planning report D&P/3474a/01 30 January 2017 Glengall Quay, in the Borough of Tower Hamlets planning application no. PA/16/03518

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 comprehensive mixed use redevelopment including two buildings ranging from 25 storeys (85.5m AOD) to 30 storeys (100.8m AOD) in height, comprising 316 residential units (Class C3), 1,778sqm (GIA) of flexible non-residential floor space (Classes A1, A3, A4 and D1), private and communal open spaces, car and cycle parking and associated landscaping and public realm works.

The applicant The applicant is Healey Development Solutions (Millharbour) Ltd, the planning agent is GVA and the architect is 3D Reid.

Strategic issues summary Land use principle: residential-led mixed-use redevelopment is supported (paragraph 14) Housing: the proposed offer of 35% by habitable room is broadly supported; however further discussions are required to ensure the affordability of the units, including the inclusion of London Living Rent. The applicant is also required to fully explore the use of grant funding in accordance with the draft Affordable Housing and Viability SPG. (paragraphs 15-19) Urban design: the scheme is generally well designed and the height and massing would not harm strategic views or the setting of heritage assets. (paragraphs 22-28)

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, for the reasons set out in paragraph 42 of this report. However, the resolution of those issues could lead to the application becoming compliant with the London Plan.

page 1 Context

1 On 23 December 2016 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 30 January 2017 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.

2 The application is referable under the following Categories 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 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 outside Central London and 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 and outside the City of London.

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

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011, as amended, has been taken into account in the consideration of this case.

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

6 This 0.7 hectare site is bound to the east by Inner Dock and to the west by Millharbour. Pepper Street runs through the site from east to west and provides pedestrian and cycle access between Millharbour and Crosshabour DLR station via a bridge over the dock, although elements of this route are also open to traffic. Muirfield Crescent runs around the edge of the site, providing vehicle access to the existing buildings, as well as the flats immediately to the east. To the north and south are large data centre buildings in the process of being extended/redeveloped. The application site comprises predominantly three to four storey buildings with ground floor commercial uses fronting Pepper Street and office uses above, along with surface car parking. There is also a two storey public house, known as Pepper St Ontiod, adjacent to the dock.

7 The site is well served by public transport; Crossharbour Docklands Light Railway (DLR) station can be accessed 150 metres to the east, across Glengall Bridge, and South Quay DLR station is located 450 metres to the north. The nearest London Underground station is , on the Jubilee line, located 1 kilometre north of the site. Canary Wharf Elizabeth Line station, due to open in December 2018, is located approximately 1.3 kilometre to the north of the site. In addition, three bus routes operate along East Ferry Road (D6, D8 and 135). The site therefore has a moderate Public Transport Accessibility Level (PTAL) of three (on a scale out of six, where six is excellent). The site is also served

page 2 by the Mayor’s Cycle Hire Scheme, with the nearest docking station located on Millharbour (19 docking points). Pepper Street is on National Cycle Route 1, from London Docklands to Lea Valley.

8 The site sits within a number of strategic views and river prospects, as identified in the Mayor’s London View Management Framework, including View 5A.1: Park, View 6A.1 Blackheath, View 11B.1: London Bridge and View 11B.2: London Bridge. The site also falls within the wider setting of the Maritime Greenwich World Heritage Site.

Details of the proposal

9 Full planning permission is sought for the comprehensive redevelopment of the site, retaining the Davenport House office building and Pepper St Ontiod pub, and comprising the construction of two new buildings of 25 and 30 storeys. The buildings would comprise 1,778 sq.m. of retail and nursery uses at ground floor, with 316 residential units above. The residential element comprises a mixture of private market and affordable housing. Improved public realm is also proposed, including an east-west route linking Millharbour with Glengall Bridge, as well as private amenity and play space. Case history

10 On 5 March 2015, the former Mayor considered a report on a previous planning application for the site (reference D&P/3474/01), which proposed a comprehensive redevelopment for three buildings up to 15 and 45 storeys comprising 484 residential units and ground floor commercial and community space. The former Mayor supported the principle of the development, but requested further information regarding affordable housing, strategic views, inclusive design, energy and transport. This application was subsequently withdrawn by the applicant prior to being considered by Tower Hamlets Council.

