P7490
ROYAL WHARF PLOT 14B, LONDON ROYAL WHARF PLOT
E16 E16 PLANNING STATEMENT
May
2021 www.rolfe-judd.co.uk P7490
On behalf of Oxley Wharf Property 4 14B, LONDON ROYAL WHARF PLOT
Royal Wharf Plot 14b
E16 E16 Planning Statement
PLANNING STATEMENT
RJP: P7490
May
May 2021 2021
www.rolfe-judd.co.uk
Contents
Introduction 1
Summary 1
Planning Statement 1
Supporting Application Documents 2
The Application Site and Surrounding Area 4
Site Description & Location 4
Surrounding Area 4
Relevant Planning History 5
The Royal Wharf Masterplan 6
Pre-Application Consultation 7
The Proposal 9
Relevant Planning Policies 10
Summary 10
Government Guidance 10
The London Plan 11
Draft New London Plan (Intend to Publish Version December 2019) 12
LB of Newham Local Plan 2018 13
Planning Considerations 15
Principle of Development 15
Design, Layout and Massing 16
Housing Mix 18
Affordable Housing 19
Density 20
Quality of Residential Accommodation 20
Open Space Provision 21
Impact on Amenity of Adjoining Properties 22
Transport and Accessibility 24
Servicing and Refuse 25
Planning Statement i Sustainability and Energy 25
Environmental Considerations 26
Planning Obligations and Community Infrastructure Levy (CIL) 28
Statement of Community Involvement 30
Introduction 30
Policy Framework 30
The Consultation Process 31
Consultation Area and Recipients 31
Feedback from Consultation 32
Summary & Conclusions 33
Conclusion 34
Planning Statement ii
Introduction
Summary
Rolfe Judd Planning on behalf of Oxley Wharf Property 4 (‘the applicant’) has prepared this planning statement. It is submitted in support of an application for full planning permission to the London Borough of Newham (‘the Council’) for the redevelopment of the site at Plot 14b, Royal Wharf, London, E16, which will henceforth be referred to as "the site".
The site, which is 0.3 hectares in size, is located within the wider Royal Wharf site (formerly Minoco Wharf), which was recently completed and circa 90% occupied. The overall Royal Wharf site is situated in the Royal Docks / Silvertown area of the London Borough of Newham (LBN). The site is bounded to the north by North Woolwich Road and to the west by Deanston Wharf. The River Thames forms the site's southern boundary with the Thames Barrier 100 metres to the east. Barrier Point Road and the residential development known as Barrier Point lie to the east.
Plot 14b is located in the central area of Royal Wharf. The application comprises a circa 0.3 hectare area shown as Plot 14b within the proposed amended Masterplan 2015 for Royal Wharf.
For the purpose of the planning application the proposed development is described as follows:
Demolition of existing site and construction of a new building formed of 2 blocks of 11 and 7 storeys in height providing new 116 residential units; 444sqm GIA of non-residential floorspace (class E); car parking spaces (including blue badge spaces); bicycle parking spaces and hard and soft landscaping works including integration into the wider Royal Wharf site.
The above development of Plot 14b provides an exciting opportunity to create a vibrant new residential-led mixed-use development, which completes the final piece in the centre of the Royal Wharf Masterplan. It will deliver new much needed homes (including affordable homes) and a substantial improvement to public realm by completing the high street frontage within the centre of the Masterplan.
Careful consideration of the new Newham Local Plan, pre-application feedback and a thorough site analysis has resulted in a high quality design for the site that will integrate and be sympathetic to the surrounding land uses. The scheme proposes high quality residential and commercial space and has been designed to integrate fully into the wider Masterplan for Royal Wharf.
Planning Statement
The purpose of this statement is to examine the planning issues raised by the current development proposals for the application site. In particular, this statement identifies and describes the key opportunities presented by the proposed redevelopment of what is a vacant industrial offering for a sustainable mixed-use development.
Planning Statement 1
The statement also provides a comprehensive analysis of the relevant planning policy framework at national, strategic and local levels. As such, our planning statement is structured as follows:
Section 1: Introduction Section 2: The Application Site and Surrounding Area - sets the context the current proposal and provides a detailed description of the application site and its previous uses; Section 3: The Proposal - provides a full description of the proposed development; Section 4: Planning Policy Context - summarises the planning policy relevant to this proposal at national, strategic and local levels; Section 5: Relevant Planning Considerations - reviews the proposal in terms of the relevant policy context and other material considerations; and Section 6: Conclusion
Supporting Application Documents
This planning statement should be read in conjunction with the following additional documents, which accompany the application:
• Architectural Drawings (Floorplans, Elevations and Sections) – prepared by Glenn Howells Architects;
• Landscaping Drawings – prepared by Townsend Landscape Architects
• Design & Access Statement – prepared by Glenn Howells Architects
• Site Location Plan – prepared by Glenn Howells Architects;
• Planning Statement including the Statement of Community Involvement – prepared by Rolfe Judd Planning;
• Financial Viability Statement – prepared by Gerald Eve
• Draft Construction Environmental Management Plan - prepared by TPP Consulting
• Air Quality Report – prepared by AECOM
• Acoustic Assessment – prepared by AECOM
• Delivery and Servicing Plan - prepared by TPP Consulting
• Travel Plan - prepared by TPP Consulting
• Transport Assessment - prepared by TPP Consulting
• Flood Risk Assessment – prepared by AECOM
• Archaeological Desk Based Assessment
Planning Statement 2
• Ecology and Arboricultural reports – prepared by AECOM
• Sustainability Report – prepared by In2 Consulting
• Energy Statement – prepared by In2 Consulting
• Internal and External Daylight Report – prepared by EB7
Planning Statement 3
The Application Site and Surrounding Area
Site Description & Location
The 0.3 hectare Plot 14b site is located within the administrative boundary of the London Borough of Newham (LBN) and forms part of the 'Strategic Site 'S22'' in the Newham Core Strategy - where a substantial new residential-led development is supported in order to create a new neighbourhood at West Silvertown. This strategic allocation has already seen the emergence of the adjoining Royal Wharf development, which was recently completed and is circa 90% occupied.
The site is square and shares a development parcel with Plot 14a. The site is broadly flat and ties into the surrounding levels of the wider Royal Wharf site having already been remediated and cleared. The site has been cleared however is currently occupied by modular offices and welfare units for the wider Royal Wharf Development.
As discussed above Plot 14b is located within the wider Royal Wharf Masterplan site. The overall Royal Wharf site is situated in the Royal Docks / Silvertown area of the London Borough of Newham (LBN). It is bounded to the north by North Woolwich Road and to the west by Deanston Wharf. The River Thames forms the site's southern boundary with the Thames Barrier 100 metres to the east. Barrier Point Road and the residential development known as Barrier Point lie to the east.
The Royal Wharf site covers an area of approximately (17.23 hectares) and formerly comprised three wharves namely Venesta, Crescent and Minoco Wharves (west to east), none of which have the status of being a safeguarded wharf. The site is not located in a Conservation Area and there are no listed buildings on, site. A listed war Memorial is located to the east of Plot 14b within the central park. The War memorial, formerly located on North Woolwich Road, was relocated to its current location as part of the regeneration of Royal Wharf.
The site is within an archaeological priority area but is within the lowest tier of sensitivity. The River Thames, which is to the south of Plot 14b, is designated as a Metropolitan Site of Importance for Nature Conservation (SINC). According to the Environment Agency's flood zone maps, the site is located in Flood Zone 3 (Defended), and is at high risk of flooding from fluvial or tidal sources.
The Plot, which is the subject of this Application, relates to the central area of Royal Wharf. The application comprises a circa 0.3 hectare area shown 14a within the proposed amended Masterplan 2015. The plot is bound by Plot 14a immediately to the south, Plot 13 to the west and Plot 23 (the school) to the north across the main high street. To the east is Plot 12, which also frames the northern edge of the central park.
