planning report GLA/4758/01 14 January 2019 Site north west of Road in the Borough of Tower Hamlets planning application no. PA/18/03089

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

The proposal Erection of 18 storey building (up to maximum height of 64.250 metres AOD) to provide a 350 room hotel (Use Class C1) together with ancillary restaurant and bar, car parking, cycle parking and landscaping.

The applicant The applicants are Marick Real Estate Limited and Mill Lane Estates and the architect is Dexter Moren Associates.

Strategic issues

Land use principles: The proposed hotel in this accessible location within the Lower Lea Valley Opportunity Area is supported in strategic planning terms (paragraphs 16 & 17). Urban design & heritage: The height, massing and architecture is supported. The scheme is dominated by surface car parking which significantly compromises the design and is contrary to policy; this must be reduced. The proposed landscape strategy should be revised to increase areas of meaningful soft landscaping and public realm. No harm would result to nearby heritage assets (paragraphs 19-24). Sustainable development: The extent of hard surfacing should be reduced with a view to maximise urban greening and contribute towards the reduction of the heat island effect. Details of planting and a calculation of the proposal’s Urban Greening Factor should be provided. The proposal should seek to achieve the urban greening target as set out in draft London Plan Policy G5 (paragraphs 29-35). Transport: The proposed level of parking generates a mode share of 33.4% of trips by car, which does not comply with the intent of the draft London Plan. Car parking should be reduced and the Transport Assessment should be revised to reflect a higher proportion of trips by foot, cycle or public transport, in line with the Mayor’s strategic targets (paragraphs 36-41). Further information is sought with respect to energy (paragraphs 26-28) and drainage (paragraphs 29 -31).

Recommendation That Tower Hamlets Council be advised that, whilst the principle of the proposal is supported, the application does not comply with the London Plan and draft London Plan for the reasons set out in paragraph 46 of this report, however possible remedies set out in that paragraph can address those deficiencies.

page 1 Context

1 On 13 November 2018 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 Order 2008’) the Mayor has to provide the Council with a statement setting out whether he considers that the application complies with the London Plan and draft London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under the following Categories of the Schedule to the Order 2008:

• Category 1B: “Development with a total floorspace of more than 15,000 sq.m.”.

• Category 1C: “Development which comprises or includes the erection of a building more than 30 metres high outside the .”

3 Once the Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

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

5 The application site, referred to as ‘Plot 8’, is located to the north of the Leamouth Circus Roundabout, bounded by Leamouth Road to the east, Sorrel Lane to the north and Oregano Drive to the west and south. The site is broadly rectangular and covers an area of 0.35 hectares. At present, the site is clear, with no permanent structures.

6 The area surrounding the application site comprises the Telehouse Data Centre Campus and a Travelodge hotel located on Coriander Avenue, to the north-west of the application site. Outline planning permission has been submitted for the redevelopment of the Travelodge site for a new data centre building. The site and surrounds lie within the Lower Lea Valley Opportunity Area and the Poplar Riverside Housing Zone. The site is within the setting of the Grade II listed East India Dock Wall and Gateway, which sits to the north-east.

7 The site has a Public Transport Access Level (PTAL) of 4, measured on a scale of 0-6b where 6b is the highest. East India Docklands Light Railway (DLR) station is located approximately 400m to the south west of the site and station is located approximately 900m to the east. The site is also served by three bus routes and the cycle superhighway 3 (Barking to Tower Gateway) which runs directly to the north of the site along Sorrel Lane.

8 The A13 East India Dock Tunnel runs diagonally beneath the site from the south-west to north- east. TfL have imposed a development loading restriction zone above this tunnel, which also spans 15m on either side.

page 2 Details of the proposal

9 It is proposed to construct a 18 storey (64.2m) hotel with 350 rooms, which would be operated by Travelodge. The hotel would also incorporate a first floor ancillary bar & restaurant and 82 surface level parking spaces.

