Canal & River Trust Fradley Junction, Alrewas, Burton-Upon-Trent

Tower Hamlets Borough Council Your Ref PA/20/00516/A1 Mulberry Place 5 Clove Crescent Our Ref CRTR-PLAN-2020-29482 London E14 2BG 24th April 2020

Dear Mr Woolway, Proposal: Redevelopment of existing site to accommodate two-storey community centre comprising nursery and community facility, ballcourt, playground, community garden, community orchard, and two x four storey buildings comprising 14 self-contained flats (all affordable rent tenure), together with landscape and access works (including 1 x disabled parking space and highway safety measures). Location: Canal Club Community Centre, Waterloo Gardens, London Waterway: Regent's Canal

Thank you for your consultation. We are the charity who look after and bring to life 2000 miles of canals & rivers. Our waterways contribute to the health and wellbeing of local communities and economies, creating attractive and connected places to live, work, volunteer and spend leisure time. These historic, natural and cultural assets form part of the strategic and local green-blue infrastructure network, linking urban and rural communities as well as habitats. By caring for our waterways and promoting their use we believe we can improve the wellbeing of our nation. The Trust is a statutory consultee in the Development Management process.

The main issues relevant to the Trust as statutory consultee on this application are:

a) The impact of the proposed development on the Conservation Area b) The impact on the structural integrity of the canal wall and subsequently, Conservation Area c) The impact on overshadowing of the adjacent moorings, the Regent s Canal and its ecology d) The impact on privacy and security of the adjacent moorings e) The impact on surface water drainage

Based on the information available our substantive response (as required by the Town & Country Planning (Development Management Procedure) (England) Order 2015 (as amended) is to advise that further information is sought on a number of matters prior to determination. Subject to this information being satisfactorily provided, suitably worded conditions and a legal agreement are necessary to address these matters. Our advice and comments follow:

Canal & River Trust Fradley Junction, Alrewas, Burton-upon-Trent, Staffordshire DE13 7DN T 0303 040 4040 E canalrivertrust.org.uk/contact-us W canalrivertrust.org.uk

The site falls within the Victoria Park Conservation Area, but also lies adjacent to the Regent Area. The submitted Heritage Statement makes only minimal reference to the Regent . It is understood that there is an historic slipway at the site, believed to have served local industrial purposes, including a timber yard, and later a furniture factory, and this should be further investigated to ensure evidence on site is not lost during redevelopment, and that the proposals adequately reflect the site with the canal. It would be beneficial if the development could incorporate some interpretation of the history and previous use of the site, and its relationship with the Regent s Canal as a working wharf.

The proposed architectural expression and forms appear to be quite interesting, and largely appropriate. However, having the western building (Block A1) built directly off the canal wall, at 4-storeys tall, will dramatically change the feel of the area, especially in this location where the offside (non-towpath side of the canal) opens up from the dense waterside development of Vyner Street, and where the existing properties on Lark Row and Sewardstone Road are set back some distance from the canal.

The 4 storeys proposed reaches something of a balance between the 3-storey development facing the canal on Lark Row and the slightly older development to the rear (Colville and Halkett House) which are 5-storeys. However, like this existing form, the proposed development might benefit if it were to step up in height further from the canal, with the elements closest being limited to 3-storey considering the proximity to the water, and the moorings. We consider that amendments are required to the design of Block A1 in the western corner, to minimise and the adjacent residential moorings.

It is unfortunate that the vista between the buildings is somewhat dominated by the cycle hoops and play equipment. The hard landscaping materials adjacent to the canal appear to be of high quality, as do the building materials themselves, with elevations that are interesting and generally well detailed. However, the winter garden framing full height, to differentiate it from the window openings on either side.

b) The impact on the structural integrity of the canal wall, and subsequently, Conservation Area

Development must not result in land instability in relation to the canal, in accordance with paragraph 109 of the National Planning Policy Framework. It is typically not advisable to develop right up to the canal edge due to the complex foundation interaction of the building and the canal wall. Setting the building back might be more appropriate. While technically possible to construct, the offside wall in this location is recorded as being of the proposed building, particularly given that it is shown springing directly off the canal wall. The Canal Conservation Area states: The protection of the character of the canal side should be protected and the It would appear that historically the canalside boundary of the site was previously a wharf, and its waterway walls are a significant

waterway wall survey be provided in advance of determination of the planning application, as well as full proposed foundation details, with cross section for 'Block A1', to enable full assessment of potential structural implications to the existing waterway wall. We therefore request that this information be provided as soon as possible, and be made available to the Trust, to allow us to properly assess the impact of the planning application. We will respond within 21 days of receiving this information.