Surrounding Area
The surrounding area is characterised by a mix of residential, industrial and commercial uses. The area is historically industrial but is changing with the development of Royal Wharf (3,385 new homes) and Barrier Point to the east of the site. The approved, but yet to be constructed, Silvertown Quays development will also
Planning Statement 4
substantially transform the local built environment. Deanston Wharf to the west of the site forming a link between Royal Wharf and Lyle Park has also been consented with construction works having started on site in February 2021 due for completion in November 2024.
The West Silvertown DLR station is located c. 400m to the west of the site, and the DLR viaduct runs parallel to North Woolwich Road directly in front of the site. Based on Transport for London's (TfL's) Public Transport Accessibility Level (PTAL) ratings the site is given a PTAL rating of 2/3 with four bus stops and two Docklands Light Railway (DLR) stations within walking distance of the site. A Thames Clipper pier recently opened within the Royal Wharf Development which provides peak services to Central London.
On the opposite side of North Woolwich Road are predominantly 2-3 storey residential dwellings, and beyond this is the ExCeL London precinct. Approximately 800m upstream (west) from the site is the Thames Barrier with Royal Victoria Dock and London City approximately 240m and 1km south west of the site respectively.
Relevant Planning History
As discussed above Plot 14b is located within the Wider Royal Development. This scheme is formed of a hybrid planning permission which was granted by LB Newham and London Thames Gateway Development Corporation (LTGDC) in March 2012 (application ref: 11/00856/OUT and 11/00844/LTGOUT) for the residential-led mixed use redevelopment of the industrial lands at Royal Wharf site (former Minoco Wharf, Crescent Wharf and Venesta Wharf). The description of this development is set out below:
“Outline planning permission for comprehensive mixed use redevelopment of the whole site for up to 363,000 sq. m (GEA), comprising: Retail (Use Class A1) not exceeding 3,250 sq. m (GEA); Financial and professional services (Use Class A2) not exceeding 750 sq. m (GEA); Restaurants and cafes (Use Class A3), Drinking establishments (Use Class A4) and Hot food takeaways (Use Class A5) not exceeding 1,500 sq. m (GEA); Business (Use Classes B1 (a), (b) and (c)) not exceeding 15,000 sq. m (GEA), of which not more than 5,000 sq. m (GEA) will be offices (B1 (a)); Residential (Use Class C3) up to 329,900 sq. m (GEA) and not exceeding 3,385 residential units; Non-residential institutions (Use Class D1) not exceeding 9,600 sq. m (GEA); Assembly and leisure (Use Class D2) not exceeding 3,000 sq. m (GEA); together with: Demolition of all existing buildings; Vehicular, cycle and pedestrian access from North Woolwich Road; Public realm, public open space and private amenity space; Covered parking areas, plant, storage and an Energy Centre (not exceeding 68,550 sq. m); On street parking; Landscaping; River wall works; and, Other supporting infrastructure works and facilities.
Approval in respect of land on the eastern part of the application site, shown on drawing DPA-00-001 Rev P1 dated Jan 2011, labelled as “detailed area”, approval of ‘Scale’, ‘Appearance’, ‘Landscape’, ‘Layout’ and ‘Access’ (as defined by Article (2) (1) of the Town and Country Planning (Development Procedure (England)) Order 2010 (“DMPO”)) in respect of development consisting of 95,026 sq. m GEA and comprising the following elements: 811 residential units (Use Class C3) (88,744 sq. m (GEA)); 3,957 sq. m (GEA)
Planning Statement 5
of mixed use floorspace (Use Classes A1, A2, A3, A4, A5, B1, C3, D1 and D2); 290 sq. m (GEA) (Use Class B1(a); 2,035 sq. m (GEA) of ancillary plant and storage (above basement); and Associated highway infrastructure, river wall and public realm works, together with plant, storage and parking.”
811 residential units and 3,706 sq. m of commercial uses were granted detailed planning permission within Phase 1 with the remaining elements being subject to approval of reserved matters for scale, appearance and landscaping in line with the approved parameter plans.
A revised decision notice was issued in September 2014 (Council ref: 14/01007/VAR) following the approval of a number of minor material amendments to the Phase 1 detailed area of the scheme under Section 73 of the Town and Country Planning Act 1990 (as amended). A further section 73 application (Council ref: 14/01734/VAR), which amended the approved parameter plans to align with the emerging reserved matters for plots within Phase 2, was granted planning permission on 17th December 2014.
The latest Section 73 application (Council ref: 15/00577/VAR), which was subject to an approval on 15th December 2015, varies the planning permission to accommodate amendments to the approved outline parameter plans as they relate to Phase 3 of the development. This is now the relevant planning permission for the wider Master Plan development.
Detailed consent for the outline area has now been achieved for all plots. The site is now circa 90% occupied with all plots completed.
While Plot 14b did form part of the overall masterplan due to land assembly issues it could not come forward with the wider regeneration proposals. Unfortunately as the Royal Wharf permission maximum parameters have now been achieved a new standalone application is required for Plot 14b to come forward.
The Royal Wharf Masterplan
The Royal Wharf Masterplan is a design document led by Glenn Howells Architects in conjunction with Ballymore and Oxley to redevelop the sites of Venesta, Crescent and Minoco Wharves now known as Royal Wharf. It was formalised through a planning application in 2012.
The Masterplan sets out that Royal Wharf will be an exemplary landmark development. In addition to the masterplan vision as a whole, it also encompasses an urban design strategy. Together they aspire to realise the full potential of this one-off combination, entailing a large site in single ownership next to the River Thames, with Views to the Thames Barrier, Canary Wharf and the Millennium Dome; to be an attractive place in Newham to live, work and play.
The masterplan seeks the careful integration of well-designed high quality residential buildings, alongside business workspace, local retail and a wide range of diverse community uses. A desire to create special places summarises the team’s approach for Royal Wharf. The masterplan aspires to create neighbourhoods where work, leisure and home life all come together. The proposed concept focuses on family living and places shaped
Planning Statement 6
by building edges to make a high quality residential setting protected from the scale and hustle of neighbouring roads and public transport routes.
The sensitive deployment of materials and landscape is used enhance the sense of place and allow attractive private outdoor spaces, creating a place where people feel they can belong within a wider contextual setting framed by famous London landmarks and city parks. The masterplan proposals also aim to build upon and engage with existing and future designs for neighbouring sites; while also generating a successful individual and site-specific urban strategy.
The masterplan through the approved hybrid planning application sets out a series of parameters that all development must adhere. These parameters while only formally binding on the hybrid application apply in principle across the masterplan area and are written to help shape any future development that comes forward in the area. It is these principles which Plot 14b seeks to comply with.
Pre-Application Consultation
The applicant committed to undertaking a comprehensive pre-application process to ensure that the local community including the current residents at Royal Wharf and LB Newham were given sufficient opportunity to fully engage in and contribute to the evolution of a new scheme design for the site. This has been carried out in accordance with national and regional policies and meets the requirements of the LB Newham’s Statement of Community Involvement (as amended in 2015).
The details of this extensive programme of consultation and engagement are set out in a Statement of Community Involvement, which is covered in Chapter 6 of this statement. The following section outlines a brief overview the consultation process.
Consultation with LB Newham
Members of the project team first met with LB Newham’s Design Review Panel (DRP) and planning officers in November 2019 to discuss the principles of the initial design proposals. This initial feedback established an acceptable way forward in terms of the massing approach and appearance with additional work required on the layout and relationship to plot 14a.
Further design work on the evolving scheme design has been undertaken since the DRP. A further presentation was scheduled to present the evolution of the design to officers and the DRP Panel members.
The above period of consultation has provided helpful guidance on how to progress the scheme design and has resulted in a number of significant amendments. Such amendments include a change in approach to the service access to the south as well as the introduction of more active frontage at the lower levels of the building to maximise active frontage on to the public realm.
Consultation with the Local Community
As part of the public consultation process, presentations were made to individual Councillors and a public exhibition was held on December 2019 to inform the local community of the proposals at that time.
