planning report GLA/4823/01 3 September 2019 G-Park London Docklands (Land at Central Thameside West) in the London Borough of Newham planning application no. 19/01776/FUL
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 Construction of a three-storey storage and distribution warehouse, containing 40,473 sq.m. of floorspace; 275 sq.m. of flexible storage/distribution/retail use; associated servicing yards; 255 staff parking spaces over five storeys; roof level staff amenity area; landscaping and public realm; re-positioning of wharf access road; and new vehicular roundabout.
The applicant The applicant is Gazeley and the architect is Chetwoods.
Strategic issues summary Principle of development: The proposal for a three storey storage and distribution ‘last mile logistics’ warehouse on a SIL site within an Opportunity Area that has been vacant for 20 years, in close proximity to central London and the northern Isle of Dogs, is strongly supported in line with the London Plan, draft London Plan, and the Site Allocation; however, this is subject to the resolution of air quality issues and appropriate mitigation. Air Quality: The applicant must consider how emissions can be further reduced, including maximising the use of zero emission onward deliveries, a reduction in staff car parking, and the use of river transport for inward freight movements. Urban design: The proposed building is innovative in design and well-conceived. Transport: Employee car parking should be reduced, and Blue Badge provision increased. A revised trip assignment and highway impact assessment is required taking account of the Silvertown Tunnel. Further work on the design of the proposed access roundabout is required to achieve a more pedestrian and cycle friendly environment. Climate change: Further information has been requested on the energy strategy, the surface water drainage strategy, water consumption, and urban greening.
Recommendation That Newham Council be advised that the application does not yet comply with the London Plan and the draft London Plan, for the reasons set out in paragraph 60 of this report; but that the possible remedies set out in that paragraph could address these deficiencies.
page 1 Context
1 On 23 July 2019, the Mayor of London received documents from Newham 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 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 Categories 1B, 1C, and 3F of the Mayor of London Order 2008: • 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 (c) outside Central London and with a total floorspace of more than 15,000 square metres.” • 1C “Development which comprises or includes the erection of a building of (a) more than 25 metres high and is adjacent to the River Thames”, and (c) ”more than 30 metres high and is outside the City of London.” • 3F “Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use.”
3 Once Newham 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 2017, 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 The 3.3 hectares site is located on the south-west side of North Woolwich Road/ Silvertown Way and the DLR viaduct; to the north-west of a Tate and Lyle facility; and to the south-east of a Nuplex Resins facility. To the south-west is a designated wharf (Peruvian Wharf) beside the River Thames, owned by the Port of London Authority (PLA), with part of the wharf site currently being developed for an aggregates facility, and a further part subject to a current planning application for waste transfer and associated works (Ref: GLA/0064g/01; LPA Ref: 18/03543/FUL). The proposal site, and these neighbouring sites, are within a designated Strategic Industrial Location (SIL). An area of vacant land to the north-east of the site adjacent to West Silvertown DLR Station falls outside the SIL, and is subject to a current planning application by L&Q for residential-led mixed-uses (Ref: GLA/4924/01; LPA Ref: 19/01791/FUL). Further to the north, across Silvertown Way, is the Britannia Village residential area, with blocks of up to 6 storeys, beyond which is the Royal Victoria Dock.
7 The proposal site has been vacant for approximately 20 years and is hoarded, apart from the wharf access road that runs along the north side of the site, providing access to the wharf to the west.
page 2 8 The site forms part of Strategic Site S07 (Central Thameside West) within Newham Council’s Local Plan (2018), for employment and wharf development consistent with the SIL designation, maximising opportunities for modern industrial uses and supporting the wharf use, including providing access.
9 The site is within the London City Airport Safeguarding Zone, which constrains the height of any development.
10 The site falls within the Royal Docks and Beckton Riverside Opportunity Area.
11 The part of North Woolwich Road adjacent to the site is a Borough highway, while the A1020 Silvertown Way/North Woolwich Road is part of the Strategic Road Network (SRN). The nearest parts of the Transport for London Road Network (TLRN) are the A13 at Canning Town and Pier Road/Woolwich Ferry (A117), respectively 1.6 kilometres and 2.9 kilometres away. The Docklands Light Railway viaduct is adjacent to the site and West Silvertown Station is approximately 50 metres away, with one bus route stopping adjacent to the Station. As such, the site records a public transport accessibility level (PTAL) of 2 to 3 (on a scale of 0 to 6b, where 6b is the highest).