11 This current scheme differs from the previous scheme principally due to the retention of two of the existing buildings and the reconfiguration of the layout and scale of the development to accommodate them. This scheme has been the subject of pre-application discussions with GLA officers, over four meetings since May 2016. Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

 Land use principle London Plan;  Housing and affordable housing London Plan; Draft Affordable Housing & Viability SPG; Housing SPG; Housing Strategy; Providing for Children and Young People’s Play and Informal Recreation SPG; Social Infrastructure SPG;  Urban design London Plan; Character and Context SPG;  Tall buildings and heritage London Plan; London View management framework SPG, Character and Context SPG, World Heritage Sites SPG;  Inclusive design 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;  Transport and parking London Plan; the Mayor’s Transport Strategy;  Crossrail/CIL London Plan; Mayoral Community Infrastructure Levy; Crossrail SPG.

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13 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 Managing Development Document (2013), as well as the London Plan (Consolidated with Alterations since 2011). The Tower Hamlets Draft Local Plan (November 2016), the National Planning Policy Framework and Technical Guide to the National Planning Policy Framework, are also relevant material considerations. Land use principle

14 The site lies within the Isle of Dogs & South Poplar Opportunity Area, as identified in the London Plan. London Plan Policy 2.13, and Table A1.1, states that the Opportunity Area is capable of accommodating at least 10,000 homes, and 110,000 jobs up to 2031. An Opportunity Area Planning Framework (OAPF) is currently being produced by GLA and Tower Hamlets officers. The London Plan recognises that the north of the Isle of Dogs forms a strategically significant part of London’s world city offer for financial, media and business services, and that surplus business capacity south of Canary Wharf provides an opportunity to deliver new housing, and to support a wider mix of services for residents, workers and visitors. Furthermore, the site is not identified for employment use within the London Plan. Accordingly, the proposed mixed-use development, to include housing and commercial uses to serve the local population, is strongly supported in accordance with strategic planning policy. Housing

Housing products and mix

15 The proposed residential mix is set out in the below table. The scheme prioritises affordable family housing, which is supported in line with London Plan Policy 3.8. The applicant has advised that the market element may come forward as a build to rent product. The principle of PRS housing in this highly accessible location in an Opportunity Area is supported.

unit type market % intermediate % affordable rent % 1 bed 88 40 12 40 18 28 2 bed 116 52 18 60 16 24 3 bed 17 8 - - 24 37 4 bed - - - - 7 11 total 221 30 65

Affordable housing

16 The application proposes 95 affordable units, which equates to 30% of the unit numbers and 35% of the habitable rooms within the scheme. The split would be approximately 70% affordable rent (at Council framework rent levels) and 30% intermediate (shared ownership), in line with the Council’s Local Plan policy requirements. Whilst the overall quantum responds positively to the strategic threshold set out in the Mayor’s draft Affordable Housing and Viability SPG, the affordability of the offer (set out in the below table) is not consistent with the requirements of the SPG. Accordingly, the applicant has submitted a viability assessment to support the application.

page 4 affordable rent intermediate unit type LBTH London % of household income monthly London framework Rent Map market requirements property Living rents rent expenditure Rent 1 bed £234pw £335pw 70% £65,000pa £1,814 £1,058 2 bed £245pw £420pw 58% £86,500pa £2,400 £1,176 3 bed £295pw £506pw 58% N/A N/A N/A 4 bed £299pw £685pw 44% N/A N/A N/A

17 Given the site is located in an Opportunity Area, a more flexible approach can be taken with regard to tenure mix, as set out in the draft SPG. However, it is essential that the proposed affordable offer, and particularly the intermediate units, are genuinely affordable. Further discussions are therefore required with the applicant and the Council regarding the affordability of the proposal, including a full investigation of the inclusion of the London Living Rent product.

18 Furthermore, the applicant is required to submit additional scenario testing to demonstrate whether the scheme can viably deliver 40% affordable housing with grant funding. If it can, two scenarios should be secured through the S106, one with grant and the other without. The applicant’s chosen Registered Provider (RP) would be responsible for bidding for the grant funding, so further discussions with potential RPs is required prior to the application being referred back to the Mayor at Stage 2.