Planning Statement 7
The exhibition was publicised through the distribution of a newsletter to all residents who reside on site with confirmation that a dedicated website and information line were also available for people to submit comments. The exhibition was attended by circa 40 local residents with queries relating primarily to the level of car parking provision, local highway improvements and the potential impact on local transport infrastructure.
It is submitted that the level of consultation has been considerable and has enabled the applicant to establish the key areas of concerns. It is therefore considered that the proposals have, as far as possible, accommodated and responded positively to a number of concerns raised by local stakeholders. It is intended that further meetings will be held with community stakeholders and politicians if required up until a decision is made by the LB Newham Strategic Planning Applications Committee.
Planning Statement 8
The Proposal
The overarching objective of the proposal is to clear the existing the site and provide a residential-led mixed use development that will deliver high quality residential accommodation and contribute significantly to the already positive transformation of the local built environment delivered through Royal Wharf with further improvements to public realm, open space, permeability and legibility.
The new development will comprise one singular building ranging in height from 7 storeys to 11 storeys. The scheme will consist of the following elements:
• 116 residential apartments (20 x studios, 18 x 1 beds, 56 x 2 beds and 22 x 3 beds)
• 20 of these units (17%) are proposed as affordable (3 x 1 beds, 11 x 2 beds and 6 x 3 beds) with a 60:40 rented: intermediate mix;
• 444 sq. m GIA of mixed use commercial floorspace (Use Class E to be provided within separate units across the building
• A small servicing street containing set up and pick up for the waste and refuse generated by the development as well as 14 car parking (of which 4 are blue badge) surrounding the development.
The scheme will provide for a range of open spaces including a new public accessible open space on the northern portion of the site (to integrate with the existing high street), a new private pedestrian route running east to west on the southern boundary of the site, a large podium courtyard framed by the buildings and balconies/terraces for each residential dwelling.
The scheme will fully integrate with the wider Royal Wharf Masterplan and be publically accessible with the exception of the service route to the south and the podium courtyard, which only are for residents of both tenures.
Meanwhile all residential units will be well insulated and sealed, with Mechanical Ventilation Heat Recovery (MVHR) to recover waste heat. The commercial units will also be well insulated with heating and built to shell and core with capped services.
Planning Statement 9
Relevant Planning Policies
Summary
This section sets out the overarching planning policy framework and development plan documents against which the application scheme has been assessed.
In accordance with Section 38 (6) of the Planning and Compulsory Purchase Act (2004), planning applications should be determined in accordance with the Development Plan unless material considerations indicate otherwise. The adopted Development plan documents relevant to the Application Ste are as follows:
• The London Plan (as modified) (2016)
• The Newham Local Plan (2018)
For the purpose of emerging policy it is clearly set out within Paragraph 48 the National Planning Policy Framework (NPPF, February 2019) that local authorities may give weight to relevant policies in the emerging plans according to a) the stage of preparation of the emerging plan (the more advanced its preparation, the greater the weight that may be given); b) the extent to which there are unresolved objections to relevant policies (the less significant the unresolved objections, the greater the weight that may be given); and c) the degree of consistency of the relevant policies in the emerging plan to this Framework (the closer the policies in the emerging plan are to the policies in the in the NPPF, the greater the weight that may be given).
The following emerging planning policy and guidance have also been given consideration.
• The draft New London Plan (Intend to Publish Dec. 2019)
Government Guidance
The Government adopted a new National Planning Policy Framework (July 2018) with additional amendments published in February 2019.
The NPPF has a presumption in favour of sustainable development (Paragraph 11). It requires that, in assessing and determining development proposals, local planning authorities should apply the presumption in favour of sustainable development. This means that development that is sustainable should be approved immediately.
The Application Scheme has been designed in accordance with the principles set out within the NPPF, and represents sustainable development that utilises an existing site which is currently underutilised. The NPPF recognises that sustainable development should support the three overarching objectives of the economy, society and the environment. These objectives give rise to the need for the planning system to perform a number of roles, which are mutually dependent and should not be undertaken in isolation:
Planning Statement 10
The relevant NPPF Paragraphs and Policy are referred to within the following Relevant Planning Considerations Section (Chapter 5).
The London Plan
The policies and guidance within the London Plan is consistent with both national and local objectives in terms of the need to promote sustainable forms of development. The following sections and policy numbers of the London Plan are considered to be relevant to the determination of the proposed scheme
• Policy 3.3 Increasing Housing Supply;
• Policy 3.4 Optimising Housing Potential;
• Policy 3.5 Quality and Design of Housing Developments;
• Policy 3.6 – Children and young people’s play and informal recreation facilities;
• Policy 3.8 Housing Choice;
• Policy 3.11 Affordable Housing Targets;
• Policy 3.12 Negotiating affordable housing on individual private residential and mixed use schemes;
• Policy 3.13 Affordable housing thresholds;
• Policy 4.3 Mixed use development and offices;
• Policy 5.3 Sustainable design and construction;
• Policy 5.9-5.15 – Climate Change adaptation;
Planning Statement 11
• Policy 6.3 Assessing effects of development on transport capacity;
• Policy 6.9 Cycling;
• Policy 6.10 Walking;
• Policy 6.13 Parking;
• Policy 7.1 Lifetime neighbourhoods;
• Policy 7.2 An inclusive environment;
• Policy 7.3 Designing out crime;
• Policy 7.4 Local Character;
• Policy 7.5 Public Realm;
• Policy 7.6 Architecture;
• Policy 7.7 Location and Design of Tall and Large Buildings;
• Policy 7.14 – Improving Air Quality; and
• Policy 7.15 – Reducing and managing noise, improving and enhancing the acoustic environment and promoting appropriate soundscapes
The London Plan also allocates the Royal Docks and Beckton Waterfront area as an opportunity area with significant capacity to accommodate new housing, commercial and other development linked to existing or potential improvements to public transport accessibility.
Draft New London Plan (Intend to Publish Version December 2019)
The London Plan is the statutory Spatial Development Strategy for Greater London prepared by the Mayor of London (“the Mayor”) in accordance with the Greater London Authority Act 1999 (as amended) (“the GLA Act”) and associated regulations.
The London Plan (2016) is undergoing a programme of review. The latest version of the Draft London Plan (July 2019) contains minor changes arising from Examination in Public (EIP). In accordance with Section 338(3) of the GLA Act, the Secretary of State appointed a Panel to conduct an examination in public (“EIP”) of the London Plan. The EIP took place from January to May 2019 and has now ended. Since then the Inspectors report for the EIP has been published and minor amendments have been made to the Plan. The GLA issued its Intension to publish the new London Plan in December 2019. While not forming part of the adopted development plan, in accordance with paragraph 48 of the NPPF, the Draft New London Plan should be given significant weight based on its stage of preparation (the more advanced the preparation, the greater the weight that may be given).
Planning Statement 12
In occasions where the wording of policies within the Draft London Plan has remained consistent at each stage of review, notably following the EIP review, it is anticipated that these policies are likely to be adopted as currently worded and as such, these policies can be viewed as material considerations at this stage of the Draft London Plan review process. The planning assessment of the Proposed Development, and the development of the Application, has therefore been undertaken against and in accordance with the adopted London Plan and Draft London Plan policies.