Details of the proposal
12 A full application to construct a three-storey (approximately 36 metres), 40,473 sq.m. storage and distribution ‘last mile logistics’ warehouse (Use Class B8); 275 sq.m. of flexible storage and distribution/retail use (Use Class B8/A1/A3) at ground level; associated servicing yards; 255 space staff parking facility over five levels; new access arrangement; and roof-level staff amenity space. The building has been designed flexibly so that each of the building’s floorplates can be sub-divided, allowing for between one and six occupiers. Each level provides an element of ancillary office accommodation, and an external yard area accessed via a ramp that circulates around the exterior of the building.
13 A new landscaped public space is proposed to the east of the building, fronting onto North Woolwich Road and extending beneath the DLR viaduct. The proposals also include re- positioning the wharf access road and a new roundabout junction from North Woolwich Road. The southern exit on the proposed roundabout will lead to a dedicated on-site access road running along the eastern boundary of the Site (adjacent to Tate and Lyle’s premises) to a gatehouse and the ramped access. The proposed roundabout includes an exit providing vehicle access to the adjacent L&Q residential-led/mixed-use Lyle Park West site, subject to a current planning application.
Case history
14 In September 2016, Galliard Homes submitted a planning application proposing to comprehensively redevelop land at Peruvian Wharf (GLA Ref: D&P/3844/01; LPA Ref: 16/02947/FULL). This application site was significantly larger than the site under consideration here, including the neighbouring L&Q site to the north-east. It proposed a mixed use scheme of up to 20 storeys, comprising 946 residential units, 527 sq.m. of retail and 1,841 sq.m. of employment uses. The application was withdrawn in early 2018, due to non-conformity with the SIL designation.
15 On 8 November 2018, a pre-planning application meeting was held at City Hall for a “three storey ‘last-mile’ logistics premises (45,000 sq.m. Use Class B8), 350 space multi-storey car park, new vehicular access, and associated works”. On 27 November 2019, a pre-application advice note was issued, which concluded that the principle of a three-storey logistics facility, at
page 3 this long-vacant SIL site within the Royal Docks and Beckton Riverside Opportunity Area, was strongly supported in strategic planning terms; however, the level of car parking proposed raised concerns. The applicant was also requested to ensure that issues raised with respect to Strategic Industrial Locations; Safeguarded Wharves; urban design; transport; and climate change should be fully addressed prior to the submission of any planning application.
16 A planning application (LPA Ref: 19/02183/FUL) was approved by Newham Council in December 2018 for enabling works comprising remediation/below-ground obstruction removal, archaeological investigations and associated works. These works allow delivery of the scheme proposed by the current planning application.
Strategic planning issues and relevant policies and guidance
17 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 Newham Local Plan (2018) and the 2016 London Plan (Consolidated with Alterations).
18 The following are also relevant material considerations: • The National Planning Policy Framework 2019 and National Planning Practice Guidance. • The draft London Plan consolidated suggested changes version (July 2019), which should be taken into account on the basis explained in the NPPF.