Canal & River Trust Fradley Junction, Alrewas, Burton-upon-Trent, Staffordshire DE13 7DN T 0303 040 4040 E canalrivertrust.org.uk/contact-us W canalrivertrust.org.uk

Subject to the information provided by the waterway wall survey, the Trust may wish to request a suitably worded condition requiring the submission of the proposed foundation design for agreement with the Trust, to demonstrate that it will not have a short/long term impact on the canal wall integrity, during or after construction. This includes any excavation behind the canal wall.

We would also request a separate condition for details of an impact assessment for the expected vibrations and excavations due to the foundation construction, as well as a demolition plan to be agreed with the Trust, to mitigate impacts of the demolition works (vibrations and dust/debris) on the canal environment and boaters.

c) The impact on overshadowing on the adjacent moorings (Belmont Wharf), the Regent s Canal and its ecology

Moorings

The boats at Belmont Wharf (E2 Collective) are registered as residential moorings, having received planning consent in 2007. Yet the daylight and sunlight assessment does not consider them for the purposes of assessing the overshadowing impact of the development.

The submitted Daylight and Sunlight studies, both for Neighbouring Development and Within Development, fails

The effect of overshadowing upon the canal corridor, and in particular those boats moored on the southern bank will clearly be far greater than the existing canoe club building, yet this has not been considered at all within the submitted Daylight and Sunlight reports, despite the boats having approved residential use. We consider that further information should be submitted that properly assesses the impact of the proposed development on the living environment for the boaters, and the ecology/amenity value of the canal and towpath.

The gap between the buildings will go some way towards mitigating the overshadowing of the canal, but the high freeboard (distance between the water level and the top of the canal wall) of the southern bank only exacerbates the issue.

Ecology

Nature Conservation, although there seems to be little consideration for this within the proposals, with increased shadowing from building height and minimal ecological enhancements. The ecological survey briefly mentions the canal but does not propose any enhancements pick up any of the potential impacts upon the canal environment.

The increased height of the development, and its proximity to the canal corridor, are likely to have a significant impact on phytoplanktonic wildlife such as daphnia, the building blocks for aquatic systems, which are an important food source. Shading reduces plankton s ability to photosynthesis, therefore affecting the rest of the aquatic ecosystem. We would recommend a S106 requirement to provide floating ecosystems within the canal at appropriate locations (as agreed with the Trust), which would help to mitigate this impact, and help meet the objectives of the Tower Hamlets Biodiversity Action Plan.

Light pollution from adjacent developments can increase the ambient light in the canal corridor, which can impact upon foraging bat populations which are present in this area. We have therefore requested a condition be attached for further details of lighting.

Canal & River Trust Fradley Junction, Alrewas, Burton-upon-Trent, Staffordshire DE13 7DN T 0303 040 4040 E canalrivertrust.org.uk/contact-us W canalrivertrust.org.uk

We note that the existing community garden is proposed to be relocated, and this should be re-provided to an appropriate standard. The existing garden represents a very important biodiversity site, which is important to the ecology of the Regent , and its disruption due to the redevelopment should be mitigated by way of enhancements that improve the ecology of the canal corridor, as well as the amenity of the existing and future residents of the site (including the moorings) and the wider local community. This could include greening of the vertical north facing sections of building facing the waterway to deliver biodiversity, wellbeing and air quality and wellbeing benefits to the occupants and waterway users and wildlife, contributing to the green corridor.

c) The impact on privacy and security of the adjacent moorings (Belmont Wharf)

The proposals include a secured public canalside walkway for residents to access and sit alongside the Regent s Canal. However, there does not appear to be any screening between this area and the residential moorings on Belmont Wharf, and a loss of privacy and amenity seems highly likely. We have requested a condition, below, requiring further details of how the privacy and security of the moorings is to be managed.

We also have reservations about the stairwell/lift lobby ( common area ) in Block A1 being proposed immediately adjacent to the canal with openings looking directly onto the moorings beneath, and making them vulnerable to things being dropped from this public area, as well as exacerbating a loss of privacy. The scheme would be mo canal, which would also give the north facing apartments in the western block a better outlook onto the water. Private windows or balconies would be less likely to attract antisocial behaviour that could be detrimental to the mooring boats.

f) The impact on surface water drainage

We note the reference in the application to discharging surface water discharge to the canal. This may be acceptable contact informative, below.