The following list outlines the key policies within the Draft New London Plan:
• GG5: Good Growth
• SD1: Opportunity Areas
• D1 Good design and good planning
• D4 Quality of Design
• D4 (f) Daylight and Sunlight
• D7 Public Realm
• D8 High density Development
• D12 Agent of Change
• H1 Housing Targets
• H5 Delivering more genuinely affordable housing
• SI12 Current and expected flood risk
• T1 Sustainable Transport
• T6 Car-free development
LB of Newham Local Plan 2018
The following sections and policy numbers of the London Plan are considered to be relevant to the determination of the proposed scheme are set out below:
• S3 Royal Docks
• SP1 Borough-wide Place-making
• SP2 Healthy Neighbourhoods
Planning Statement 13
• SP3 Quality Urban Design within Places
• SP4 Tall Buildings
• SP8 Ensuring Neighbourly Development
• H1 Building Sustainable Mixed Communities
• H2 Affordable Housing
• SC1 Environmental Resilience
• SC2 Energy and Zero Carbon
• SC3 Flood Risk and Drainage
• SC4 Biodiversity
• SC5 Air Quality
• INF2 Sustainable Transport
• INF3 Waste and Recycling
• INF7 Open Space and Outdoor Recreation
Appendix 1 Strategic Site Allocations of the Local Plan identifies the site as falling within the designated ‘Minoco Wharf Strategic Site 22’ stating that this site will be released from the designation of a Strategic Industrial Location (SIL). Policy S3 of the Local Plan allocates the wider S22 site to:
“…A new local centre should address North Woolwich Road providing a focus to the new neighbourhood as a whole and provide connections to both DLR stations, and pedestrian and cycle links to Silvertown Quays. Development should include pedestrian and cycle access to river. Indicative building heights of 10 to 12 storeys and up to 18 storeys at key locations.”
Planning Statement 14
Planning Considerations
Principle of Development
The site was previously hardstanding associated with an industrial/warehouse building (Use Class B2/B8) within the wider Royal Wharf Site. The site is used as modular offices and site welfare buildings associated with the construction of the wider masterplan. This planning application seeks to clear the existing buildings to facilitate the residential-led mixed-use redevelopment of the site.
The site is identified as being within the Royal Docks & Beckton Waterfront Opportunity Area where both the London Plan (March 2015) and New London Plan (2019) promote the comprehensive regeneration of the area. The current London Plan identifies the area for the delivery of 11,000 new homes alongside a new enterprise zone (delivering 6,000 jobs). The new London Plan goes much further stating that 30,000 new homes and 41,500 new jobs should be delivered.
More specifically within Newham policy, the site forms part of the designated ‘Minoco Wharf Strategic Site 22’. Policy S3 of the Core Strategy states that the ‘Royal Docks will become a unique and high quality waterfront urban quarter; today’s fragmented residential development will become consolidated into a number of distinct neighbourhoods’ and approximately 8,404 new dwellings will be developed, the majority of which will come forward on the Strategic Sites. The designation for Site S22 states that:
The release of land designated as a Strategic Industrial Location (SIL) at Thameside West up to the eastern boundary of Lyle Park, and west of Lyle Park adjacent to North Woolwich Road (18 ha), will assist in the development of a new neighbourhood at West Silvertown. A new local centre should address North Woolwich Road providing a focus to the new neighbourhood as a whole and provide connections to both DLR stations, and pedestrian and cycle links to Silvertown Quays. Development should include pedestrian and cycle access to the river.
The majority of the S22 area already has consent for the Royal Wharf and Deanston Wharf developments and much of this development is already under construction or occupied. The application site is situated within the Royal Wharf development and provides an important opportunity to link in with and finalise the Royal Wharf Site.
The proposal provides a high quality residential-led mixed-use development that will finalise the Royal Wharf development and combined with Deanston Wharf seek to complete the intent of S22. This also complies with Paragraph 117 of the NPPF, which promotes mixed-use developments and identifies the need for plan making and decision taking to “promote an effective use of land in meeting the need for homes and other uses”.
The 116 new residential units on the site will contribute to meeting the target for new dwellings in the Royal Docks area of opportunity (as outlined in Policy S3) as well as the minimum annual average housing target of 2,800 new homes for Newham as identified in the Newham Local Plan. The proposed commercial uses at
Planning Statement 15
ground floor level will also generate important activity to the northern edge of the scheme, which completes the high street within the development.
The redevelopment of the site presents the opportunity to replace poor quality previously developed land with a high quality mixed use development in an emerging mixed use precinct. The proposal is consistent with the intent for the NPPF and Strategic Site S22 as outlined in Policy S3 and will contribute to achieving the Council and GLA housing targets.
The proposed ground floor and upper floor uses are wholly in accordance with the parameter plans and intent of the wider Royal Wharf Masterplan. The proposed uses will fit seamlessly in with the surrounding plots and continue the excellent variety consented within the development.
Based on the above the principle of bringing forward a residential led mixed-use scheme at this site to deliver high quality housing is considered acceptable in principle and in accordance with the local, strategic and national policies.
Design, Layout and Massing
The National Planning Policy Framework promotes high quality and inclusive design as one of the key components of sustainable development while London Plan Policy 3.5 and New London Plan Policy D4 state that housing development should be of the highest quality internally, externally and in relation to their context and the wider environment. Furthermore, both documents outline that buildings should be of the highest architectural quality and should activate and appropriately define the public realm. It states that new buildings should complement the local architectural character, not cause unacceptable harm to the amenity of surrounding land and buildings, particularly residential buildings, provide for climate change mitigation and adaptation and optimise the potential of sites.
At a local level, Policy SP3 of the Core Strategy states that development should create a high quality urban environment that respects and enhances its townscape context and heritage assets, including the borough's conservation areas.
Layout, Height and Massing
The concept of the layout for the site is driven by the approved Royal Wharf Masterplan, which seeks to deliver one singular building formed of two separate blocks joined at lower floors. The Application scheme seeks to build on this approach adopting the principle of one singular building however redefining the orientation of both the western and eastern element to face East west. This approach seeks to replicate the already consented and built approach within Plot 14a and provides higher quality accommodation removing any single aspect north facing units.
At lower levels, the layout of the scheme remains as per the approved parameter plan with commercial floorspace facing the approved high street, active frontages on the eastern and western boundaries and a small service area on the southern boundary facing a similar approach within Plot 14a.
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London Plan Policy 7.7, New London Plan Policy D8 and Policy SP4 of the Newham Core Strategy state that larger scale buildings should be of the highest quality design and in particular, be suited to the wider context in terms of their relationship with other buildings, streets and public and private spaces and contribute positively to the skyline. Policy SP4 of the Core Strategy states that locations on Strategic Sites within both the Arc of Opportunity and Urban Newham are regarded as suitable locations in principle for tall buildings with scale reflecting place hierarchy.
The proposed site is located in close proximity to a high volume transport node (being a DLR station), and is within a Strategic Site (S22) and the Arc of Opportunity. The local built environment has rapidly transformed because of comprehensive local regeneration that includes a much larger scale within Royal Wharf, Deanston Wharf to the west, the approved Silvertown Quays development to the north and the completed 1 Knight’s Road scheme with other substantial developments proposed for other brownfield sites in the area.
To be acceptable, any new tall building should be in an appropriate location, should be of first-class design quality in its own right and should enhance the qualities of its immediate location and setting. As demonstrated in the accompanying Design and Access Statement by Glenn Howells Architects, the architecture of the proposed scheme is intended to be of a high quality, appropriate to its context and responds to the requirements as set out in the London Plan and New London Plan.
In addition, within the submitted Design and Access Statement Glenn Howells architects have provided a series of views of the scheme within the immediate context. Given the scale of the wider Royal Wharf development and the location of the plot, it is considered that while the plot may feature in wider views it will not be intrusive and will sit within the context of the already built surrounding buildings.
The layout, massing and height were broadly supported by LB Newham planning officers during pre-application discussions. The design for the site is supported place-making policies which seek to secure a well-connected and integrated series of successful and distinctive places.
Further to this, the proposal provides for a high quality of accommodation (see section 5.6 below), including family accommodation, provides a contribution to the quality of public realm and open space in the area and incorporates high standards of sustainability and energy reducing measures as outlined in the Sustainability and Energy Statement. As demonstrated by the accompanying reports the proposed building heights will not have an adverse impact on the local environment in terms of key considerations such as overlooking, loss of privacy, air quality and noise and wind.
Building Design
High quality architecture is proposed in accordance with Paragraph 124 of the NPPF, Policy 7.6 of the London Plan and Policy D4 of the New London Plan, with the design having regard emerging and built context within Royal Wharf to ensure the proposal will positively contribute to the area in accordance with Policy SP3 of the Local Plan.