10 The proposal forms part of a wider development proposal by Telehouse, which enables the extension to their data centre campus. Telehouse are proposing to demolish the existing Travelodge hotel at Coriander Avenue, to construct a new data centre on this site. The existing hotel is a five- storey building, comprising 232 rooms and 89 parking spaces. It is proposed to re-provide the Travelodge on the currently vacant site, known as ‘Site 8’ (the application site) owned by Telehouse. Planning history

11 The site benefits from an extant planning permission (ref: PA/14/00074/A1) for the redevelopment of ‘Plot 6’ and ‘Plot 8’ located on Oregano Drive. The planning permission granted approval for a 10-storey data centre building on site 6 and a 12-storey office development (59m maximum height) at site 8. A link bridge was proposed to the existing Telehouse campus buildings. 32 parking spaces, including 4 disabled bays, were proposed for Plot 8. Whilst it is noted that the 10- storey data centre has been established at site 6, the permission for the 12-storey office building has not commenced at Plot 8. The associated car parking has also not been brought forward. As it stands, planning permission PA/14/00074/A1 has been implemented.

12 A pre-planning application meeting was held on 8 August 2018, with written advice issued on 30 August 2018. In summary, the proposed hotel use was considered acceptable in strategic planning terms. The proposed massing and heights were also accepted. Notwithstanding this, the excessive provision of 82 surface level parking spaces was not considered to respond to the Mayor’s vision for good growth, or policies relating to sustainable transport. The applicant was strongly advised to reduce the provision of on-site parking and explore opportunities to enhance pedestrian permeability and the delivery of meaningful soft landscaping.

13 A follow-up pre-planning meeting was held on 4 September 2018. It was noted that there were no reductions to the provision of car parking (82 spaces). Discussions at the meeting focused on the provision of car parking and opportunities for landscaping to reduce the visual impact of the surface parking area. Strategic planning issues and relevant policies and guidance

14 The relevant strategic issues and corresponding policies and guidance are as follows: • Opportunity areas London Plan; Town Centres SPG • Visitor infrastructure London Plan • Urban design London Plan; Character & Context SPG • Inclusive access London Plan; Accessible London SPG; • Sustainable development London Plan; Sustainable Design and Construction SPG; London Environment Strategy; • Transport and parking London Plan; the Mayor’s Transport Strategy;

15 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 Core Strategy (2010), Managing Development Document (2013) and the London Plan (Consolidated with Alterations since 2011). The revised National Planning Policy Framework (July 2018), National Planning Practice Guidance and draft London Plan (consultation draft, December 2017 incorporating early suggested changes published August 2018) are also relevant material considerations.

page 3 Land use principle

16 London Plan Policy 4.5 directs hotel provision to Opportunity Areas and CAZ fringe locations with good public transport. This intent is reflected in draft London Plan Policy E10. It is estimated that London will need to build an additional 58,000 bedrooms and serviced accommodation by 2041, which is an average of 2,230 bedrooms per annum. The proposal would be consistent with this strategic policy objective. The hotel use in this Opportunity Area location would be appropriate and would not lead to an over-concentration of such uses in this area. The ancillary restaurant / bar use would also be appropriate to support the hotel use. The proposed hotel and ancillary uses are therefore supported in line with London Plan policy.

17 Tower Hamlets have confirmed that the principle of the development also meets Local Plan Policies.

Urban design

18 Good design is central to all objectives of the London Plan. London Plan Policy 7.1 sets out a series of overarching design principles for development in London. The design policies within chapter 7 and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, views and public realm. Policy 7.4 also requires that new development has regard to its context and makes a positive contribution to local character. The intent of these policies is reflected in draft London Plan Policies D1 and D2.

