Arrowhead Quay Planning Statement

Transcription

1 Planning Statement For Arrowhead Commercial Ltd, part of the Ballymore Group December 2012

2 Report prepared by:

3 Contents CONTENTS 1. INTRODUCTION CONTEXT OF THE PROPOSALS THE PROPOSED DEVELOPMENT PLANNING POLICY FRAMEWORK PLANNING ASSESSMENT CONCLUSIONS Appendices Appendix 1 Accommodation Schedule December 2012 I gva.co.uk

4 1. INTRODUCTION 1.1 This Planning Statement has been prepared by GVA and is submitted in support of a full planning application made on behalf of Arrowhead Commercial Ltd (the Applicant), part of the Ballymore Group of Companies for the redevelopment of the site (the Site), Marsh Wall, London, E14. This statement demonstrates the planning case in support of the proposals in the context of relevant national, regional and local planning policy, and other best practice guidance. 1.2 Ballymore Group is an award winning international property development and investment company. It is one of the largest, privately owned companies specialising in high end residential and mixed use development, and is owned by the Mulryan family. Ballymore has a reputation for creativity, design and attention to detail on all aspects of a development. Ballymore is currently developing schemes at various locations including 21 Wapping Lane, Providence Tower and Leamouth Peninsula. With over 20,000 residential units in the development pipeline, Ballymore controls some of the most exciting regeneration opportunities in the capital including Bishopsgate Goodsyard in the City Fringe, Brentford High Street and Kensal Canalside in West London and over 70 acres of riverside development sites in the Royal Docks. 1.3 The Site was granted planning permission in 2003 and an amended application was approved in August 2007 for an office development of circa 79,000 sqm. There is a partly constructed concrete basement which relates to this latter permission and as such the permission has been lawfully implemented. 1.4 Due to recent changes in the economic climate however, the scheme was never fully built out. As will be explained later in this statement, planning policy has also changed since the grant of this permission which suggests the site would be better suited to an alternative use. As such, Ballymore are now pursuing a residential-led mixed-use scheme. 1.5 The proposals are for a full planning application for two towers of 50 and 55 storeys for residential-led mixed-use development with ancillary residential uses (residents gym and pool, cinema, business suite and residents lounge) and ground floor commercial uses (retail units and café). The proposals have been developed in consultation with Officers at the London Borough of Tower Hamlets and the Greater London Authority. December 2012 I gva.co.uk 1

5 Supporting Information 1.6 This Planning Statement should be read in conjunction with the accompanying plans and drawings submitted as part of the application, as well as the following documents: Design and Access Statement (Glenn Howells Architects); Environmental Statement (Environ); Transport Assessment (WSP); Sustainability Statement (Hoare Lea); Energy Statement (Hoare Lea); Ventilation/Extraction Statement (Hoare Lea); Utilities Statement (Hoare Lea); Waste Management Strategy (WSP); Statement of Community Involvement (Indigo Public Affairs); Employment Report (GVA). Community Engagement 1.7 The National Planning Policy Framework notes that pre-application discussions have the potential to improve the efficiency and effectiveness of the planning application system for all parties (para 188), going on to state that the more issues that can be resolved at the pre application stage, the greater the benefits (para 190). Planning authorities are asked to look for solutions rather than problems and decision takers are urged to approve applications for sustainable development where possible (para 187). 1.8 Prior to submission of this application, the development proposals have been subject to pre-application consultation with officers at the London Borough of Tower Hamlets (LBTH) including Pete Smith, Graham Harrington (Development Management), Sripriya Sudhakar (Urban Design), Carole Martin (Housing) and Rachel Yorke (Transport). The meetings have been used to agree a number of principles that are reflected in the planning application submission. December 2012 I gva.co.uk 2

6 1.9 The development proposals for the Site were also subject to consultation with Claire O Brien, Emma Williamson (Planning Decisions Unit) and Euan Mills (Urban Design) at the Greater London Authority and James Forrest at Transport for London The proposed development has evolved in form and appearance following the consultation process and this is addressed in the accompanying Design and Access Statement, prepared by Glenn Howells Architects A number of events have also been held with the local community and key stakeholders including a public exhibition which was held on 8 November 2012, a presentation to the Design Review Panel on 10 December 2012 as well as a presentation to the Strategic Development Committee on 13 December For further details of the consultation exercises undertaken and responses received please refer to the Statement of Community involvement, prepared by Indigo Public Affairs, which is submitted as part of this planning application package. December 2012 I gva.co.uk 3

