planning report D&P/2060c/01 8 April 2015 160 – 166 Chrisp Street, Poplar, Tower Hamlets in the London Borough of Tower Hamlets planning application no. PA/15/00039

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

The proposal

Demolition of existing buildings and redevelopment to provide three new buildings ranging from three to thirteen storeys in height comprising 273 residential units (comprising 95 x 1 bed; 118 x 2 bed; 55 x 3 bed& 5 x 4 bed), 20 car parking spaces and 358 cycle spaces; associated amenity and child playspace. The applicant The applicant is a Bellway Homes Ltd (Thames Gateway) and the agent is Savills

Strategic issues The principle of this proposal is welcomed as it brings about the redevelopment of a declining industrial and will help to contribute towards the much needed uplift of housing provision in Tower Hamlets. Outstanding information is required to be provided on affordable housing provision, with the submission of the viability assessment, inclusive access, energy, sustainable drainage and transport matters. Overall the scheme has progressed positively following the earlier pre-applications and the applicant is commended for the design enhancements. Recommendation That Tower Hamlets Council be advised that while the application is generally acceptable in strategic planning terms the application does not comply with the London Plan, for the reasons set out in paragraph 67 of this report; but that the possible remedies also set out in that paragraph of this report could address these deficiencies.

Context

1 On 27 February 2015 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 8 April 2015 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

page 1 2 The application is referable under Categories 1A and 1C of the Schedule to the Order 2008:

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

Category 1C

“Development which comprises or includes the erection of a building of more than 30 metres high”.

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

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

5 The site is located in Poplar to the north of . The site is bounded by Rifle Street to the north, Cording Street to the south, the (DLR) line to the east and Chrisp Street to the west. The nearest part of ’s Road Network (TLRN) is East India Dock Road (A13), approximately 500m to the south.

6 The nearest station is Langdon Park DLR, which is approximately 150m to the south. The area is also served by 5 bus routes from nearby stops on Cordelia Street, Morris Street and East India Dock Road. This area is served by the Mayor’s cycle hire scheme with docking stations located at Langdon Park and , within 550m of the site.

7 The public transport accessibility level of the site (PTAL) ranges from 3 (average) in the north to a 4 (good) in the south.

8 The current light industrial car/garage site, occupies 6,736sq.m of land between two residential developments on Chrisp Street, very close to Langdon Park DLR station. The site is currently under-utilised and forms a weak edge along Chrisp Street.

9 The site immediately to the south of the application site, and immediately next to Langdon Park station, is a recently approved 22 storey Ballymore residential scheme. Beyond the station, to the west, various residential blocks have been developed, and across the road, opposite the station there is an estate renewal taking place by Bellway. Adjacent to this redevelopment by Bellway, there are two storey, flat roofed residential terraces, which form part of an estate. The site is therefore, at present, the only area where there is an element of declining light industrial activity remaining. Should this proposal be successful, and together with the Ballymore scheme going ahead, the area will become predominantly residential.

10 Overall, the wider area incorporates a range of 1980’s and modern residential developments with a range of densities and building heights, from the 2-storey terraced housing described above, to the 17-storey council housing blocks.

11 In addition to these industrial and residential uses, Chrisp Street also incorporates a mix of other uses including a health centre, shopping units and Chrisp Street market. The site is located 300 metres from Chrisp Street District Centre. Immediately to the west of the station is a modern/contemporary youth centre called ‘Spot Light’.

page 2 12 There is a large conservation area to the east of the site across the railway tracks known as Langdon Park Conservation Area. The closest main watercourses to the site are the Cut Canal and Bow Creek.

Details of the proposal

13 The applicant proposes a residential redevelopment comprising 273 residential units in total. The scheme consists of 3 buildings with the highest point at 13 storeys and various cut backs to the massing starting from the 4th floor. A new landscaped street through the site, which will run from north to south to connect Rifle Street and Cording Street is proposed. This will connect with the neighbouring site and provide a through route to the DLR station. Case history

14 Since the initial pre-application meeting for this site held on 18 September 2013, the applicant is now Bellway Thames Gateway, who acquired the application site from the previous consortium of landowners in mid - 2014.