19 The relevant issues, corresponding policies, and guidance, are as follows: • Opportunity Areas London Plan; draft London Plan • Industrial land London Plan; draft London Plan; Land for Industry and Transport SPG • Air quality London Plan; draft London Plan; Sustainable Design and Construction SPG; Mayor’s Environment Strategy • Safeguarded wharfs London Plan; draft London Plan • Urban design London Plan; draft London Plan; Shaping Neighbourhoods: Character and Context SPG; Accessible London: achieving an inclusive environment SPG • Transport London Plan; draft London Plan; the Mayor’s Transport Strategy • Climate change London Plan; draft London Plan; Sustainable Design and Construction SPG; Mayor’s Environment Strategy Principle of development
Opportunity Area
20 The site is located in the Royal Docks and Beckton Riverside Opportunity Area, as identified in London Plan Policy 2.13 and Table A1.1, and Policy SD1 of the draft London Plan. The London Plan identifies the Opportunity Area as having an indicative employment capacity of 6,000; while the draft London Plan identifies a significantly increased employment capacity of 41,500 between 2019 to 2041. The draft London Plan recognises that the area has significant Strategic Industrial Locations (SIL) and cites recent evidence confirming that there is a continued demand for industrial space in east London. It states that the forthcoming Royal Docks and Beckton Riverside Opportunity Area Planning Framework (OAPF) should ensure that industrial capacity is managed in ways that reduce overall vacancy rates and support the intensification of industrial, logistics and commercial uses so that they continue to form part of the overall mix of uses in the area.
page 4
21 The proposals are estimated to provide 655 full-time equivalent jobs on a SIL site within an Opportunity Area that has been vacant for 20 years. The proposal will contribute to these policies and job targets, and is strongly supported, subject to the resolution of air quality issues discussed below.
Strategic Industrial Land
22 The site is located within the Thameside West Strategic Industrial Location (SIL), which extends beyond the proposal site to the east, west, and south. The neighbouring site to the north-east was de-designated as SIL by the Council’s 2012 Core Strategy and is subject to a current planning application by L&Q for a mixed-use residential scheme. The application site is identified as part of Strategic Site S07 ‘Central Thameside West’ in Newham’s Local Plan, for employment and wharf development consistent with the SIL designation, maximising opportunities for modern industrial uses and supporting the wharf use, including access.
23 London Plan Policy 4.4 ‘Managing industrial land and premises’ states that a rigorous approach is required to ensure a sufficient stock of land and premises to meet the future needs of different types of industrial and related uses, including good quality and affordable space; and that any release of surplus industrial land must be planned, monitored and managed. London Plan Policy 2.17 ‘Strategic Industrial Locations’ states that SIL should be promoted, managed and protected as London’s main reservoir of industrial and related capacity, and that proposals in SIL should be refused unless they fall within the broad industrial type activities appropriate to the function of the particular SIL in question. This SIL is identified in Table A3.1 as a Preferred Industrial Location, with suitable uses including employment workspace to meet identified needs for SMEs or new emerging industrial sectors, and small scale ‘walk to’ services for industrial occupiers such as workplace creches or cafes. Policy 2.17 also identifies that development proposals within or adjacent to SILs should not compromise the integrity or effectiveness of these locations in accommodating industrial type activities.
24 Policy GG5 ‘Growing a good economy’ of the draft London Plan seeks sufficient employment and industrial space in the right locations to support economic development and regeneration. Policy E4 ‘Land for industry, logistics and services…’ seeks to ensure a sufficient supply of land and premises to meet current and future demands for industrial and related functions to be maintained, as set out in Policy E7 ‘Intensification, co-location, and substitution…’, which supports intensification, including multi-storey schemes. The uses supported in these areas are identified in Policy E4, including storage and logistics/distribution (Class B8), including ‘last mile’ distribution close to central London and the Northern Isle of Dogs, consolidation centres and collection points. Draft London Plan Policy E5 ‘Strategic Industrial Locations’ states that developments within or adjacent to SIL must not compromise the integrity or effectiveness of these locations in accommodating industrial type activities and their ability to operate on a 24-hour basis.
25 The proposal for a three storey storage and distribution ‘last mile logistics’ warehouse on a SIL site within an Opportunity Area that has been vacant for 20 years, in close proximity to central London and the northern Isle of Dogs is strongly supported in line with these London Plan and draft London Plan policies, as well as the Site Allocation, subject to the resolution of air quality issues discussed below. The stacked intensified nature of the proposals also accords with draft London Plan Policy E7, responding to the release of areas of former SIL in the area. The 275 sq.m. of flexible storage and distribution/retail use (Use Class B8/A1/A3) has been requested by the Council in order to provide active ground floor use on the SIL boundary facing onto North Woolwich Road, which is supported in line with London Plan Policy 2.17.