Layout and public realm

19 The constrained nature of the site, which is subject to a number of development restrictions, has informed the proposed location of the building in the north-western corner. Whilst this approach is accepted, under the unique circumstances, the building must positively respond to its frontages along Sorrel Lane and Oregano Drive. The ground floor layout is currently dominated by plant, servicing, and back-of-house facilities, all of which create an overbearing and inactive relationship to the adjacent streets. Furthermore, the location of the entrance lobby and the restaurant / bar at first floor represent a missed opportunity to activate the adjacent street scene. The ground floor layout should be reviewed to maximise active frontage and internalise areas of plant and servicing. Alternative layouts for the plant and water tank storage, such as energy centres / plant rooms with mezzanine levels, should be explored. The ground floor entrance design would also benefit from further consideration in terms of appearance and usability.

20 The proposed development is dominated by surface level parking. During preapplication discussions, the applicant was advised to reduce the amount of hardstanding across the site. Whilst there has been no reduction in parking, the applicant has attempted to reduce the visual impact through permeable surface materials and boundary planting. Notwithstanding this, officers remain of the position that the over-provision of parking and associated lack of meaningful soft landscaping creates a harsh visual environment for visitors which would also have a wider impact on pedestrian experience and the character of the surrounding area. Whilst the construction constraints associated with the East India Dock tunnel are acknowledged, the principle of an 82-space surface level parking area does not reflect the Mayor’s vision for good growth, or policies relating to urban greening, sustainable transport and healthy streets. Furthermore, whilst the principle of a pocket park is welcomed, officers consider that the current arrangement could be significantly improved. Accordingly, prior to stage 2 referral, car parking should be reduced, and the landscape strategy should be revised to increase areas of soft landscaping, improve pedestrian permeability and explore opportunities to increase areas of publicly accessible open space and play, in line with London Plan Policy 2.18 and draft London Plan Policy G4.

page 4 21 Overall, a more appropriate response to the site, its context and constraints is required. Whilst the general approach to the siting of the building is accepted, areas of active frontage to Sorrel Lane and Oregano Drive must be increased. The amount of car parking should be reduced to facilitate high-quality landscaping, which would result in a significant benefit to the design and overall appearance of the site, visitor experience and pedestrian permeability.

Height, massing and architecture

22 The proposed height and massing is supported in terms of the context of the surrounding development. The architectural approach is generally supported and in keeping with the character of the area. The acceptability of the design is however subject to simple, high quality detailing and the use of high quality facing materials. The Council should ensure that high quality materials are secured. Details of the proposed product and detailed construction drawings should be submitted prior to Stage 2 referral.

Historic environment

23 London Plan Policy 7.8 states that development should identify, value, conserve, restore, re-use and incorporate heritage assets where appropriate. Draft London Plan Policy HC1 seeks to ensure that development proposals affecting heritage assets, and their settings, should conserve their significance, by being sympathetic to the asset’s significance and appreciation within their surroundings. The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the tests for dealing with heritage assets in planning decisions. In relation to listed buildings, all planning decisions should “have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses” and in relation to conservation areas, special attention must be paid to “the desirability of preserving or enhancing the character or appearance of that area”.

24 The Grade II Listed East India Dock Wall and Entrance Gateway is located to the north-east of the site. As previously discussed, the height, massing and architecture of the proposed building is acceptable. Furthermore, given the character and scale of surrounding development, the proposed development would not be a distinctive or obtrusive addition to the streetscape. Accordingly, on this basis, no harm would result to the nearby heritage assets.

Inclusive design

25 In accordance with London Plan Policy 4.5, 10% of the hotel rooms will be accessible, and these are shown on the plans. The Council should secure this provision by condition. Energy

26 The applicant has followed the energy hierarchy and the proposed strategy is generally supported; however, further information is required before the proposals can be considered compliant with London Plan Policy 5.9 and draft London Plan Policy S12. The applicant has advised that the utilisation of rejected heat from the data centre is unfeasible from an operational and financial viewpoint. Further evidence is required to support this statement. In terms of the ‘be clean’ element, further detailed information is required to determine the suitability of the proposed CHP. The use of centralised heat pumps to supply both space heating and hot water for the development should be further investigated as an alternative to the proposed CHP. For the ‘be green’ element of the hierarchy, further detailed information is required for the proposed heat pumps, including SCOP and SEER energy modelling.

page 5 27 An on-site reduction of 235 tonnes of carbon dioxide per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected. This is equivalent to an overall saving of 37%. The carbon dioxide savings exceeds the target set in London Plan Policy 5.2, however the applicant should address the technical queries raised in order to verify these savings.

