. The applications comply with some of these policies but not with others, for the following reasons:

• Principle of use – The City Pride proposal supports the Isle of Dogs interdependence with central London and the Central Activities Zone and is supported by policy 5G.3 of the London Plan. The provision of residential accommodation on the Island Point site is supported by policy 3A.1, which seeks to increase London’s supply of housing. As such the proposals complies with polices 3A.1 and 5G.3 of the London Plan.

• Density – The proposed residential density of the City Pride site is above the guidance range contained within table 3A.2 of the London Plan. However, it is not out of context with the surrounding development and the site location on the Isle of Dogs. The proposed residential density of the Island Point site is within the guidance range provided by the London Plan. As a result of this the proposal complies with policy 3A.3 of the London Plan.

• Affordable housing – Insufficient evidence has been provided to demonstrate that the concentration of affordable housing in the south of the Isle of Dogs won’t overload the existing social infrastructure. The independent financial appraisal by Atis Real is not complete and as such it is impossible to assess whether the proposed quantum of affordable housing represents the maximum reasonable amount. As a result of this the proposal fails to comply with policies 3A.9 and 3A.10 of the London Plan.

• Children’s play space (City Pride) – There is discrepancy over the estimated child population, and as such the proposal fails to provide enough playspace for children under 5 years of age. No play strategy has been submitted and, it is not clear therefore if there is adequate surrounding play space to accommodate the residents of the development. As a result the proposal does not comply with policy 3A.13 of the London Plan.

• Children’s play space (Island Point) – The proposal provides 1623 sq.m. of children’s play space on site. However, it fails to provide a kick about area for children aged 12 years and over. As such the proposal complies fails to comply with policy 3A.13 of the London Plan.

• Climate change mitigation (City Pride) – More information is required to assess the passive design measures proposed for the residential units. It is not clear why the Barkentine heat network cannot provide more of the heat demand of the development. The applicant has not secured the use of dock or aquifer water. It is not clear why dock or aquifer water cannot be used as direct cooling to the residential units. As a result of this

page 25 the proposal fails to comply with the policies contained within chapter 4A of the London Plan.

• Climate change mitigation (Island Point) – The U-values for the buildings facade and other site-specific energy reduction measures have not been fully explained. No details have been provided on the arrangement for selling electricity generated from the plant. It Is not clear if the dwellings will be provided with active cooling. Limited information on the energy centre has been provided. As a result of this the proposal fails to comply with the policies contained within chapter 4A of the London Plan.

• Air quality – An air quality assessment of the biomass boiler has been undertaken. It is not expected to have a detrimental impact upon air quality. As a result of this the proposal complies with policy 3A.19 of the London Plan.

• Climate change adaptation – Both proposals incorporate passive design measures, including natural ventilation, low energy lighting and increased insulation. The proposals also include sustainable urban drainage. All units will be fitted with water meters and rainwater harvesting and water attenuation systems will be provided. As a result of this the proposal complies with policies 4A.10, 4A.14 and 4A.16 of the London Plan.

• Transport (City Pride) – The data used for the modal split and trip rate estimate is not suitable. The proposal will contribute to the already congested Upper Bank Street/Aspen Way junction and Preston’s Road roundabout. It will also increase the number of bus passengers generated by the development. No on-site shower and change facilities within the non-residential uses. A number of the dropped kerbs along Westferry Road are in poor condition. No contribution towards DAISY boards. No delivery service plan or construction logistics plan. As a result of this the proposal fails to comply with the polices contained with chapter 3C of the London Plan.

• Transport (Island Point) – It is not clear if the visitor cycle parking spaces will be provided. There is no cycle route along the site frontage of Westferry Road. The trip generation assessment is inaccurate. There is no delivery service plan or construction logistics plan. As a result of this the proposal fails to comply with the polices contained with chapter 3C of the London Plan.

155On balance, the application does not comply with the London Plan.

156The 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 evidence should be provided to demonstrate that the concentration of affordable housing in the south of the Isle of Dogs wouldn’t overload the existing social infrastructure. The findings of the independent economic appraisal of the proposed quantum of affordable housing should also be submitted prior to the application being referred back to the Mayor. • Children’s Play space (City Pride) – The methodology used by the applicant to estimate he child population should be submitted. Details of the surrounding parks, including their size, capacity, accessibility and suitability should be submitted. • Children’s play space (Island Point) – Provision should be made for a kick about area for children over 12 years of age.

page 26 • Climate change mitigation (City Pride) – The applicant should confirm whether there is more room to reduce the demand of energy in the residential units. Could the thermal insulation of the building envelope be improved beyond what is currently being proposed? The applicant needs to clarify that the Barkentine heat network is not able to provide all of the heat requirements of the development. The applicant should develop an alternative renewable energy strategy incase aquifer or dock water use is not possible. The applicant should clarify why dock water could not be used to provide ‘direct’ cooling to the residential element.

• Climate change mitigation (Island Point) - The applicant should specify, for the residential element, the U-values proposed for the buildings facade and what other site specific measures will be required to achieve this reduction. The applicant should clarify the arrangement to be put in place for selling the electricity generated from the plant. The applicant should also specify of the dwellings will be provided with active cooling and if this is the case how this would be provided. Further details of the location and size of the energy centre should be submitted; it should take into consideration space requirements for biomass fuel, the boiler, the thermal store, the combined heat and power plant and any top up boilers.

• Transport (City Pride) - In order to be fully compliant with the London Plan the following transport issues should be addressed:

• A revised trip generation assessment with reference to the Isle of Dogs Cordon Survey (2007), the Canary Wharf Employee Survey (2007) and the Census data (2001) should be submitted. • A contribution of £250,000 to help fund a study of Upper Bank Street / Aspen Way signal-controlled junction and Preston’s Road roundabout and funding any subsequent improvement works should be made. • A contribution towards bus network improvements, assessing the condition of bus stops within a 400 metres radius of the development and upgrading those, which are deficient, should be made. The developer should contribute £258,000 towards improving the local bus services. • Shower and changing facilities for the commercial and retail elements should be provided. The design of all cycle parking should meet TfL cycle parking standards. • A financial contribution should be made to rectify the dropped kerbs along the Westferry Road. • Provide section 106 contributions for DAISY boards, local pedestrian improvement and bus service enhancements. • Submit a delivery service plan and a construction logistics plan and investigate the potential for delivering construction materials by water. • Submit a full workplace travel plan and a full residential travel plan.

• Transport (Island Point) - In order to be fully compliant with the London Plan the following transport issues should be addressed:

• The trip generation assessment should exclude sites with a PTAL of 6. • The condition of bus stops within a 400-metre radius of the development should be assessed and those which are deficient upgraded. • Provide section 106 contributions for DAISY boards, local pedestrian improvements and bus service enhancements.

page 27 • The provision of 20 visitor cycle parking spaces should be confirmed. • A formal cycle route as part of the site frontage along Westferry Road should be provided. • A delivery and service plan and a construction logistics plan should be submitted; the travel plan should be secured through the S106 agreement.

for further information, contact Planning Decisions Unit: Giles Dolphin, Head of Planning Decisions 020 7983 4271 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Colin Wilson, Strategic Planning Manager (Planning Frameworks) 020 7983 4783 email [email protected] Kim Hoffman, Case Officer 020 7983 6589 email [email protected]

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