Overall, it is considered that the building design throughout the scheme is of a very high quality and will continue to contribute to the high quality built form already consented as part of the Royal Wharf Masterplan. The
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overarching aim for Royal Wharf was to create a neighbourhood of exceptional buildings complemented by a smaller number of maker buildings. Plot 14b is designated as being part of the mansion typology and the proposed design adopts this approach complementing the aesthetics of Plot 14a to the South.
The materiality, massing and positioning of the proposed development present a strong-shared aesthetic with the wider Royal Wharf site and continue precedent for high quality development in this emerging part of Strategic Area S22 to complement the wider area, which is well underway.
Landscaping and Public Realm
London Plan Policy 7.5 (Public Realm) and Policy D4 of the New London Plan establish design principles for public realm within new developments, encouraging public spaces that are secure, accessible, inclusive, connected, easy to understand and maintain, relate to local context and incorporate the highest quality design, landscaping, planting, street furniture and surfaces.
Policy SP3 (Quality Urban Design within Places) recognises the importance of successful public realm in place making. Policy SP3 encourages “the desirability of making the public realm attractive as a social meeting place to be enjoyed by the whole community, and of creating a sense of safety and security and helping to prevent crime and antisocial behaviour inside and outside buildings and in public spaces”.
A landscape strategy has been produced by Townsend Landscape Associates and is included within the Design and Access Statement which is submitted in support of the planning application. The proposed development will incorporate a number of landscaped spaces and routes to ensure safe access throughout the site.
• The Northern High Street – New landscaping is proposed to the north of the scheme to complete the high street facing the school. This landscaping will be typical of the Royal Wharf development providing generous pavement widths design to encourage commercial spill out onto the street. Formalised green landscaping is also proposed to soften the perception of the space.
• Central Courtyard – A centralised podium communal garden is proposed to provide residents with semi private space. The courtyard is split into two distinct themes designed to provide formalised areas as well as a more relaxed and flexible area. The courtyard will also include the primary doorstop and local playspace for the residents.
• Integration with wider Approved Masterplan – Plot 14b is designed to integrate with the wider Royal Wharf Masterplan and on all common boundaries the landscaping fits seamlessly into the already constructed scheme.
The landscape design is considered to be of a high quality and will provide an important contribution to the enhancement of the local public realm in accordance with the requirements of London Plan Policy 7.5, New London Plan D4 and Newham Local Plan Policy SP3.
Housing Mix
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National planning policy contained in the NPPF requires new development to deliver sustainable, inclusive and mixed communities in accessible locations. To achieve mixed communities, the NPPF advises that a variety of housing should be provided in terms of size, type, tenure, price, and a mix of different households such as families with children, single-person households, people with disabilities, service families and older people.
London Plan Policy 3.8 and New London Plan Policy H10 require new development to offer a range of housing sizes and types. Policy H1 of the Newham Local Plan replicates this approach stating that sites should comprise a mixture of housing sizes and / or types or tenure.
The application scheme provides for a total of 116 residential units which are broken down as follows:
Unit Number % Split Number % Split Number % Split Total % Split Type of of of of of Social of Social Units of all Private Private Intermed Intermed Units Units tenures Units iate iate Units Units
Studio 20 20% 0 0 20 17%
1 Bed 15 16% 1 12.5% 2 16% 18 16%
2 Bed 45 39% 5 62.5% 6 50% 56 48%
3 Bed 16 17% 2 25% 4 34% 22 19%
Total 96 8 12 116
The proposed scheme incorporates a mix of dwelling types and sizes with 19% of the total units as family sized. This approach is in line with the approved target for the Royal Wharf Development and that broadly consented within the Strategic Site of Minoco (S22). The approach has been determined as the preferable mix to enable the scheme to remain viable.
Overall, given the site's location and the market demand, viability considerations and the proposed mix is considered appropriate in this case.
Affordable Housing
Current London Plan policy 3.11 states that housing schemes should maximise affordable housing provision and within that, the London wide objective of 60% of the affordable housing provision should be for social rent and 40% intermediate rent or sale. Policy H4 of the draft New London Plan requires major developments which trigger affordable housing requirements to provide affordable housing through the threshold approach. Policy H5 states that for development on former public land a viability assessment is required for any scheme proposing less than 50% affordable housing by habitable room.
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Policy H2 of the Core Strategy seeks for all new developments with a capacity for 10 units or more to provide between 50% of units as affordable housing. This approach is subject to mix and tenure considerations such as the need to secure quality mixed and balanced communities, scheme viability, the existing mix of housing in the area, and the individual circumstances of the site in terms of site conditions, local context and site features.
Paragraph 76 of the NPPF acknowledges planning policies should not threaten the viability of a development or its ability to come forward. A Viability Assessment has therefore been undertaken by Gerland Eve to assess the scheme’s economic viability. This has identified that the scheme can viable provide for 17% affordable housing (based on residential units) with a rented to Intermediate split of 60:40
Although it is recognised that the proposed development is below the policy target for affordable housing provision this is considered appropriate given the high percentage of social rented units and the high remediation and other construction costs associated with the redevelopment of what has been a long-standing industrial landholding.
Density
Policy H1 of Newham’s Local Plan supported by the London Plan and the NPPF expects housing densities to reflect local context and character and be appropriate in relation to the provision of open space and transport requirements.
The New London Plan moves away from mechanistically reviewing the propose density of a scheme and instead seeks to consider the quality of the accommodation within the development. Through the approach of the Royal Wharf scheme, it is acknowledged by the GLA and LB Newham officers that the setting is changing in this opportunity area.
Many of the recently consented developments in the surrounding area have the characteristics of a central setting and will improve the infrastructure and amenities available to future residents. An example of this is where TTP have calculated in their Transport Assessment that with the completion of Royal Wharf and the river service the PTAL for the site will increase to 4.
As identified in this report, the proposal is a high quality development that complies with all of GLA requirements. An exemplary design is proposed including quality residential units and amenity space, and the massing and height of the building has been designed in consideration of nearby residential properties. Pre-application discussions have been undertaken and a viability report is submitted which identifies the maximum affordable housing provision that can be provided whilst still ensuring that the project remains viable. The proposed density is therefore considered appropriate for this particular site.
Quality of Residential Accommodation
London Plan Policy D6 (Housing quality and standards) states that housing developments should be of the highest quality internally, externally and in relation to their context and to the wider environment. The policy sets out a series of design criteria that proposed housing should be designed to. The policy also identifies that
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Housing development should provide adequately-sized rooms with comfortable and functional layouts which are fit for purpose and meet the needs of Londoners without differentiating between tenures. This is reiterated in Policy H1 of the Council’s Local Plan.
The proposed unit sizes all comply with the minimum space standards identified in Table 3.1 of the New London Plan and are therefore considered acceptable. The proposed residential dwellings have been designed in accordance with the standards set out within the latest buildings regulations with 10% of units being wheelchair accessible (M4 (3)) and the remaining 90% of units being in accordance with the requirements of Building Regulation M4 (2). The submitted Design and Access Statement details how the residential units will comply with these requirements.
The design of the buildings seeks to create high quality residential accommodation and the majority of units enjoy favourable views and multiple aspects towards attractive amenities such as Minoco Park, the River Thames and new podium spaces within the development itself. Due to the predominantly east-west facing orientation of the buildings, there are no single aspect north facing units within the scheme. The internal daylight and sunlight report prepared by EB7 confirms that the proposed units enjoy excellent compliance rates that is commonplace for the Royal Wharf Development and reflects the layout and design of the masterplan. This conclusion is further enhanced by the fact that each unit will have access to external amenity space in the form of private balconies, ground floor terraces and public and communal open space.
Communal cores within the buildings have natural light and ventilation and the number of units per core does not exceed eight. The submitted energy strategy for the scheme also confirms how the development will achieve a 45% improvement over the 2017 Building Regulation standards. The development plans to connect into the Royal Wharf Energy Centre located within Plot 01 of the development and will meet the CO2 reduction target of Policy SI2 of the London Plan and Policy SC2 of the LB Newham Local Plan.