7 2. CONTEXT OF THE PROPOSALS Site Location and Land Use Context 2.1 The application site comprises an area of approximately 0.55ha and is located on Marsh Wall, towards the north of the Isle of Dogs and to the south of Canary Wharf, within the London Borough of Tower Hamlets (LBTH). A site location plan is located at Figure 1, with the Site shown in red. Figure 1 Site Location Plan 2.2 The site is bounded by Marsh Wall to the south, the Britannia International Hotel to the west, the Docklands Light Railway (DLR) to the east and West India South Dock to the north. 2.3 The site is brownfield, having previously been occupied by industrial development, a car park providing surface parking for circa 250 vehicles and most recently, by the marketing suite and temporary offices for the construction of the Pan Peninsula development. All previous structures and hardstanding on-site have been demolished and the site is currently occupied by an excavated and secant pile retained basement cavity December 2012 I gva.co.uk 4

8 constructed in 2007 under extant consent (ref. PA/07/00347). Please see planning history section for further details. 2.4 The site has a PTAL (Public Transport Accessibility Level) of 5, which indicates very good accessibility to public transport. It is in close proximity to a number of public transport nodes. Established links are: The DLR at South Quay Station located approximately 220m east of the Site; The DLR at Heron Quays Station located to the north of West India South Dock; Canary Wharf Station on the Jubilee Line Extension, approximately 500m (7 minutes walk) from the Site; and Several bus services within approximately 300m (5 minutes walk) from the site. 2.5 Walking to and from the Site is also well provided for with footways bordering each side of the Marsh Wall carriageway and walkways bordering South Dock providing direct access to the Wilkinson Eyre Footbridge across to Canary Wharf and Heron Quays. In 2017, the Site will be within approximately 600m of a Crossrail Station (Canary Wharf). 2.6 There are no structures on the Site that are listed and the Site does not lie within a Conservation Area or an Archaeological Priority Area (APA) as designated within LBTH policy. 2.7 Further discussion on the site and its surroundings are set out in the Townscape and Visual Impact Assessment (Volume III of the Environmental Statement), as prepared by Miller Hare and Environ. Surrounding context 2.8 The wider setting of the Site has undergone major changes in the last 25 years following the closure of the docks. During this time the commercial centre at Canary Wharf has developed considerably. Development to the north of West India South Dock is now largely characterised by commercial use and tall buildings. However, to the south of the Dock, residential development has been dominant in recent years, with an increase in building height and taller buildings becoming more common. December 2012 I gva.co.uk 5

9 2.9 The Site is located within an area undergoing significant development. The Landmark (22-28 Marsh Wall), a residential development comprising two towers up to 44 storeys in height, is located to the west of the site and was completed in Pan Peninsula, a Ballymore development, is located south east of the Site and comprises two tall towers of 48 and 39 storeys. This was largely completed in The emerging cluster of taller buildings is further demonstrated through the approval of the following schemes: Full planning permission granted on 15 November 2010 for the erection of a 39 storey building with a three level basement comprising a 305 bedroom hotel and associated ancillary hotel facilities including restaurants and leisure facilities, conference facilities and serviced offices at 40 Marsh Wall. Full planning permission granted 27 October 2009 for the erection of a 62 storey tower including basements, comprising 430 residential apartments, 203 bed hotel and ancillary uses at the City Pride site Other sites within the vicinity of the Site which benefit from planning permission include: Hertsmere House; Newfoundland; Heron Quay West; Riverside South; Manilla Street; Wood Wharf; Baltimore Wharf, aka the former London Arena, Limeharbour; 1 Park Place; 82 West India Dock Road and 15 Salter Street, West India Dock Road; 25 Churchill Place; Former Indescon Court (Phase 2 site), 20 Millharbour; Glengall Bridge; December 2012 I gva.co.uk 6