15 The current applicant has made significant amendments to the pre-application submission, building on the GLA officer comments from last year (at the second pre-application meeting held on 19 December 2014), and from having had discussions with the London Borough of Tower Hamlets (LBTH) officers since September this year.

16 Since the previous pre-application submission the applicant has amended the proposal in the following ways:

 Rationalised the number of units within the cores;  Enhanced cycle parking provision;  Enhanced central public amenity space and improved access (through route);  Enhanced the defensible space at pavement level and improved entrances;  Sought to increase the number of dual aspect units within the scheme and reduce north facing single aspect units and  The schedule of accommodation now proposes ten additional residential units against the previous scheme seen in December 2014.

17 These amendments are discussed in greater detail within the body of this report. Strategic planning issues and relevant policies and guidance

18 The relevant issues and corresponding policies are as follows:

 Mix of uses London Plan  Housing London Plan; Housing SPG; Housing Strategy; Providing for Children and Young People’s Play and Informal Recreation SPG;  Affordable housing London Plan; Housing SPG; Housing Strategy;  Density London Plan; Housing SPG;  Urban design London Plan;  Access London Plan; Accessible London: achieving an inclusive environment SPG;  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy

page 3  Transport London Plan; the Mayor’s Transport Strategy  Crossrail London Plan; Mayoral Community Infrastructure Levy;  Parking London Plan; the Mayor’s Transport Strategy

19 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) and the London Plan (Consolidated with alterations 2011.

20 The following are also relevant material considerations:

 The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The Lower Lea Valley Opportunity Area Planning Framework, January 2007

Principle of Use

21 Whilst the site is currently a light industrial location, the character of the surrounding area has changed significantly becoming almost entirely residential. Once this scheme and the neighbouring site are built out, the area will become predominantly residential in character.

22 The initial scheme in September 2013 had an element of retail on the ground floor, however this has since been removed. It is understood from the applicant that the Council has accepted the provision of a solely residential scheme on this site, as any commercial or retail space should be directed towards the more central areas such as Chrisp Street Market and district shopping centre, in line with the Council’s Core Strategy and Site Specific Proposals Document. It is understood that there are also a number of developments in the area which have vacant commercial units in their ground floors. A solely residential scheme is therefore acceptable.

Housing

23 The applicant’s schedule of accommodation has been amended, as set out in the table below, the applicant is now proposing 273 residential units against the previously proposed 263 and 260 units at the earlier two pre-application stages:

Unit type Private Affordable Intermediate Total Rent provision

1 bed 71 8 18 95 2 bed 88 18 10 118 3 bed 37 15 3 55 4 bed 0 5 0 5 Total 196 46 31 273

24 A range of tenure and dwelling types are proposed, including 1-4 bedroom flats and 23 maisonettes.

Tenure split and the amount of affordable housing

25 The scheme proposes to deliver 30% affordable housing by habitable room in the form of three bedroom flats and maisonettes and four bedroom flats. Overall this equates to 77 affordable

page 4 units within the scheme, with a tenure split of 46 affordable rented units (60%) and 31 intermediate units (40%). It is understood that the applicant has undertaken a viability assessment to demonstrate that this is the maximum reasonable amount. The results of the independent assessment by the Council should be shared with the GLA officers.

26 The tenure split of affordable housing proposed is in compliance with London Plan policy 3.11 and the Mayor's Housing Supplementary Planning Guidance (SPG), which requires 60% of overall housing provision to be social housing, and 40% for intermediate provision for the purposes of meeting affordable housing targets.

Family housing

27 The scheme will provide 22% family housing by unit across all tenures or 31% by habitable room. 45% family accommodation is proposed within the affordable rent element which will provide a significant amount of family sized units to cater for locally identified needs, thereby meeting the Council’s strategic housing needs.

Density

28 London Plan Policy 3.4 requires development to optimise housing output for different locations taking into account local context and character, design principles set out in London Plan Chapter 7 and the public transport capacity; table 3.2 provides density guidelines in support of this. The site has a public transport accessibility level (PTAL) of 3/4. The site lies in an urban setting, as defined by the London Plan and based on the site’s PTAL, a density range of 200 – 700 habitable rooms per hectare (hr/ha) should be applied to the scheme as indicated by Table 3.2.