A comprehensive survey of environmental noise levels associated with road, rail and air transport and the nearby safeguarded industrial wharves has been undertaken by Aecom. The assessment concludes that mitigation measures can be incorporated into the scheme design to ensure that an appropriate internal noise environment is achieved within the residential apartments. The detail of these noise mitigation measures will be agreed with the Council through appropriate conditions.
Both the layout of the development and the arrangement of the individual residential units have been carefully considered to ensure an efficient use of space and the creation of a well-conceived living environment. The design of the new residential accommodation is compliant with the housing quality standards set out in the draft New London Plan and the Councils Local Plan.
Open Space Provision
Public and Communal Open Space
The New London Plan and Newham Local Plan require all dwellings to be accompanied by adequate private open space (i.e. outdoor amenity area). The guidance sets a minimum space requirement of 5 sq. m per 1-2
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person dwelling with an extra 1 sq. m for each additional occupant. This requirement will be met through the provision of private balconies and podium level gardens.
A new podium garden is provided for all residents of Plot 14b and will be accessed controlled to ensure that the residents are provided with a level of semi-private space beyond the balconies and terraces. This semi-private space is supported by the ample green and open spaces provided within the wider Royal Wharf Masterplan.
Minoco Park, the River Thames Walkway and Lyle park are all within short walking distance of the site and will provide the residents of the Plot 14b with an excellent and varied selection of green and open spaces to complement the amenity already provided with the block.
These open spaces and other associated public realm improvements are considered to represent high quality planning gain on a site that previously had little interaction with the surrounding public realm. It will help to mitigate the impact of the new population and contribute to the delivery of an improved network of open spaces in this area.
In terms of amenity space quality, the enclosed Daylight and Sunlight basement by EB7 identified that the sunlight (overshadowing) within the proposed areas of shared amenity space have shown deviations from the BRE targets due to the dense nature of the surrounding context. Additional technical analysis considering the hours with direct sunlight however shows that the vast majority of the proposed amenity spaces would experience at least c.1.6 hours of direct sunlight and as such, marginally below the suggested targets.
The BRE guidelines allow a degree of flexibility when applying the BRE criteria and given the nature of the surrounding context together with the minor nature of the deviations, the results should be considered in line with the BRE criteria.
Play Space
Policy S4 of the New London Plan (Play and Informal Recreation) states that housing developments should make provision for play and informal recreation space based upon the expected child population to be generated by the scheme. This approach is replicated by Policy SP2 of the Newham Local Plan.
As set out in the submitted Design and Access Statement, a total of 435.1 sq. m of designated play space is proposed within the scheme. This play space will be integrated into the podium courtyard, so that children and adults can share and benefit from the same spaces.
In accordance with the Masterplan, approach for Royal Wharf play for older ages (12+) is provided within the larger parks and open spaces within the development such as Minoco Park. Further to this substantial provision, there is also an abundance of high quality accessible off-site play space in the form of the immediately adjoining Lyle Park and Thames Barrier Park less than 10 minutes’ walk to the east.
Impact on Amenity of Adjoining Properties
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Policy D1 of the New London Plan identifies that the design of new developments and the spaces they create should help reinforce the character and accessibility of the neighbourhood. Policy D3 follows this approach by requiring development to enhance local context by delivering buildings and spaces that positively respond to local distinctiveness through their layout, orientation, scale, appearance and shape, with due regard to existing and emerging street hierarchy, building types, forms and proportions.
Policies S6, SP1, SP2 & SP3 of Newham’s Local Plan all echo the same principles in requiring a high quality of design and a development which responds well to local character and the established pattern of development yet does not detrimentally effect neighbouring amenity.
In the wider sense, the scheme proposals will allow for a number of significant improvements to the local built environment. At present, the existing site is vacant with an unattractive boundary treatment of fences, railings and walls presenting a dead and impenetrable frontage to the wider Royal Wharf development. In contrast the proposed development will provide additional linkage within the development and seek to complete the masterplan
The potential impact of the proposed development has also been assessed against the surrounding plots, notably Plots 12, 13, 14a and 23 (the school).
As discussed above the application is supported by a Daylight and Sunlight Assessment undertaken by EB7. Within this document assessments have been undertaken using the VSC, ADF (daylight) and APSH (sunlight) tests set out within the BRE guidance ‘Site layout planning for daylight and sunlight: A guide to good practice’ (2011).
It is important to reiterate that alterations in daylight and sunlight to adjoining properties are often inevitable when undertaking any meaningful development, especially in an urban environment. The BRE guide is meant to be interpreted flexibly because natural lighting is only one of many factors in site layout design. The site currently holds planning consent as part of the wider regeneration for the area and as such, this should be considered as one of many factors when applying the BRE criteria.
The results of the technical analysis have shown that, whilst there will be some reductions to individual rooms / windows, the amount of daylight received within each of the neighbouring habitable rooms will remain broadly in line what is expected for the location. This is confirmed by the comparison with the consented scenario where the overall effects generally present an improvement on the consented scenario, or are in the same order of magnitude. In addition, the results of the sunlight assessment to neighbouring properties shows little noticeable change from the consented position.
For detailed analysis please refer to the Daylight and Sunlight Assessment undertaken by EB7 and enclosed with this application.
The results are broadly in line with all plots within the Royal Wharf Masterplan and on balance it is considered that the proposed development will ensure a substantial improvement to the local public realm, open space and built environment that will significantly outweigh any potential impact on adjoining properties or open space. The
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proposed development is therefore considered to be in accordance with New London Plan Policy D6 and Policies S6, SP1, SP2 & SP3 of Newham’s Local Plan.
Transport and Accessibility
Chapter 9 of the NPPF seeks to promote sustainable transport. In doing so, it seeks to ensure that developments that generate significant movements are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. This is reflected in Policies T1, T2 and T3 of the New London Plan and Policy INF2 of the Newham Local Plan, which also seeks to ensure that the impacts of development proposals on transport capacity and the transport network are fully assessed.
The Transport Statement prepared by TPP Consultants provides a detailed review of the proposals and an assessment of the highway and transport aspects associated with the proposed development. The proposals have been discussed with the Newham Highways Officer during the pre-application process.
Trip Generation
The trip generation assessment undertaken as part of the Transport Assessment indicates that there will only be a marginal increase in vehicle trips because of the development due the low level of parking proposed. The commercial component is minor and delivery and servicing is already accommodated within the wider Royal Wharf Masterplan. The report determines that the anticipated level of trips is unlikely to have any effect on the operation of the local highway network and is likely to be within fluctuations that would occur on a daily basis.
West Silvertown station is the nearest Docklands Light Railway (DLR) station, located to the North West. One existing bus route is within 400m walk of the site, the 474, which runs along North Woolwich Road and a new bus route through Royal Wharf is proposed to open shortly. The site has a Public Transport Accessibility Level (PTAL) rating of three indicating average access to sustainable modes of transport. Adding in river services from North Woolwich Pier to this assessment increases the PTAL has the potential to increase further.
Overall, the proposal will not give rise to any additional transportation impacts or cause any harm to the character and function of the local area.
Car and Cycle Parking
Policy T6 of the New London Plan aims to achieve an appropriate balance between promoting new development and preventing excessive car parking provision. Maximum standards are set out in Table 6.2. The policy also requires that all spaces provide an electrical charging point, and sufficient provision is made for disabled people in terms of parking. Local Plan Policy INF2 (Sustainable Transport) states that development proposals should incorporate appropriate cycle and car parking standards as set out in the New London Plan.
The residential parking ratio within the scheme is proposed at 0.12 spaces per unit with 14 parking spaces being provided at ground floor underneath the Plot. Vehicular access to the site is via a small service road immediately to the south of the plot. Of the spaces, proposed 4 (3% of all units) will be suitable for use as accessible bays
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that meet the Borough’s planning policy. In addition, all spaces will have electric vehicle charging points as required by LBN and TfL.
The residents within Plot 14b will have access to the 10 car club bays already provided within the wider Royal Wharf Development.