10 35 North Aspen Way; and No. 1 South Quay Square There are a number of other development proposals in the vicinity that have been submitted to LBTH and are currently pending consideration. These schemes include: Cuba Street; Angel House; Site at Skylines Village, Limeharbour; and Former site at Guardian Press Centre, 2 Millharbour. Planning History 2.13 A planning application was previously submitted for an office proposal on the site (PA/07/00347) which was granted on 22 August 2007 and was an amendment to the previous office scheme granted planning permission in July 2003 (PA/04/00423). The originally consented scheme consisted of part 16 and part 26 storeys, with a height of +116m AOD. The 2007 scheme was part 16 and part 26 storeys, with a height of +119m AOD. This permission has been implemented with the part construction of the basement A full summary of the sites planning history is set out in Table 2.1 below. Table 2.1 Planning History Application Reference Development Proposal Decision Date PA/10/00280 Submission of details pursuant to Condition 23 (life of river wall) of planning permission ref: PA/07/00347, dated 22 August Permit Development 19/04/2010 PA/08/00014 Approval of details pursuant to Condition 22 (Access route to water course) of planning permission ref: PA/07/00347, dated 22 August Permit Development 12/03/2008 PA/07/02911 Submission of details pursuant to Condition 21 (renewable energy measures) of planning permission ref: PA/07/00347, Permit Development 11/01/2008 December 2012 I gva.co.uk 7

11 dated 22 August 2007 PA/07/02898 Submission of details pursuant to Condition 19 (water efficiency measures) of planning permission ref: PA/07/00347, dated 22 August 2007 Permit Development 05/11/2007 PA/07/02810 Submission of details pursuant to Condition 15 (site foundations) of planning permission ref: PA/07/00347, dated 22 August 2007 Permit Development 05/11/2007 PA/07/02646 Approval of details pursuant to Condition 16 (surface/foul water drainage) for planning permission ref: PA/07/00347, dated 22 August 2007 Permit Development 05/11/2007 PA/07/00347 Redevelopment of site to provide a 16 storey and 26 storey plus plant (119m AOD to top of plant) office building including retail/restaurant use on part of the ground floor and basement car park (79,244 sqm GEA), dockside walkway and landscaped plaza. Permit Development 22/08/2007 PA/06/02107 Redevelopment to provide a 16/25 storey office building (plus plant) including retail/restaurant use on part of the ground floor (59,250 sqm gross) plus car parking, dockside walkway and landscaped plaza without compliance with Condition 2 of Planning Permission PA/00/00423, dated 25 July 2003 Permit Development 08/02/2007 PA/07/00295 Approval of details pursuant to conditions 2H (car parking), 2K (waste disposal), 5 (archaeology), 6 (access), 11 and 12 (construction traffic), 13 and 14 (environmental management) of planning permission dated 08/02/2007. Permit Development 19/07/2007 PA/07/00947 Approval of details in accordance with Condition 10 (levels of ground borne vibration from any works or activities associated with the development shall not exceed 10mm/sec at any occupied building) of Planning Permission RN: PA/06/2107 dated 08/02/2007. Permit Development 12/06/2007 PA/00/00423 Redevelopment to provide a 16/25 storey office building (plus plant), including retail/restaurant use on part of the ground floor (59,250 sqm gross), plus car parking, dockside walkway and landscaped plaza. Permit Development 25/07/2003 December 2012 I gva.co.uk 8