29 The applicant’s planning statement states that the scheme will achieve a density of 407 units per hectare and 1,171 habitable rooms per hectare. The London Plan notes that the density matrix should not be applied mechanistically and given the site’s context and the quality of the proposed scheme, the proposed density is acceptable. Design

Layout

30 The GLA commends the applicant for addressing the design concerns raised at the pre- application stages. The layout of the scheme is particularly supported as it creates an active and animated public realm, through the generous provision of ground floor entrances to all units at street level. At the Cording Street entrance, a gym has been proposed, which further activates surrounding streets.

31 Between the residential blocks, a pedestrian priority (north south) area has been proposed. This improves the permeability of the area, as this potential new pedestrian route will link the DLR station with this site, running through the Ballymore scheme next door.

32 The applicant was advised at the last pre-application meeting that consideration should be given to the northern corner of Rifle Street, which had a sub-station that could be relocated to further improve the frontage at this location. The applicant has addressed this concern which is welcomed.

Residential quality

33 The residential quality of the scheme has been improved significantly since pre-application stage. The layout has been optimised to increase the number of dual aspect units by limiting the

page 5 number of units no each core and maximising the number of through units at the end of corridors. No single aspect north facing units are proposed due to the orientation of the blocks. All ground floor units have direct access from the street which is also supported. The applicant has included an additional core on the eastern block as recommended, so that each core has a maximum of eight units per core which is also welcomed. All of the units meet or exceed the Mayor’s minimum space standards, which is welcomed.

Noise-DLR line

34 The applicant has had a noise and vibration study undertaken as recommended. The study has identified that the measured levels of noise and vibration from the DLR line have been found to be within acceptable limits, with reference to BS6472-1:2008 - Guide to evaluation of human exposure to vibration in buildings. The applicant proposes appropriate glazing and sound reduction walls as architectural mitigation to provide sound insulation to residents. These mitigation measures should be secured by the Council through appropriate conditions. The realignment of the cores as suggested at pre-application has further helped to reduce this impact.

Bulk, scale and massing

35 The proposal has been designed to reflect the height and massing of adjacent blocks. The building increases in height to complement the Ballymore scheme proposal and drops in height towards the northern end. This approach is supported.

Appearance

36 Overall, the architecture of the scheme is generally supported. The predominant use of brick reflects the residential use of the buildings whilst creating robust and hard wearing elevations which is welcomed. The architect has simplified the massing of the buildings creating a more elegant form with terracotta vertical screens in between the balconies.

Children’s play space

37 Given the close proximity to Langdon Park, the applicant proposes to only provide child play space for the 0-5 year category, in which 43 children are expected. This results in a requirement to provide 430 sq.m. of play space. The applicant proposes to provide 440sq.m. of defined formal playspace within the central communal area. 400sq.m is proposed on the roof terraces on blocks A-C. The applicant states that the Council has agreed that Langdon Park will be an appropriate facility for the older children. This should be confirmed by the Council and the various play timber elements proposed are secured. Access

Inclusive Design

38 The aim of London Plan Policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and inclusion (not just the minimum). Inclusive design principles if embedded into the development and design process from the outset help to ensure that all of us, including older people, disabled and Deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity.

39 There are some of areas where the current proposals need further consideration or clarification of the provision is required.

page 6 Public realm

40 The proposals are formed from two main buildings separated by a new north to south, shared surface street, linking with an access route proposed for the adjacent site leading to Langdon Park and the DLR station.

41 Paragraph 6.37 of the London Plan emphasises the importance of providing “safe and attractive routes that are easy to navigate”, and paragraph 6.38 explains that “Walking issues should be addressed in development proposals, to ensure that walking is promoted and that street conditions, especially safety, security and accessibility for disabled people, are enhanced.” As shared surfaces are proposed, the applicant should illustrate what design features will be incorporated to ensure that the areas are safe and usable for disabled people. This has not been addressed within the design and access statement nor the appended access statement by the access consultant. Further information is therefore required on this element of the proposals.

42 In the pre-application report the applicant was asked to ensure that access to the communal amenity at podium level is secure and controlled and to have a strategy in place should the external lifts not be in working order. This needs to be addressed.