19 The viability assessment has been carried out on the basis of a private sale scheme, rather than a PRS option, which the applicant is also considering, and the proposal as currently presented includes affordable housing to be secured through the s.106 agreement. Further discussion is therefore required on the nature of the market element and the overall scheme viability, in order to understand fully the maximum proportion of affordable housing, and how this will be secured.

Density

20 London Plan Policy 3.4 requires development to optimise housing output for different locations taking into account local context and character, the design principles in Chapter 7 and public transport capacity. The PTAL of the site is 3 and is in a central setting, although it is very close to higher PTAL areas, on the eastern side of Glengall Bridge. Based on a site area of 0.7 hectares, the proposal would have a density of 1,492 habitable rooms per hectare, which is significantly above the guidance range set out in the London Plan. The principle of a high density scheme on this site is acceptable and as discussed below, no strategic concern is raised with regard to scale and massing. As set out below, whilst a comprehensive approach would deliver further benefits to public realm, the proposal responds positively to London Plan design policies, is of a high residential quality, and provides appropriate levels of play space.

Children’s play space

21 London Plan Policy 3.6 seeks to ensure that development proposals include suitable provision for play and recreation and further detail is provided in the Mayor’s Shaping Neighbourhoods: Play and Informal Recreation SPG. The development will provide a total of 1,285 sq.m. of play space, split between the blocks and public realm, exceeding the 1,075 sq.m. quantum required by the SPG. Doorstep play space for 0-5 year olds has been prioritised in the private podium courtyards, and play space has been designed to integrate with the proposed landscaping, usable by all age groups. The

page 5 approach to children’s play space accords with London Plan Policy and is supported. The Council should secure details of the play space design by condition. Urban design

Layout and public realm

22 The approach taken to scheme layout is well resolved and the applicant has responded positively to pre-application advice. The proposal would reinstate the strategic east-west route linking Millharbour to Crossharbour and the emerging district centre, over Glengall Bridge. The improvement to the quality and generosity of this important route is welcomed, subject ensuring a safe environment for cyclists and pedestrians, and the new Pepper Street would be well animated by active commercial uses and residential entrances. A Use Class A4 unit has been included opposite the retained public house to provide additional activation in this section of the site, which is welcomed. The pub would be retained as a low rise, pavilion structure within this space.

23 The scheme proposes two other public spaces at each end of the east-west route. The corner park space fronting Millharbour helps to signal the importance of Pepper Street and would read as an extension to the existing and emerging public realm along this part of Millharbour. The quayside space would be in two parts, a playable seating area between the dockside and the retained Davenport House, along with a plaza space between the retained pub and the southern building. The retention of these two buildings does significantly limit the configuration and quantum of the public realm in this part of the scheme, and as such a comprehensive scheme involving the demolition of these buildings, and the provision of increased public realm at the dock edge would deliver demonstrable benefits. Nevertheless, the applicant has responded positively to pre-application advice on the design of these spaces, and has also extended the basement area to reduce surface level vehicle movements. There is also the potential for the public realm to be extended to the south, when this site comes forward.

24 The overall approach to layout, which starts to form perimeter blocks with the adjacent sites to the north and south, is welcomed. The applicant has responded positively to concerns raised during pre-application discussions regarding the proximity of the southern tower to the boundary. The residential layouts on the lower floors have been designed to ensure that primary living spaces are orientated east and west, so as not to impact on the future development potential of this site, which is welcomed. However, the applicant should commit to gating off the rear service route and car park entrance area between Building A and Archway House, to the north. A scheme showing this area delineated away from the public realm, whilst enabling the necessary service vehicle movements, should be provided and secured by the Council as an amendment or by condition.

Height, massing, heritage and strategic views

25 The application proposes two buildings at 30 and 25 storeys. These building heights would be taller than the emerging context along this part of Millharbour, although similar to other permitted schemes nearby, including Baltimore Wharf and Westferry Printworks. Whilst the towers would be prominent in local views, given the benefits of landmarking the intersection of Millharbour with the key strategic east-west route, the high standard of architecture proposed and the emerging context in the Opportunity Area, this height does not raise strategic concern.