Summary and planning conditions

Prior to planning permission being granted, therefore, we request that the outstanding information be submitted, and the Trust be consulted, on details of a waterway wall survey, in advance of determination of the planning application. This should include full proposed foundation details, with a cross section for 'Block A1', to enable full assessment of potential structural implications to the existing waterway wall. Detail of the proposed materials for the repair of the waterway wall should also be provided (this should potentially also be secured by condition, if sufficient information is not submitted prior to determination).

Additionally, we request further amendments to Block A1, including a redesigned stairwell/lift lobby (described as common area ), to be located away from the canal, to avoid public openings looking directly onto the moorings.

Should planning permission be granted (following receipt of the requested waterway wall information and the amendments to Block A1), we request that the installation of floating ecosystems be included in the S106 agreement, and that the following conditions and informatives are also appended to the decision notice:

Conditions

Risk assessment and method statement

Canal & River Trust Fradley Junction, Alrewas, Burton-upon-Trent, Staffordshire DE13 7DN T 0303 040 4040 E canalrivertrust.org.uk/contact-us W canalrivertrust.org.uk

Patron: H.R.H. The Prince of Wales. Canal & River Trust, a charitable company limited by guarantee registered in England and Wales with company number 7807276 and registered charity number 1146792, registered office address First Floor North, Station House, 500 Elder Gate, Milton Keynes MK9 1BB Prior to the commencement of the development hereby permitted, full details of a Risk Assessment and Method Statement (RAMS) shall be submitted to and approved in writing by the Local Planning Authority for all activities which have a potential to impact the integrity of the Regent s Canal or any of its associated infrastructure, including details of the scaffold design, and measures in place to mitigate contamination/collapse near the canal. These details shall include a program of implementation in accordance with the Canal & River Trust Code of Practice for Third Party Works. The works on site shall be carried out in accordance with the approved details.

Reason: To ensure, prior to any works taking place, the proposed construction works do not have any adverse impact on the safety and amenity of waterway users and the integrity of the Regent s Canal.

Vibrations and excavations

Prior to the commencement of the development hereby permitted, full details of an impact assessment for the expected vibrations and excavations due to the foundation construction, as well as a demolition plan shall be submitted to and agreed in writing by the Local Planning Authority, to mitigate impacts of the demolition works (vibrations and dust/debris) on the canal environment and boaters.

Reason: To ensure, prior to any works taking place, the proposed construction works do not have any adverse impact on the safety and amenity of waterway users and the integrity of the Regent s Canal.

Privacy and security of adjacent moorings

Prior to the commencement of the development hereby permitted, details of measures to ensure the continued privacy, security and enjoyment of the adjacent residential moorings shall be submitted to and approved in writing by the Local Planning Authority, and implemented in accordance with the approved details.

Reason: To ensure there are no adverse impacts on the adjacent moorings from the approved development.

Lighting

Prior to the occupation of the development hereby permitted, full details of the proposed lighting scheme, to include a lux levels plan, shall be submitted to and approved in writing by the Local Planning Authority. The approved lighting should be implemented in accordance with the approved details. Reason: In the interest of access, ecology, visual amenity and the waterway setting.

Landscaping The development hereby permitted shall not be occupied until full details of the proposed landscaping scheme (including the community garden) have been submitted to and approved in writing by the Local Planning Authority. The landscaping scheme should include reference to plant species types, surface treatments, fences and walls, any signage and information boards together with the means of on-going maintenance. The approved landscaping scheme shall be implemented by the first planting scheme after the development commences. Reason: In the interests of the appearance of the site when viewed from the waterside, access and to enhance the biodiversity of the area. Earthworks and associated landscaping also have the potential to impact on the integrity of the waterway and it is necessary to assess this and determine future maintenance responsibilities for any planting.

Informatives

e of Practice for Works affecting the Canal & River http://canalrivertrust.org.uk/about-us/for- businesses/undertaking-works-on-our-property).

Canal & River Trust Fradley Junction, Alrewas, Burton-upon-Trent, Staffordshire DE13 7DN T 0303 040 4040 E canalrivertrust.org.uk/contact-us W canalrivertrust.org.uk

The applicant/developer is advised that any surface water discharge into waterspace belonging to the Canal & for further information ([email protected]).

For us to monitor effectively our role as a statutory consultee, please send me a copy of the decision notice and the requirements of any planning obligation.

Please do not hesitate to contact me with any queries you may have.

Yours sincerely,

Claire McLean MRTPI Area Planner London

[email protected]

https://canalrivertrust.org.uk/specialist-teams/planning-and-design

Canal & River Trust Fradley Junction, Alrewas, Burton-upon-Trent, Staffordshire DE13 7DN T 0303 040 4040 E canalrivertrust.org.uk/contact-us W canalrivertrust.org.uk