Mobility scooters

43 At pre-application stage the applicant was recommended to consider providing secure storage space and charging points for mobility scooters due to the limited amount of parking and the low PTAL. The design and access statement identifies that they are being considered but makes no commitment. Further information on what is to be provided is required.

Residential Units

44 The applicant has confirmed that all residential units will be designed to the Lifetime Homes standard and that 10% will be wheelchair accessible or easily adaptable homes. This is welcomed and, in line with London Plan Policy 3.8 Housing Choice, the applicant should demonstrate in the design and access statement that the design of the residential units meet the 16 Lifetime Home standards and that the wheelchair accessible homes meet the standards. This detailed information should be provided.

45 The access statement identifies that the proposals for standard units reviewed to date meet the requirements of the Lifetime Homes Standards subject to detail design. At pre-application officers advised that the inverted duplexes would need to be rearranged as the proposed plans indicated that the entry is into a floor with only bedrooms and bathrooms, which does not comply with Lifetime Homes. Detailed layouts are not provided in the design and access statement to demonstrate compliance and as such further detail is required.

Climate Change Energy

Energy efficiency

46 In terms of energy efficiency, a range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include mechanical ventilation heat recovery (MVHR) and low energy lighting.

page 7 Overheating

47 The demand for cooling will be minimised through solar control glazing and cross ventilation. The applicant has provided sample SAP outputs Part L compliance with the overheating criterion. However, the Part L compliance checklists provided suggest a medium risk for some of the dwellings. Further passive measures should be considered in line with Policy 5.9 to avoid the risk of overheating now and in future climate. Dynamic overheating modelling in line with CIBSE Guidance TM52 and TM49 is recommended. The development is estimated to achieve a reduction of 14 tonnes per annum (4%) in regulated carbon dioxide (CO2) emissions compared to a 2013 Building Regulations compliant development.

District heating

48 In terms of district heating, the applicant has carried out an investigation and determined that there are two potential district heating networks within the vicinity of the proposed development. Given the proximity to the scheme the applicant should contact the local energy officer to enquire about the current status of the proposed Tower Hamlets network, the applicant should provide evidence of correspondence to demonstrate that this has been thoroughly investigated.

49 The applicant has provided a commitment to ensuring that the development is designed, in accordance with the District Heating Manual for London, to allow future connection to a district heating network should one become available, which is supported.

50 The applicant is proposing to install a site heat network. However, the applicant should confirm that all apartments and non-domestic building uses will be connected to the site heat network. A drawing showing the route of the heat network linking all buildings on the site should be provided. The site heat network will be supplied from a single energy centre. This will be 110 sq.m. in size and located on the ground floor of block B.

Combined Heat and Power

51 In terms of combined heat and power (CHP), the applicant is proposing to install a 135 kWth gas fired CHP unit as the lead heat source for the site heat network. The CHP is sized to provide the domestic hot water load, as well as a proportion of the space heating (75% of the total heat load). A reduction in regulated CO2 emissions of 82 tonnes per annum (27%) will be achieved through this second part of the energy hierarchy.

Renewable energy technologies

52 In terms of renewable energy, the applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install a total 623 sq.m. (96kWp) of PV panels on the roof of Blocks B & C. A roof plan has been provided detailing the proposed location of the PV arrays. A reduction in regulated CO2 emissions of 46 tonnes per annum (20%) will be achieved through this third element of the energy hierarchy, which is supported.

Conclusion

53 Based on the above energy analysis, a total reduction of 142 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected, equivalent to an overall saving of 44%. The carbon dioxide savings exceed the target set within Policy 5.2 of the London Plan and subject to clarification of the above points the proposals are welcomed.

page 8 Flood risk/ sustainable drainage

54 A flood risk assessment (FRA) has been undertaken by RSK. This confirms that the site is at the edge of the tidal Flood Zone 3 and partially within Flood Zone 2 but is defended to a high level by the Thames Tidal Flood defences. The FRA has considered the likely impact of a breach or overtopping in the flood defences. This shows that the site is not likely to be affected by a breach. The FRA recommends that finished floor levels are set above any likely flood level, that flood resistant/resilient design measures are incorporated and that a flood emergency plan is prepared. Given the low level of risks present at the site, the proposals are considered to be compliant with London Plan Policy 5:12.