12 3. THE PROPOSED DEVELOPMENT 3.1 Full details of the Proposed Development are provided in the accompanying Design and Access Statement prepared by Glenn Howells Architects. The key details of the proposals are summarised below. Description of Development 3.2 The planning application to which this Planning Statement refers seeks to optimise the development potential of the site by redeveloping the site as follows: Erection of two buildings of 55 and 50 storeys to provide 792 residential units (C3) and ancillary uses, plus ground floor retail uses (A1-4) (701 sqm), provision of ancillary amenity space, landscaping, public dockside walkway and pedestrian route, basement car park, servicing and a new vehicular access. Development Content 3.3 The finalised design proposes two slim towers of 50 storeys (172.4m AOD to top of plant screen) and 55 storeys (188.4m AOD to top of plant screen) in height, to provide a residential-led mixed-use scheme. The towers have been carefully designed so as not to appear as one single mass, however they will be linked at ground floor level with a double height, glazed lobby. The towers contain: Private and Intermediate residential units; Ancillary residential indoor and outdoor amenity space including podium level amenity space and sky garden, a gym/swimming pool, cinema, residents lounge, business suite; and Ground floor retail units and café. 3.4 The amenity space proposed at podium level (located at the second floor) provides both communal residential space as well as child playspace. A sky garden is proposed at level 53 of the east tower. Private balconies are provided for all residential units. Further amenity space is provided at ground floor in the form of a publicly accessible western garden. December 2012 I gva.co.uk 9

13 3.5 A breakdown of the main proposed land uses is set out in Table 3.1 below. 3.1 Proposed Land Uses Land Use Number of Units Gross Internal Area (sqm) Residential (C3) ,726 Ancillary residential uses at ground and first floor (gym, cinema, residents lounge, business suite) Retail/Cafe Units (A1-A4) Total , At ground level there are retail units and a cafe (which are publicly accessible), as well as the swimming pool, gym and a residents lounge, which are ancillary to the residential use. These provide ground floor animation and activity to both major frontages along Marsh Wall as well as to the dockside. 3.7 The first floor provides further ancillary residential uses, including a second floor to the gym, cinema and a business suite. There is also an upper floor to the cafe, which is accessible to the public. 3.8 A number of scenarios have been modelled to consider the tenure of the units to be provided on-site. A viability analysis has indicated that on-site provision of affordable housing fails to maximise provision and an off-site solution is therefore being promoted. As part of this, an element of affordable housing is to be retained on site. Accordingly, 42 intermediate residential units are included on the submitted plans within the west tower at levels 03 to 08. However, it has been agreed with officers that in order to ensure early delivery that the intermediate housing should be provided in the first building to be constructed and it is anticipated that this will be secured through a non-material amendment application at the appropriate time. Level 09 and above provides private units (with the exception of level 26 which contains mid-level plant), with penthouse accommodation at floors 48 and 49. The east tower comprises private units with penthouses located at the 53 rd and 54 th floors. There is a sky garden located at the top of the east tower, on the 53 rd floor. December 2012 I gva.co.uk 10

14 3.9 The development proposals aim to deliver a range and mix of unit A breakdown of the proposed residential mix is set out in Table 3.2 below. Table 3.2 Residential Mix Unit Type Private Tenure (No. Units) Intermediate (No. Units) Suite bed bed bed 3 6 Total The residential accommodation in the Proposed Development has been designed to meet, and where possible, exceed the Mayor of London s Housing Supplementary Planning Guidance standards, and the scheme aims to deliver accommodation of an exemplary quality. Planning and Regeneration Benefits 3.11 The proposal will provide a wide range of planning benefits for the Site and its surrounding area, as set out below: The scheme will deliver a significant number of high quality homes, which is the Borough s priority land use. The proposal will ultimately deliver a number of affordable homes to meet the Borough s identified need. The redevelopment of the Site will optimise the potential of a previously developed brownfield site and will contribute to ongoing improvement of the surrounding area. The Proposed Development will open up linkages from Marsh Wall to the dockside, creating a more pleasant and permeable urban environment. The environment under the DLR will be greatly improved and will encourage pedestrian movement through this area. December 2012 I gva.co.uk 11

15 The proposals will further enhance the public realm through the creation of a publicly accessible open space to the west of the site which will include planting, seating and child play space. The scheme will provide residential accommodation of an exemplary standard which will comply with and exceed the Mayor s residential unit size standards and will provide large and high quality amenity spaces and child play spaces. The Proposed Development will utilise sustainable and energy efficient building techniques and will combine this with renewable energy technologies to ensure that the development achieves a significant reduction in potential carbon dioxide emissions. Substantial section 106 financial contributions towards education, healthcare, local community facilities, the environment, public transport improvements and training and skills provision (taking account of previous contributions already paid in relation to extant permission PA/07/00347 which should be offset against any required contributions). December 2012 I gva.co.uk 12