page 5 Agent of change, air quality, noise, and lighting
26 Draft London Plan Policy D12 ‘Agent of change’ states that new noise and other nuisance-generating development proposed close to residential and other sensitive uses should put in place measures to mitigate and manage any impacts. Furthermore, it states that development proposals should manage noise and other potential nuisances by ensuring good design mitigates and minimises existing and potential nuisances; exploring mitigation measures early in the design stage, with necessary and appropriate provisions, including ongoing and future management of mitigation measures secured through planning obligations; and separating new noise-sensitive development where possible from existing noise-generating businesses and uses through distance, screening, internal layout, sound-proofing, and insulation and other acoustic design measures.
27 The applicant has submitted an Environmental Statement, which includes assessments of noise and air quality, primarily arising from the road traffic impacts arising from the scheme. A fully occupied scheme would generate movements of 138 heavy goods vehicles and 2,478 vans operating over a 24-hour period. The noise assessment has been undertaken on the basis of the site’s proximity to existing residential uses at Britannia Village, beyond the DLR viaduct and North Woolwich Road, but also taking account of the proposals on the adjacent site to the north-east, subject to a current planning application for a residential-led mixed-use scheme by L&Q (Ref: GLA/4924/01; LPA Ref: 19/01791/FUL). The assessment concludes that none of the scheme’s noise impacts would be significant, subject to the proposed mitigation measures, which include sound absorption within the service yard areas at lower levels, and restriction of refrigeration operations to the lower two levels within the scheme. The noise assessment concludes that construction, operational, plant, and road traffic impacts will be ‘minor adverse’ or ‘negligible’. It is also noted that L&Q, the applicant for the current planning application referred to above on the adjacent site, has worked closely with Gazeley in developing its proposals, and the L&Q proposals also include measures to mitigate impacts arising from this proposal. Given the above, the proposals are considered to have been designed to ensure that they are compatible with the surrounding area and existing/emerging sensitive receptors from a noise perspective, subject to appropriately secured mitigation as part of any permission.
28 The applicant’s air quality assessment is of high quality, considers the relevant emissions sources, and includes a reasonable selection of receptors. It details existing air quality conditions in the wider area, with nitrogen dioxide (NO2) concentrations exceeding the national air quality objectives at some locations, while concentrations of particulate matter (PM10) in the majority of locations are below the objectives. The draft London Plan emphasises that the World Health Organization target for fine particulate matter (PM2.5) should be considered similarly to legal limits for other pollutants. This target is not currently being met in London and developments are expected to minimise as far as possible emissions of this pollutant.
29 The air quality assessment is informed by the transport trip assignment and highway impact assessment; however, as discussed under ‘transport’ below, this requires a future-year 2026 assessment to take account of the Silvertown Tunnel, and further air quality modelling.
30 During the construction phase, a number of mitigation measures to reduce dust emissions have been identified and will need to be appropriately secured in any permission. During the operation of the proposed development, emissions from the energy plant would have ‘non-significant’ impacts on local air quality. While development-generated traffic is expected to have negligible impacts on most receptors, the air quality assessment identifies potentially major and moderate NO2 impacts at the recently built Aberfeldy Village development on East India Dock Road, approximately 1.5 kilometres to the west. The assessment identifies that it has not been possible to review the ventilation strategy for Aberfeldy Village, although it is
page 6 understood that a mechanical ventilation system has been installed. Notwithstanding this, in line with agent of change principles, the applicant must further reduce air quality impacts. The applicant proposes to offset the impacts through the use of an air quality payment, based on DEFRA’s ‘damage-cost’ approach; however, the use of such off-setting payments should only be used as a last resort.