235 cycle parking spaces are proposed within the scheme. This includes 207 spaces for residents and the remaining for the commercial units and visitors. This is in compliance the New London Plan standards.
The proposed development is considered to meet the transport aspirations of the London Borough of Newham and current Governmental guidance in respect of sustainable development and through its design will encourage the use of sustainable modes of transport.
Servicing and Refuse
The NPPF states that developments should be designed, where practical, to accommodate the efficient delivery of goods and supplies. This is reflected in Policy T7 of the New London Plan, which states that developments must provide for the needs of businesses for delivery and servicing.
A Delivery and Servicing Plan produced by Transport Planning Practice Ltd (TPP) for the Proposed Development, following consultation with the Council Highways and Waste officers, and has been submitted in support of the planning application. This strategy outlines the approach that will be adopted to manage the residential and commercial waste generated by the proposed development once operational and within the context of the established servicing at Royal Wharf.
In terms of residential waste storage, these will be stored at ground level with direct vehicle access. Commercial waste will be stored within each of the commercial tenant's leased area and collected would be arranged through waste contractors or coordinated through the site management office.
Refuse vehicles will enter the Royal Wharf estate roads from North Woolwich Road where servicing zones will be located off-street on the service access to the south of the plot. Residual waste and dry recyclable waste will each be collected from the proposed development on a weekly basis in accordance with the LBN's standard practices.
Sustainability and Energy
The NPPF seeks that development promotes the use of renewable energy where the technology is viable, economic, and where the social impacts can be addressed satisfactorily. Policies SI2 and SI3 of the London Plan states that development proposals should demonstrate that sustainable design standards are integral to the proposal and meet the minimum standards set out in the Policy.
Sustainability and Energy Statements have been prepared by In2 Engineers that identifies that the proposed scheme has been designed and specified in accordance with the relevant sustainability and energy policies from
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the New London Plan and will provide a good level of energy efficiency and sustainability for a development of this type and size.
Following the heat hierarchy, It is proposed that the development will connect into the existing Combined Heat and Power (CHP) plant at Royal Wharf. This will serve all proposed residential apartments and be supported by renewable energy from PV panels. The retail / commercial units of the Proposed Development will also be supported by these measures.
A BREEAM pre-assessment has been carried out to guide the design in terms of maximising the sustainability of the development. This pre-assessment shows the predicted rating of BREEAM Excellent.
Environmental Considerations
All relevant environmental considerations have been assessed within the Environmental Statement of Conformity prepared by Aecom and submitted with the planning application.
This Environmental Review has been prepared to support the detailed planning application for Plot 14b (the Proposed Development) and responds to a request from LBN to provide a summary of how the environmental effects associated with the proposed development of Plot 14b relate to the findings of the May 2011 Outline ES for the wider Royal Wharf development.
For the purposes of the Environmental Review, the Proposed Development has been appraised against the environmental topics which were considered in the May 2011 Outline ES in order to identify whether any new or additional significant effects would arise as a result of the Proposed Development. Consideration is given within this document as to how the Proposed Development compares to the parameters which have been consented for Plot 14 and were assessed in the May 2011 Outline ES as updated by the March 2015 ES Review. In addition, a review has been undertaken of the environmental mitigation measures identified previously as applicable to Plot 14b and whether any additional mitigation is required in light of the Proposed Development.
The Environmental Review draws on the findings of various technical studies that have been undertaken to support the detailed planning application. The following technical topics are covered in this Environmental Review:
• Air Quality;
• Archaeology and Built Heritage;
• Aviation;
• Daylight, Sunlight, Overshadowing, Light Pollution and Solar Glare;
• Ecology;
• Electronic Interference;
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• Ground Conditions;
• Noise and Vibration;
• Socio-economics;
• Sustainability;
• Traffic and Transportation;
• Water Resources;
• Waste; and
• Wind.
By way of summary, the principal conclusions on the key environmental issues are detailed below.
Noise
The application site is located in close proximity to noise generating activities such as North Woolwich Road, the DLR, London City Airport and a number of safeguarded wharves. Noise predictions indicate that suitable internal ambient noise levels can be achieved within the proposed development through the implementation of high specification acoustic glazing in accordance with Policy SP2 of the Local Plan. The detailed design will also be required to identify suitable additional mitigation to deal with low frequency noise generated by the safeguarded wharves on the opposite side of the river.
To ensure acceptable noise levels for outdoor amenity areas some of the balconies have been recessed into the façade to ensure protection from the proposed building fabric and the proposed balustrades. It is considered that this mitigation will provide the lowest noise levels practicable whilst retaining outdoor amenity space for residents.
Air Quality
An Air Quality Assessment has been undertaken as part of the Environmental Statement to assess the potential impact the proposed development could have on nearby residential receptors during both the construction and operational phases of the development.
Overall, the significance of the impacts of the proposed development is determined to be ‘negligible’, and following the adoption of recommended mitigation measures, the development is not considered to be contrary to any of the national, regional or local planning policies regarding air quality including Policy SP2 of the Local Plan which looks for development proposals to contribute to the improvement of Newham’s air quality.
Ecology / Biodiversity
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Policy SC4 of the Local Plan seeks to protect and enhance biodiversity in the borough and states that development should only be permitted where it can be demonstrated that significant adverse impacts on species and habitats can be avoided. Following the implementation of the Royal Wharf Consent the site has been cleared and previously housed the construction welfare for the development. The ecological potential of the site is limited and has been addressed through the proposed mitigation for the wider consent.
These wider measures include upgrades to the Thames river wall tidal terracing that hosts wintering bird species alongside a substantial number of green and brown roofs, and native plant specifies to support biodiversity.
Flood Risk
The subject site is located within Flood Zone 3(a) which has a high risk of experiencing flooding from fluvial/tidal sources. However, the site is protected by the River Thames Flood Defences for up to the 1 in 1000 year flood event which reduces it to a residual flood risk.
To minimise the potential flood risk for the residential use, the site level has been increased above the relevant flood zone to ensure the safety of residents. Upgrades to the wider River Wall have also been undertaken increasing its maximum height and ensuring it will last for the lifetime of the development.
Archaeology
An archaeology assessment has been prepared in accordance with the requirements of Local Plan Policy SP5. The site is located within an Archaeological Priority Area associated with the recognised potential of the Thames floodplain and does not contain any statutorily designated assets. The report identifies that no archaeological finds or features were recorded during the evaluation; however, Trenches 1 and 3 did help refine the geo- archaeological mapping of the natural gravels across the study area. Overall it is considered that the development is in accordance with Policy SP5.
Wind and Microclimate
A wind tunnel assessment has been carried out by RWDI Anemos. This has found that the wind environment within key areas such as thoroughfares, entrances and amenity areas within the scheme and within adjoining spaces such as Minoco Park would be acceptable for the intended use. It has been identified that the existing and proposed landscaping generally has a beneficial impact on the wind conditions and that wind conditions are generally calmer within the inclusion of cumulative surrounding schemes.
Contamination
The site has already been de-contaminated as part of the wider Royal Wharf Development. Further work will be required through the development process to ensure that the future residents are protected. This includes minimum build-up of clean topsoil on made ground. We expect the final detail of the assessment to be conditions by the Council.
Planning Obligations and Community Infrastructure Levy (CIL)
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Whilst the affordable (intermediate and social rented) units benefit from mandatory social housing relief from the Community Infrastructure Levy (CIL) payments, the open market units will have CIL charges of £80 per square metre and the commercial component will have a charge of £30 per square metre, as identified in the Council’s CIL Charging Schedule (2014). There will also be a GLA charge of £25 per square metre for the open market units and the commercial component.
Draft Heads of Terms for a s106 agreement will be prepared and agreed with the Council. These are likely to include the following items:
• Early and Late Stage Affordably Housing Review Clause
• Commitment to Car Free Development
• Carbon Offset Payment
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Statement of Community Involvement
Introduction
This Chapter encloses the Statement of Community Involvement (SCI) has been prepared by Rolfe Judd Planning.