16 4. PLANNING POLICY FRAMEWORK 4.1 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 other material considerations indicate otherwise. 4.2 The proposals for the redevelopment of must take account of relevant national, regional and local planning policy. This section of the Planning Statement sets out the relevant policies and demonstrates the support of the adopted and emerging policy framework for the proposals and identifies other material considerations. Adopted Planning Policy Framework 4.3 The National Planning Policy Framework (NPPF), published 27 March 2012, replaces most of the suite of Government guidance which existed previously as Planning Policy Guidance notes (PPGs) and Planning Policy Statements (PPSs), within a consolidated document. The NPPF provides the definition of sustainable development, which should be seen as a golden thread running through the planning system underpinning both plan-making and decision-taking. In doing so, it provides an overarching framework within which Local Planning Authorities are to prepare their policy documents. As such, it is an essential decision-making tool for local authorities. 4.4 At the regional level, the Mayor of London s London Plan (2011) forms the basis for planning policy. The Greater London Authority (GLA) has also published a range of Supplementary Planning Guidance notes (SPGs). These include the London View Management Framework SPG (2012), the Mayor s Shaping Neighbourhoods: Play and informal recreation SPG (2012), GLA s Housing SPG (2012), GLA s Housing Design Guide, GLA s SPG s on Accessible London: Achieving an Inclusive Environment (2004) and Sustainable Design and Construction (2006), as well as the Mayor s Air Quality Strategy (2010). 4.5 At the local level, the adopted Development Plan for LBTH comprises the Core Strategy (CS) adopted 2010, the retained policies of the LBTHs Unitary Development Plan (UDP) adopted 1998 and subsequently saved 2007, the retained policies of the Interim Planning Guidance Core Strategy and Development Control Plan (2007) and the retained policies of the Isle of Dogs Area Action Plan Interim Guidance (2007) (Isle of Dogs AAP). December 2012 I gva.co.uk 13

17 4.6 The Millennium Quarter Masterplan (MQMP), adopted 2000, sets out a policy framework which will help manage the implementation of significant development within the Millennium Quarter. Emerging Planning Policy Framework 4.7 In accordance with the Planning and Compulsory Purchase Act (2004), the UDP is being replaced by the Local Development Framework (LDF), a portfolio of documents which collectively deliver the spatial strategy for the London Borough of Tower Hamlets. 4.8 The final round of consultation on the Post Examination in Public version of the LBTH Managing Development DPD (MD DPD) published September 2012 has now finished and the Inspector s report has now been received by LBTH and is expected to be published before 21 December Once adopted, these policies will form part of the Local Development Framework (LDF) and are to be read in conjunction with the adopted Core Strategy (2010). They will replace the remaining saved policies of the UDP and the retained Interim Planning Guidance. While not yet adopted, this Post Examination in Public document is currently being used for development management purposes and is therefore a material consideration. On this basis, we assess the proposals against the relevant policies of this emerging policy in this planning statement. Site Specific Allocations 4.9 The principle of residential-led mixed-use development at is supported by both adopted and emerging planning policies. The London Plan identifies the Site as being located within the Isle of Dogs Opportunity Area. Opportunity Areas have been identified on the basis that they are capable of accommodating substantial new jobs or homes and their potential should be maximised. These areas generally include major brownfield sites with capacity for new development and places with potential for significant increases in density. The London Plan recognises that the Isle of Dogs contributes to London s world city role and recognises that activities here are interdependent with Central London. Therefore it requires development densities and mixed use policy to reflect this The LBTH Core Strategy identifies the Site as being within the Millwall planning area and notes that towards the north of Millwall there is an opportunity to provide local December 2012 I gva.co.uk 14