26 As noted above, the development would lie within a number of strategic views, as identified in the Mayor’s London View Management Framework (LVMF), as well as in the wider setting of the Maritime Greenwich World Heritage Site (MGWHS). The Townscape, Heritage and Visual Impact Assessment accompanying the application includes a comprehensive assessment of the impact on all of the strategic views and the setting of the MGWHS. From the east and west the buildings would be seen to step down away from the taller buildings in the Canary Wharf cluster and South Quay. In

page 6 officers’ view, the proposal does not have a detrimental impact on any of the LVMF views in which it would be visible, nor would it harm the setting of the MGWHS or any other heritage assets. The height of the proposal is therefore acceptable with regard to heritage and strategic views.

Architectural treatment

27 Both buildings would have a similar architectural treatment, comprising masonry piers with deep reveals and contrasting metal panels, along with balconies that are part recessed, part projecting. The masonry frame would extend above the top floors to add interest to the skyline. At ground floor, building overhangs and colonnades would break down the mass of the buildings giving a more human scale at street level, which is supported. The overall approach is supported and will result in a high quality contemporary design. The Council should however ensure that the necessary controls over detailing and materials are secured by condition.

Residential quality

28 The residential quality of the scheme is high and the applicant has responded positively to comments made at pre-application stage, including orientating units away from the southern site boundary facing over the proposed public realm and two storey retained public house. There would be no more than 8 units per core and dual aspect units are maximised, with no single aspect north- facing units, which is welcomed. All the dwellings meet or exceed the minimum space standards established by London Plan Policy 3.5 (Table 3.3), and would be in overall conformity with the minimum standards for external amenity space set out in the Mayor’s Housing SPG. The scheme also achieves a minimum residential floor to ceiling height of 2.5 metres. The scheme is therefore acceptable in terms of residential quality. Inclusive design

29 In accordance with London Plan Policy 3.8, the applicant has confirmed that all of the residential units will meet Building Regulation M4(2) standards, and that 10% of the units will be designed to be fully adaptable and adjustable to wheelchair users (M4(3) standards). The wheelchair accessible/adaptable units would be distributed across unit types and tenures. The Council should secure details of compliance with Building Regulations M4 (2) and M4 (3) by condition.

30 The proposals would also ensure level and inclusive access to the non-residential uses and throughout the public realm, which is welcomed. Many of the proposed benches would enable wheelchair users to easily transfer and use these features, which is welcomed. Four Blue Badge spaces are proposed in the basement, which does not comply with London Plan standards. Given that 58 parking spaces are retained with an existing leasehold, this provision should be increased. Climate change

31 A range of energy efficiency measures are proposed, including low energy lighting and energy metering and monitoring. An overheating analysis has been undertaken, but the applicant should address queries made regarding the methodology. The proposed development does not achieve any carbon savings from energy efficiency alone compared to a 2013 Building Regulations compliant development. The applicant should therefore model additional energy efficiency measures and commit to the development exceeding 2013 Building Regulations compliance through energy efficiency alone.

32 The applicant has identified an existing heat network nearby, the Barkantine district heating network, and is proposing to connect. This should continue to be prioritised and the design of the energy centre should enable this connection. The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install a photovoltaic (PV) array, although the applicant should investigate increasing the amount of PV to maximise on-site savings.

page 7 33 An on-site reduction of 111 tonnes (residential) and 19 tonnes (commercial) 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 32% for the residential element and 17% for the commercial. The carbon dioxide savings fall short of the on-site target within Policy 5.2 of the London Plan. The applicant should consider the scope for additional measures aimed at achieving further carbon reductions before any agreement is made with the local authority on a contribution to the borough’s offset fund. Flood risk