28 The detailed technical comments have been sent to the applicant and the Council. Sustainable development

Flood risk and sustainable drainage

29 The approach to flood risk management for the proposed development generally complies with London Plan Policy 5.12 and draft London Plan Policy SI.12. The applicant should commit to assessing sewer flooding risk in further detail and adopting suitable flood resistance measures where necessary.

30 The surface water drainage strategy for the proposed development does not currently comply with London Plan Policy 5.13 and draft London Plan Policy SI.13, as it does not give appropriate regard to the drainage hierarchy and greenfield runoff rate. Further details on how SuDS measures at the top of the drainage hierarchy will be included within the development, and how greenfield runoff rate will be achieved should be provided. Additional attenuation storage volume calculations, attenuation tank dimensions, and SuDS maintenance information should also be provided.

Water efficiency

31 The proposed development generally meets the requirements of London Plan Policy 5.15 and draft London Plan Policy SI.5. The applicant should also consider water harvesting and reuse to reduce consumption of wholesome water for irrigation. This can be integrated with the surface water drainage system to provide a dual benefit.

Green infrastructure and urban greening 32 The landscape proposal includes an eco-brown roof, a 180 sq.m. pocket park, a green hedge buffer and 58 sq.m. of native planting. The proposal also states that the 84 parking spaces are to be covered in ‘Grasscrete’. Whilst the green hedge buffer is strongly supported, a substantial portion of the site is currently proposed to be hard surfacing. In line with London Plan Policy 5.10 and draft London Plan Policy G5, development proposals should contribute to the greening of London by including urban greening as a fundamental element of site and building design. The substantial portion of the site to be free from built form presents the opportunity to make a greater contribution to urban greening. Prior to any stage 2 referral, the design should review the extent of hard surfacing and seek to maximise the extent of greening across the site.

33 Whilst the inclusion of a brown roof is welcomed, the proposal should seek to increase the coverage of green roofs by utilising other areas of flat roof. The proposal should also consider the addition of a green wall to increase the proposal’s urban greening.

34 Prior to any stage 2 referral, a calculation of the proposal’s the Urban Greening Factor, as set out in draft London Plan Policy G5. The areas of each surface type should be colour coordinated and shown on the landscape plan. The proposal should seek to achieve the stated target. A landscape plan should also be provided stating the species and size of proposed planting. Large canopy tree species would be strongly supported.

page 6 Managing heat

35 The site is located in an area that exceeds the urban heat island target threshold. The landscape proposal should seek to contribute to the reduction of this effect. Transport

Cycle and car parking

36 A total of 82 parking spaces, including five accessible spaces and two taxi drop-off spaces are proposed. This directly conflicts with London Plan Policy 6.13 and draft London Plan Policy T6.4 relating to hotel uses within locations with a PTAL 4-6. It is acknowledged that the hotel is being proposed as a replacement to the current hotel located 200m to the north-west of the site. The Council has confirmed that the two hotels would be prevented from operating simultaneously through a clause in the s106 agreement. The applicant is therefore arguing that the proposal is effectively relocating the existing hotel and reducing car parking spaces from the current provision of 84 spaces to 82. Furthermore, the applicant contends that the provision of parking is required due to a lack of alternative packing within close proximity to the site.

37 Draft London Plan Policy T6(I) advises that where sites are redeveloped, existing parking should be reduced to reflect the current approach and not be re-provided at previous levels, where this exceeds the standards set out in this policy. Accordingly, the applicants reasoning is not accepted and car parking should be reduced. Subject to an appropriate level of on-site parking being agreed, a Car Park Design and Management Plan will need to be secured by condition.