55 The drainage strategy contained within the FRA proposes to limit the surface water discharge rate to 5l/s from the site. This will be achieved by a slight reduction in the impermeable area, the use of green roofs and the installation of an attenuation tank. Given the location and nature of the development proposals these measures represent an acceptable approach to London Plan Policy 5:13 and the measures should be secured via an appropriate planning condition. Transport

56 The proposed development will be car free with the exception of 20 Blue Badge undercroft car parking spaces which accords with London Plan policy and reflects the good accessibility of the site. TfL requests nonetheless that 20% of these spaces have active electric vehicle charging points (EVCPs) and 20% passive. A car free legal agreement and car parking management plan secured by condition is also sought.

57 TfL understands that 358 cycle spaces will be located on the ground rather than in a basement in stores in the north and south east corners of the site and in undercroft stores. TfL considers their location acceptable however the provision needs to be increased by 53 spaces in accordance with London Plan 2015 standards.

58 The applicant has submitted a pedestrian environment review system (PERS) audit which concludes that there is a lack of dropped kerbs and the pedestrian amenity is poor. Furthermore, TfL consider this area to suffer from poor way-finding and accordingly recommends that a section 106 contribution is secured towards the upgrading of local pedestrian facilities and Legible London signage in accordance with London Plan policy 6.10.

59 Langdon Park station suffers from uneven loading, with some carriages busier than others, and this is exacerbated by the lack of full-length platform canopies. In line with that secured from the adjacent development to the south, a £300,000 contribution towards station capacity enhancements, should be secured within the section 106 agreement in accordance with London Plan policies 6.1 and 6.2.

60 As this development includes the construction close to the DLR line, TfL has provided Tower Hamlets Council with infrastructure protection conditions to be attached to the grant of any planning consent.

61 TfL considers that the bus network will have sufficient capacity to accommodate the uplift in bus passenger trips, however Tower Hamlets Council are recommended to secure a contribution to upgrade the nearby stop at Langdon Park station.

62 A draft construction logistics plan (CLP) has been submitted which is welcomed and TfL consider the principles contained within to be acceptable. Nevertheless, a full CLP will be required, to be secured by condition and agreed in consultation with TfL prior to construction commencing to ensure conformity with London Plan policy 6.14.

page 9 63 A full residential travel plan is required in line with TfL’s travel planning guidance with the final document secured, managed, monitored and enforced through the s106 agreement. Local planning authority’s position

64 The Council’s current position with regards to the changes is unknown at the time of writing this report. Legal considerations

65 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

66 There are no financial considerations at this stage.

Conclusion

67 London Plan policies on housing, affordable housing, tenure split, urban design, inclusive access, childrens playspace, climate change- energy and flood risk, and transport are relevant to this application. Whilst the application is broadly acceptable in strategic planning terms, further discussion and changes are required regarding the following issues:

 Housing/affordable housing: The results of the independent assessment of affordable housing provision should be shared with GLA officers demonstrating the maximum reasonable amount of affordable housing is being secured at the site.  Design: The noise mitigation proposed through appropriate architectural materials should be secured by condition and the playspace equipment proposed should also be secured and be useable given the implementation of PV on the roof top. Therefore the screening panels proposed should also be secured by condition. The overall approach to the layout, height and massing and the residential quality is supported.  Inclusive access: In order for the scheme to comply to London Plan Policies 3.8 and 7.2, the applicant is requested to provide further information relating to inclusive design. In addition the applicant will need to provide further information as set out in paragraphs 38- 45 of this report. The way-finding measures required by TfL will assist in alleviating some of the inclusive access concerns raised.  Climate change/energy: The applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole. Further information is required before the final proposals can be understood. The current carbon dioxide savings exceed policy requirements and are welcomed.

page 10  Sustainable drainage: The drainage measures proposed for the site by the applicant should be secured by the Council by way of condition.

 Transport: The proposal is considered to be potentially acceptable from a strategic transport perspective. However to ensure the application complies fully with London Plan transport policies, the various matters raised above and should be addressed and the various S106 agreements and/or conditions be secured by the Council.

for further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Sukhpreet Khull, Case Officer 020 7983 4806 email [email protected]

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