34 The site is within Flood Zone 3, although it is protected to a degree by the existing tidal flood defences. The Flood Risk Assessment accompanying the application proposes a number of mitigation measures, including safe refuge for ground floor uses and flood proof enclosures for essential building utilities, which are welcomed and should be secured by condition. Whilst the proposals are acceptable in relation to flood risk, there is a concern that the surface water drainage design does not maximise the opportunity to reduce surface water discharge. The applicant should consider further alternative designs and, given the location adjacent to , further consideration should be given to connecting directly to the dock, in order to address the requirements of London Plan Policy 5.13. Transport

Access and pedestrian and cycle safety

35 Vehicles accessing the site will do so from Millharbour, circulating clockwise along the northern service road and exiting the site from Pepper Street. The applicant should clarify how the site will be designed to avoid conflict between vehicles and cyclists. The applicant proposes to widen Pepper Street from 6 metres to 11 metres and create a shared space, which is welcomed. As it is part of a strategic east-west cycle link, it should be designed to ensure uninterrupted cycle movement and incorporate measures to reduce conflict between pedestrians, cyclists and vehicles. The applicant should also provide new wayfinding signage within the site to encourage walking and cycling, as well as securing 24 hour public access through the S106 agreement.

Car parking

36 The development would be served by 58 spaces, a reduction of 88 spaces over the existing situation, with four designated as Blue Badge for residents, and the remaining 54 spaces allocated to existing leaseholders in the area. Whilst the reduction in overall parking is supported, the applicant should explore the possibility of reallocating leaseholder spaces to increase Blue Badge provision in line with London Plan standards, which require 30 Blue Badge spaces.

Cycle parking

37 Residential cycle parking will be located in two stores at basement level, accessed via cycle lift from Pepper Street. 554 long stay spaces are proposed which complies with London Plan standards and is welcomed. The proposed quantum of cycle parking for the non-residential uses is acceptable. The applicant should provide further details on the design of cycle parking with reference to London Cycling Design Standards (LCDS) and a Cycle Level of Service assessment.

page 8 Servicing and construction, travel planning

38 Servicing is proposed to take place from a loading area in the basement car park and on Pepper Street. A full delivery and servicing plan should be provided, secured by condition. The applicant has outlined the construction methodology, but should demonstrate how this key east- west route through the site will remain functional during construction. A full construction logistics plan including a feasibility assessment of transporting freight by water, should be secured by condition. The submission of a framework residential travel plan and a full travel plan should be secured through condition or Section 106 agreement. Local planning authority’s position

39 The Council are currently considering the application and are awaiting a number of consultation responses. Legal considerations

40 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

41 There are no financial considerations at this stage. Conclusion

42 London Plan policies on Opportunity Areas, housing, urban design, heritage, inclusive design, climate change and transport are relevant to this application. The principle of the residential-led mixed- use redevelopment of this site in the Isle of Dogs & South Poplar Opportunity Area, is strongly supported. A number of outstanding concerns are raised with regard to affordable housing, climate change, flood risk and transport:

 Affordable housing: further discussions are required to ensure the affordability of the proposed affordable housing, including a full investigation of London Living Rent. The applicant should also fully explore the inclusion of grant funding, in order to ensure compliance with London Plan Policy 3.12 and the Mayor’s draft Affordable Housing and Viability SPG.

 Climate change: the energy strategy does not fully accord with London Plan Policies 5.2, 5.6, 5.7 and 5.9. Further information regarding overheating, connection to the heat networks, the on-site heat network and renewable energy is required. The final agreed energy strategy should be appropriately secured by the Council, along with S106 obligations for off-site mitigation.

page 9  Flood risk: the applicant should investigate options for reducing the rate of surface water discharge further, including connection to the dock, in order to ensure compliance with London Plan Policy 5.13.

 Transport: to ensure that the scheme accords with London Plan policies 6.1, 6.7, 6.9, 6.10 and 6.13 the applicant should address concerns over conflict between vehicles and pedestrians/cyclists along Pepper Street, increase Blue Badge parking spaces and provide more detail on the design of cycle parking. A delivery and servicing plan, construction logistics plan, travel plans and public access should be secured by condition/S106 agreement.

for further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Sarah Considine, Strategic Planning Manager (Development Decisions) 020 7983 5751 email [email protected] Nick Ray, Senior Strategic Planner, case officer 020 7983 4178 email [email protected]

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