38 The proposed development includes 18 long-stay and 8 short-stay cycle parking spaces in line with adopted and draft London Plan standards.

Transport Assessment

39 A transport assessment has been submitted in support of the application. Whilst the approach to deriving hotel trip rates is broadly acceptable, the proposed mode share for car drivers (33.4%) is not accepted as it does not support the target set out in the Mayor’s Transport Strategy for the draft London Plan, which targets at least 80% of trips by foot, cycle or public transport by 2041. Accordingly, the level of on-site car parking should be reduced, and the mode share adjusted to reflect the requirements of the draft London Plan.

A13 East India Dock Tunnel

40 Should planning permission be granted, the applicant will need to enter into an Infrastructure Protection / Build Over Agreement with TfL, prior to implementation of the development. This should be secured by condition.

Travel planning, construction and delivery management

41 A travel plan, including all agreed measures therein should be secured, enforced, monitored and reviewed as part of the S106 agreement, with a delivery and servicing plan and construction logistics plan secured by condition.

page 7 Community Infrastructure Levy

42 In accordance with London Plan Policy 8.3, the Mayoral Community Infrastructure Levy (CIL) came into effect on 1 April 2012. The levy is charged at £35 per square meter of additional floorspace within London Borough of Tower Hamlets.

Local planning authority’s position

43 The proposal has been the subject of pre-application discussions with Tower Hamlets planning officers. The application is still under consideration, however officers have concerns in relation to the over-provision of car parking. Legal considerations

44 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

45 There are no financial considerations at this stage.

page 8 Conclusion

46 London Plan and draft London Plan policies on opportunity areas, visitor infrastructure, urban design, inclusive design, energy, flood risk, urban greening and transport are the key strategic issues relevant to this planning application. The application does not comply with the London Plan and draft London Plan. The following changes could possibly lead to the application becoming compliant with the London Plan and draft London Plan:

• Land use principles: In line with this strategic policy objectives of London Plan Policy 4.5 and draft London Plan Policy E10, the proposal would provide a small-scale hotel within an accessible location within the Lower Lea Valley Opportunity Area. • Urban design & heritage: The height, massing and architecture is supported. The scheme is dominated by surface car parking which significantly compromises the design and is contrary to policy; this must be reduced. The proposed landscape strategy should be revised to increase meaningful areas of soft landscaping and public realm, in line with London Plan Policy 7.15 and draft London Plan Policy D7. No harm would result to nearby heritage assets. • Energy: Further information is required regarding the site-wide energy network, heating and renewable energy, before the proposals can be considered compliant with London Plan Policy 5.9 and draft London Plan Policy S12. • Sustainable development: The extent of hard surfacing should be revised with a view to maximise urban greening, contribute towards the reduction of the heat island effect and increase areas of publicly accessible open space, in line with London Plan Policy 2.18, 5.9, 5.10 and 5.11 and draft London Plan Policies G1, G4, G5 and SI4. Details of planting and a calculation of the proposal’s Urban Greening Factor should be submitted. The proposal should seek to achieve the stated target as set out in draft London Plan Policy G5.

• Transport: The provision of 82 on-site parking spaces directly conflicts with London Plan Policy 6.13 and draft London Plan Policy T6.4 and should be significantly reduced. The level of parking proposed generates a mode share of 33.4% of trips by car drivers which does not comply with draft London Plan Policy T1. The mode share detailed within the Transport Assessment should be adjusted to reflect the public transport / walking & cycling requirements of the Isle of Dogs OAPF, the Mayor’s Transport Strategy and the draft London Plan.

for further information, contact GLA Planning Unit: Juliemma McLoughlin, Chief Planner 020 7983 4271 email [email protected] John Finlayson, Head of Development Management 020 7084 2632 email: [email protected] Katherine Wood, Team Leader 020 7983 4178 email [email protected] Justine Mahanga, Senior Strategic Planner (Case Officer) 020 7983 4467 email justine.mahanga @london.gov.uk page 9