31 Other mitigation measures proposed to minimise potential air quality impacts include provision of 20% electric charging points, with the remainder provided with passive provision, and encouraging operators to join a freight quality scheme. However, these are either expected by the draft London Plan or already accounted for in the modelling, and additional measures are required to make the scheme acceptable in air quality terms. A proposal of this type and scale should seek to drive improvements and be future-proofed for expected changes in the transport fleet and electric vehicle charging provision should therefore be improved. The use of zero emission vehicles for onward (last-mile) deliveries must be increased or, ideally, made a condition of operation for all vans using the site. The use of river transport for inward freight movements should also be considered. As discussed under ‘transport’ below, reductions in the level of staff car parking are also required. Once the applicant has reviewed these aspects of the proposals, further analysis of the potential impacts on Aberfeldy Village and other receptors is required, including a future year with the Silvertown Tunnel in operation.
32 Notwithstanding this, the proposals will facilitate ‘last mile’ deliveries of goods to consumers, consolidating goods into fewer vehicles in a location close to central London and the northern Isle of Dogs, as supported by draft London Plan Policy E4. In doing so, this will help to re-locate traffic from parts of London’s wider highways network to a more sustainable location nearer to the centre of demand, with potential congestion and air quality benefits.
33 The applicant’s external lighting strategy is a consideration due to nearby residential use and the DLR, particularly due to the proximity of the proposed neighbouring L&Q development. The strategy identifies that the North Woolwich Road elevation will be subtly lit at night to accentuate the structure, without causing glare or disturbance to adjacent properties and the DLR, and with no floodlighting. Any illuminated building signage will be subject to additional planning approval.
Safeguarded Wharf
34 The area of land to the south-west of the site is currently designated as a safeguarded wharf (known as Peruvian Wharf), owned by the Port of London Authority (PLA). The current wharves network dates from 2005, and the Mayor commissioned a Safeguarded Wharves Review, which published proposals for consultation until August 2018, and can therefore be given some weight. The Review recommends that Peruvian Wharf be retained as a safeguarded wharf. The Wharf has been vacant for some years; however, part has recently been developed for aggregates use, with a further part subject to a current planning application for waste transfer and associated works. The Wharf is part of a network of wharves along the Thames that are protected for use as wharves by a Safeguarding Direction issued by the Secretary of State for Housing, Communities and Local Government.
35 London Plan Policy 7.26 ‘Increasing the use of the Blue Ribbon Network for freight transport’ states that development proposals should protect safeguarded wharves; increase their use; and adjacent development should minimise conflicts and disturbance. Further support is provided by Policies 5.17 and 5.18 relating to waste, and 5.20 on aggregates. These policies are reflected in draft London Plan Policy SI15 (water transport), SI7 (waste), and SI10 (aggregates).
36 The proposals include a re-positioned wharf access road along the western edge of the site, accessed via a new junction off North Woolwich Road within the site’s northern corner.
page 7 This road will continue to be used predominantly for wharf-related traffic; however, it will also provide a vehicular access for staff vehicles and emergency access to the application site. The re-positioned road has been designed in consultation with the Port of London Authority and the Council’s Transport and Highways Officers, and allows safe and secure access into the safeguarded wharf. The proposed use is compatible with wharf-related uses on the adjacent site and no potential conflicts are expected.
Urban design
37 This proposed building is innovative in design and well-conceived, having benefitted from extensive engagement with Newham Council’s Design Review Panel, as well as Council and GLA officers.
38 The GLA, Newham Council and TfL have aspirations for North Woolwich Road to develop as an active streetscape, with a series of key public nodes, interactive street frontages, and well- designed streetscape. Together with neighbouring development, the proposed building elevation on North Woolwich Road provides an opportunity to help define it as a street, as opposed to a traffic corridor. The location of the entrance to the building and the neighbouring cafe space are expressed by a lightweight geometric cladding structure, which provides a focal point to the most prominent elevation and is supported.
39 The approach to celebrate the circulation ramp in the external elevations is supported. The function of the building dictates its bulky mass; however, the elevations and materials have been kept simple, with muted colour gradations of blue. The height of approximately 36 metres is slightly greater than the adjacent Tate and Lyle main building, but less than recent and forthcoming residential schemes along the DLR. The applicant’s visual impact assessment includes an analysis of five key views, as agreed with Newham Council officers, and raises no concerns. The success of the architecture will very much depend on the quality of its materiality and detailing, which should be rigorously secured.