This Statement of Community Involvement outlines the public consultation the Applicant has undertaken prior to the submission of the application, including consultation with local residents and ward councillors. This is considered to align with the Newham Statement of Community Involvement 2018.
Policy Framework
National Planning Policy Framework (2019)
The National Planning Policy Framework (NPPF) (2019) sets out the government objectives for community involvement that will produce the quality development needed to deliver sustainable developments. In particular, the NPPF outlines that:
Early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties. Good quality pre-application discussion enables better coordination between public and private resources and improved outcomes for the community (paragraph 39);
Local planning authorities have a key role to play in encouraging other parties to take maximum advantage of the pre-application stage. They cannot require that a developer engages with them before submitting a planning application, but they should encourage take-up of any pre-application services they offer. They should also, where they think this would be beneficial, encourage any applicants who are not already required to do so by law to engage with the local community and, where relevant, with statutory and non-statutory consultees, before submitting their applications (paragraph 40); and
The more issues that can be resolved at pre-application stage, including the need to deliver improvements in infrastructure and affordable housing, the greater the benefits. For their role in the planning system to be effective and positive, statutory planning consultees will need to take the same early, pro-active approach, and provide advice in a timely manner throughout the development process. This assists local planning authorities in issuing timely decisions, helping to ensure that applicants do not experience unnecessary delays and costs (paragraph 41).
Local Consultation Policy Requirements
The Newham Statement of Community Involvement (2018) encourages developers to inform Councillors and members of the public of any major applications before a planning application is submitted. Early engagement between applicants, the planning authority and local community about an emerging scheme demonstrates early,
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proactive and effective engagement with the community, which will be looked on more favourable than those that have not.
This Statement of Community Involvement has therefore been produced by the Applicant to assist in the consideration of the application and demonstrate the local engagement that has been undertaken prior to the submission of the planning application.
The Consultation Process
The Applicant has managed the pre-application consultation with the community and local stakeholders in conjunction with Rolfe Judd Planning. The aim of the consultation process was to ensure that neighbouring residents and interested parties who could potentially be impacted by the proposals were aware of the proposed development and provided with an opportunity to make comments prior to the formal submission.
This statement sets out below the consultation process to date.
Consultation Area and Recipients
On 27th Jan 2020, a covering email and leaflet providing an overview of the proposed scheme was distributed post to those residents and local businesses deemed to be most affected. The letter (see Appendix 2) included a brief overview of the proposed scheme and confirmed the proposed dates for a public exhibition to present the scheme.
The consultation area generally comprises all residential and commercial properties within the Royal Wharf Development. The list of proposed consultees, and the intended consultation area for the leaflet drop was agreed with the Council prior to the consultation period. It is considered that the consultation undertaken represents a sufficient scope in terms of consultation with the local community.
In addition to the leaflet and email, the following measures were also undertaken to ensure residents were aware of the proposals.
• Printed leaflets provided in the on-site concierge;
• Post on the Royal Wharf Community Website
• Communication with the Royal Wharf Residents Forum
Following the issue of the leaflet and covering email, public exhibition was held to present the scheme. The exhibition was held on Tuesday 28th January between 5 and 8pm and then again on Thursday 30th between 11am and 3pm.
Approximately 21 people attended the exhibition all of which were residents of the wider Royal Wharf scheme. The Exhibition was staffed by the design team including the client, architect and planning consultants.
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Residents were also given the opportunity to provide comments via email if this was more accessible for them.
Feedback from Consultation
Formal feedback forms were provided during the exhibition and comments were received via email. These comments focussed on a number of planning topics as well as other non-material aspects of the development and wider site.
The following table sets out the material comments received as well as the response from the design team in how the scheme has evolved to reflect them.
Issue identified during consultation Project team response feedback
Height of the buildings and daylight were raised It was explained by the applicant team on the of concern by the immediate neighbours in Plot day that Plot 14b has been developed in line 14a. with the masterplan for Royal Wharf and the proposals broadly align with the original intent for the site.
Notwithstanding this through the design and pre-app process, the application has been reduced in width and massing since the exhibition with the hope that this will assist with the impact on the adjacent properties.
A daylight and sunlight analysis by EB7 is included with this application and provides additional detail on the impacts.
Residents raised concerns regarding the While the comments regarding the leisure impact on local infrastructure most notably the centre are sympathised with it is not a material onsite leisure centre and DLR consideration for the application. Notwithstanding this separately away from the application process Ballymore is exploring options for improving capacity for the leisure provision.
The Transport Assessment prepared TPP analyses the impact of the development on the local transport network and concludes that the additional 116 residential units will not have an unacceptable impact on the wider transport network including the DLR.
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Additional modes of transport such as buses will also shortly be available from Royal Wharf as will Crossrail from Custom House that is a 15min walk away. Both of these improvements will assist in alleviating the pressure on the DLR.
Residents raised concerns regarding the The proposed scheme delivers a semi private provision of open space. communal open space within the centre of the proposal. This, alongside the private amenity space provides areas of seclusion and play for the residents.
Beyond the immediate private and semi-private spaces, the residents will have access to the wider Royal Wharf scheme including Minoco Park and the Thames Walkway both of which contain large and varied spaces designed to provide amenity to individuals and families.
Summary & Conclusions
The consultation sought to engage with local residents, businesses and key stakeholder groups prior to the formal application submission. The purpose was to:
• Explain and illustrate the nature and scope of the proposed scheme;
• Provide local residents with an opportunity to air any feedback and concerns; and
• Ascertain and understand local issues in order to ensure that the submitted proposals are better informed.
Overall, despite a considerable number of consultees, only a small number of responses were received within the time period allocated. These comments summarised in section 6.5 above were taken on board by the design team and in appropriate areas the scheme has been amended to reflect the issues raised.
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Conclusion
The proposal put forward by Oxley Wharf Properties 4 in this planning application represents an important opportunity to finalise the long-term aspects for the Royal Wharf Development delivering a key piece of the masterplan proposal with a sustainable form of development. The proposed regeneration is fully supported by local planning policy being located within the wider Royal Docks and Beckton Opportunity Area, Newham’s Arc of Opportunity and the Strategic Site 22.
The Site in its existing state is impermeable, vacant and a blight on the hugely successful wider masterplan. In contrast, the Proposed Development would redevelop the site with a coherent set of buildings, of a high architectural quality, and would provide a series of routes and spaces with distinctive characters in accordance with national, strategy and local policy. It will contribute significantly to the delivery of much needed high quality housing (including affordable housing) and open space within this part of the Borough. It has also been set out in this statement how the proposed development will have an acceptable, and in many cases beneficial, influence local residents with minimal impact in terms of amenity impact.
The proposed scheme incorporates a mix of dwelling types and sizes in accordance with Policy H1. The scheme achieves 19% of the total units as family sized. Whilst this is below the Council’s target of 39%, the maximum possible amount of family housing has been provided whilst enabling the scheme to remain viable and a significant proportion of the family dwellings have been provided as affordable housing in accordance with the priority identified in the Mayor’s Housing Strategy. The mix also reflects the wider approved provision within the Royal Wharf Masterplan, which sought to provide a balanced neighbourhood within the area.
A Financial Viability Report is submitted separately that confirms that an affordable housing provision of 17% can be provided whilst allowing the scheme to remain viable.
Fourteen car parking spaces of which 4 are blue badge spaces are at ground floor, equating to a provision of 0.12 spaces per residential apartment. The proposed spaces are slightly above the maximum standards however reflecting demand data for Royal Wharf especially in relation to three bedroom family housing. The proposed cycle parking provision is compliant with the minimum requirements identified under the New London Plan (2019).
The proposed planning application for the redevelopment of this site is considered consistent with the relevant planning policies set out within the New London Plan and the Newham Local Plan, and is wholly in keeping with the National Planning Policy Framework. It will provide a positive addition to the built environment in this location and should be granted planning permission.
Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that determination must be made in accordance with the development plan unless material considerations indicate otherwise. The Application is in accordance with both the adopted and emerging development plan and planning permission should be granted for this planning application.
Planning Statement 34