18 employment and new housing. Furthermore, in terms of housing, the Millwall area is identified as an area of Very High Growth The Isle of Dogs AAP (2007) identifies the Site as suitable for employment and leisure uses. However, this document has been largely superseded by the adopted Core Strategy and the emerging MD DPD which encourage mixed use, and residential development, in this area. Furthermore, an Employment Study undertaken by GVA, and which accompanies this application, confirms that the Site is no longer suitable for employment uses due to changing economic circumstances and limited demand for employment floorspace in this location Draft Policy DM1 of the MD DPD identifies the Site as within the Canary Wharf Activity Area where development proposals should be mixed use schemes with active uses at ground floor level with residential or office space on upper floors The MQMP also identifies the site as a focal point, and gateway linking Canary Wharf to the rest of the Isle of Dogs. The MQMP aims to encourage a mix of uses that will meet commercial and community needs in a 24-hour sustainable economy. December 2012 I gva.co.uk 15

19 5. PLANNING ASSESSMENT 5.1 This section of the Planning Statement assesses the proposals against both emerging and adopted national, regional and local planning policy as well as any other material considerations. 5.2 This section assesses the Proposed Development by a number of considerations, each of which is addressed by first detailing the relevant planning policy, then proceeding to assess the Proposed Development against the policy, before assessing any material considerations, where relevant, and forming conclusions. Overview of the Principle of Development / Land Use 5.3 Supporting and incentivising local sustainable growth and meeting people s housing aspirations by getting house building going again are key priorities for the Government 1. The Government wants more development in suitable and viable locations and has produced a shorter, more focused and inherently pro-growth National Planning Policy Framework (NPPF) to deliver this. The NPPF embodies the pro-growth principles set out in the Plan for Growth Ministerial Statement (March, 2011). 5.4 The Government continues to review the planning system for efficiencies to deliver sustainable economic growth and increase the rate of house building, most recently in an announcement by Rt Hon Eric Pickles MP in a Housing and Growth written Ministerial Statement dated 6 September It is clear from this Statement that the Coalition Government wants to get the economy growing, to remove unnecessary red tape and support locally led sustainable development. 5.5 At the heart of the NPPF is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decisiontaking (NPPF, paragraph 14). This approach to growth is reflected within the topic areas of the NPPF, specifically noting for housing that local planning authorities need to boost significantly the supply of housing (NPPF, paragraph 47). 1 Source: November 2012 December 2012 I gva.co.uk 16

20 5.6 To deliver this significant change, local planning authorities should approach decision taking in a positive way, looking for solutions rather than problems and seeking out the approval of applications for sustainable development where possible. In essence, the objective for local planning authorities is to secure developments that improve the economic, social and environmental conditions of an area (NPPF, paragraphs ). This means that development proposals that accord with the development plan should be approved without delay (NPPF, paragraph 14). 5.7 The Mayor s Vision for London set out in the adopted London Plan (LP, 2011) embraces two objectives, firstly that London must retain and build upon it s world city status as one of three business centres in the world, and secondly London must be a place where people and businesses want to locate (LP, foreword). 5.8 The London Plan is the Spatial Development Strategy for Greater London for the next years. London s population is projected to rise from 7.62m in 2011 to 8.57m in 2026 (LP, 1.10) and the LBTH is one of five London Boroughs that is projected to accommodate the greatest levels of growth (LP, Map 1.1). Indeed, the target of delivering 28,850 homes in the period up to 2021, accounting for 9% of the projected housing growth in the whole of London, is the highest housing provision target of all London Boroughs. LBTH is also projected to accommodate the greatest level of employment increase in the period up to 2031 compared to any other London Borough (LP, Table 1.1). 5.9 The NPPF encourages the re-use of previously developed land (paragraph, 111). Policy 1.1 of the London Plan reaffirms this position seeking to encourage growth within its boundaries, without encroaching into open spaces and having unacceptable environmental impacts, making the most sustainable and efficient use of space in the city. In the London Plan, East London is referenced as a particular priority at Policy 1.1, reflecting the anticipated high levels of housing and employment growth in an area that has a number of significant brownfield assets The Isle of Dogs is also designated as an Opportunity Area reflecting the population and employment growth expected in this area in accordance with Policy 2.13 of the London Plan which notes that residential output and densities should be optimised. The Opportunity Area designation recognises that outside of the Central Activities Zone and Major Centre location of Canary Wharf parts of the Isle of Dogs have significant potential to accommodate new homes. The Opportunity Area designation includes a minimum target provision of 10,000 new homes during the plan period. The Revised Early Minor December 2012 I gva.co.uk 17