Transport
40 Vehicular access to the employee car park is proposed via the private wharf access road off North Woolwich Road, and access to the long-stay cycle parking is via a shared 3 metre wide footway/cycleway alongside this private road. These arrangements are supported.
41 A new roundabout on North Woolwich Road is proposed, serving as the main access for commercial vehicles; however, its design needs further work to achieve a more pedestrian and cycle friendly environment, in keeping with the Mayor’s Healthy Streets and Vision Zero objectives. This is particularly the case considering that it will provide access to the adjacent residential-led mixed-use development subject to a current planning application by L&Q (Ref: GLA/4924/01; LPA Ref: 19/01791/FUL). The applicant should provide further information on the possibility of future proofing to enable vehicular access from the roundabout to the Tate and Lyle site, enabling its access to be relocated away from Knights Road in response to the residential nature of the Council’s site allocations along Knights Road. The roundabout would be secured via a section 278 agreement between the applicant and Newham Council, along with a contribution towards the Council’s scheme for an active streetscape and key public spaces on North Woolwich Road. These include improvements at West Silvertown Station, comprising an enlarged public space and a new zebra crossing on a raised table, which will also provide a better aligned and more convenient route between the Station and the site.
42 A total of 255 employee car parking spaces (including 11 Blue Badge spaces) are proposed, which equates to 1 per 159 sq.m. of floorspace. This does not accord with the draft
page 8 London Plan, which requires employee parking at industrial and related uses to ‘have regard’ to the office parking standards. Policy T6.2 (Table 10.4) requires ‘car-free’ office development, except for disabled, in inner London, although the policy can allow for a degree of flexibility (up or down) to be applied to reflect different trip-generating characteristics of B2 and B8 developments. As the site is within the Royal Docks and Beckton Riverside Opportunity Area, any parking provision made should reflect the transformative level of planned housing and employment growth and improvements to walking and cycling environments and public transport services, including buses, DLR and the Elizabeth Line. Excessive car parking would undermine the achievement of mode shift targets in the Mayor’s Transport Strategy, Vision Zero objectives, and draft London Plan policies promoting active travel and use of public transport. It would also exacerbate concerns about the pedestrian and cycle friendly environment of the proposed roundabout. Employee parking spaces should therefore be reduced. As discussed above, this would also help to reduce air quality impacts.
43 Operational vehicles related to industrial and related uses also contribute to impacts on the road network, vision zero, bus services and local walking and cycling environments, and further justification is therefore required for the 69 parking spaces for commercial vans. The required Parking Design and Management Plan must set out how these spaces will be prohibited from being used for staff car parking. No dedicated parking is provided for larger commercial vehicles; however, temporary parking is available at 73 docking points across three levels, capable of accommodating 66 heavy goods vehicles (HGVs) and 7 vans.
44 It is proposed that 20% of all parking spaces would have active electric vehicle charging points, with passive provision for the remainder. This is in line with draft London Plan minimum standards; however, as discussed above, a proposal of this type and scale should seek to drive improvements and be future-proofed for expected changes in the transport fleet. Provision should therefore be improved, and secured by condition, along with disabled car parking.
45 A total of 140 long-term cycle spaces are proposed, with 10 for visitor use. Whilst these meet the numerical requirements of the draft London Plan, showers, lockers and changing rooms must be provided in line with London Cycling Design Standards. Cycle parking and facilities should be secured by condition.
46 A revised trip assignment and highway impact assessment for future-year 2026 is required, taking account of the Silvertown Tunnel, before it can be determined if the proposal would have a significant impact on the strategic highway network. Further consideration and justification is also required for some route assignments, which indicate low use of the access to the TLRN and a nil HGV peak-hour assumption.
47 The Transport Assessment states that Newham Council will impose a requirement to prevent HGV traffic from the site from turning left from the site onto North Woolwich Road, and instead using Silvertown Way (A1201). However, the mechanism for enforcing this is yet to be confirmed, and in the absence of physical measures to secure this seems unachievable. There is also concern that HGVs will be more likely to route via Canning Town to go east or north, as opposed to the more indirect route via the Lower Lea Crossing and Leamouth Road suggested in the application. There are no significant impacts expected on public transport capacity.
48 A Construction Logistics Plan (CLP) and provisions for DLR infrastructure protection will need to be secured by condition. Given other development in the area, the CLP will need to include co-ordination arrangements to ensure management of cumulative impacts. A Delivery and Service Plan should be secured by condition and should particularly consider the management and routing of HGV’s. The application is accompanied by a Framework Travel
page 9 Plan, which is welcomed, and should be secured, monitored and reviewed through the section 106 agreement.
49 The development will be liable to Mayoral Community Infrastructure Levy 2 (MCIL2), as well as Borough CIL. The MCIL2 rate for the London Borough of Newham is £25 per square metre of floorspace.
Climate change and urban greening
50 Based on the energy assessment submitted, compared to a 2013 Building Regulations compliant development, an on-site reduction equivalent to an overall saving of 35% of carbon dioxide per year in regulated emissions is expected. The proposed energy strategy is generally supported; however, the applicant should submit additional information before the proposals can be considered acceptable in accordance with Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan, and the carbon dioxide savings verified.
51 The approach to flood risk management for the proposed development complies with London Plan Policy 5.12 and draft London Plan Policy SI.12.
52 The surface water drainage strategy does not yet 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. Further details should be provided on how sustainable drainage system (SuDS) measures at the top of the drainage hierarchy will be included. Additional attenuation storage volume calculations and attenuation tank dimensions should also be provided.
53 The proposal does not yet meet the requirements of London Plan Policy 5.15 and draft London Plan Policy SI.5, as it does not meet the water consumption targets of these policies, which requires amendment.
54 The application should embed urban greening as a fundamental element of the proposals, in line with London Plan Policy 5.10 and draft London Plan Policies G1 and G5. The Applicant should calculate the proposed development’s Urban Greening Factor, as set out in Policy G5 of the draft London Plan.
55 Full details on all climate change and urban greening requirements have been provided to the applicant and the Council.
Local planning authority’s position
56 Newham Council officers engaged in pre-application discussions with the applicant; however, a Committee date has not yet been set. Legal considerations
57 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.
page 10 58 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
59 There are no financial considerations at this stage. Conclusion
60 London Plan and draft London Plan policies on Opportunity Areas; Strategic Industrial Land; agent of change; air quality; safeguarded wharves; urban design; transport; and climate change and urban greening are relevant to this application. The application does not yet comply with the London Plan and the draft London Plan, for the reasons set out below; however, the possible remedies stated could address these deficiencies: • Principle of development: The proposal for a three storey storage and distribution ‘last mile logistics’ warehouse on a SIL site within an Opportunity Area that has been vacant for 20 years, in close proximity to central London and the northern Isle of Dogs, is strongly supported in line with the London Plan, draft London Plan, and the Site Allocation; however, this is subject to the resolution of air quality issues and appropriate mitigation. • Air Quality: The applicant must consider how emissions can be further reduced, including maximising the use of zero emission onward deliveries, a reduction in staff car parking, and the use of river transport for inward freight movements. • Urban design: The proposed building is innovative in design and well-conceived. • Transport: Employee car parking should be reduced, and Blue Badge provision increased. A revised trip assignment and highway impact assessment is required taking account of the Silvertown Tunnel. Further work on the design of the proposed access roundabout is required to achieve a more pedestrian and cycle friendly environment. • Climate change: Further information has been requested on the energy strategy, the surface water drainage strategy, water consumption, and urban greening.
for further information, contact the GLA Planning Team: Juliemma McLoughlin, Chief Planner 020 7983 4271 email [email protected] John Finlayson, Head of Development Management 020 7084 2632 email [email protected] Allison Flight, Deputy Head of Development Management 020 7084 2820 email [email protected] Lyndon Fothergill, Team Leader, Development Management 020 7983 4512 email [email protected] Martin Jones, Principal Strategic Planner, Case Officer 020 7983 6567 email [email protected]
page 11