21 Alterations to the London Plan (June, 2012) made no change to the emphasis of growth outlined above Recognising the regional importance of the LBTH for growth the LBTH s Core Strategy (2010) has a strategic objective to optimise the use of land. For the Isle of Dogs this is emphasised by the recognition that Canary Wharf is a key driver of London-wide growth. Like the NPPF and London Plan, sustainable economic growth is a strategic objective of the Core Strategy identifying the relationship between high quality housing and healthy environments with interrelated health benefits (Policies SO1 + SO3) The Core Strategy also reflects the housing target set by the London Plan, breaking down the Borough into spatial zones with five growth categories ranging from Zero to Very High growth. The Application Site falls within Millwall ward which is identified for Very High growth (Policy SO7). Once again this reflects the regional role of the Isle of Dogs The Government s central growth objective demands the approval of sustainable development without delay. This has been focused upon a spatial framework at a London-wide level which identifies key areas of growth and change. The Site falls within the Isle of Dogs Opportunity Area which is projected to be part of the greatest levels of population and employment growth in the whole of London. The Proposed Development optimises the potential of the Site and reflects the strategic objective of the Government, London s Mayor and the Borough. This clear and powerful policy message has been used to inform the development of the Proposed Development. The land use of residential-led mixed-use development wholly fulfils these policy objectives The applicant is seeking to optimise the development potential of the Site in accordance with the objectives of the London Plan and adopted and emerging LBTH policy. This is also in accordance with the principles of sustainable development set out in the NPPF which promotes sustainable development through the efficient use of land with high density, mixed use development and encourages the use of previously developed, vacant and underutilised sites to achieve national housing targets The remainder of this section breaks down the Proposed Development into issues of use, quantum, design and environmental issues that have shaped the detailed design. December 2012 I gva.co.uk 18

22 Housing 5.16 The national requirement for local planning authorities is to significantly boost the supply of housing. In addition, deliverability is a planning consideration that is addressed in the NPPF noting it as a key consideration against the appraisal of development viability (NPPF, paragraph 173) Policy 3.3 of the London Plan seeks to increase London s supply of housing and sets a housing provision target of at least an annual average of 32,210 net additional homes across London. More specifically however, the Isle of Dogs as an Opportunity Area, has a target of delivering a minimum of 10,000 homes for the period up to This is 35% of the minimum Borough-wide target of 28,850 new homes over the plan period Spatially, the LBTH has identified the Millwall ward (in which the Site is located) as a Very High growth area which has the highest housing target within the Borough. This position is also referenced at Strategic Policy SP02 of the Core Strategy which notes that Millwall is a location that will be the focus for the majority of new housing. The Site falls within the Canary Wharf Activity Area in the Core Strategy which has an objective to provide mixed use development that is complementary to the distinct designations of the CAZ and Canary Wharf major town centre (SP01). The emerging MD DPD supports this approach to the Canary Wharf Activity Area (DM1) which encourages mixed use schemes with active uses at ground floor level with residential or office space on upper floors The London-wide objective for the delivery of housing on the Site is clearly set out in planning policy. The provision of housing is also complementary to the projected growth in employment within the Canary Wharf Major Centre that has the highest projected growth rate in the whole of London. The delivery of a significant number of high quality homes on the Site will contribute significantly towards both London s and LBTH s housing targets and therefore accords with planning policy at all levels and the LBTH s priority land use In terms of deliverability, the Ballymore Group has a track record of housing delivery on the Isle of Dogs having developed out the Pan Peninsula, Baltimore Wharf and Phoenix Heights schemes. Other Ballymore developments within the London Borough of Tower Hamlets include New Providence Wharf, 21 Wapping Lane, and Leamouth North and South. December 2012 I gva.co.uk 19

23 5.21 In addition to housing, we address the other uses incorporated on the Site later in this section. Nevertheless the other elements fulfil the mixed use objective for the Canary Wharf Activity Area. Affordable Housing 5.22 Affordable housing is social rented, affordable rented and intermediate housing provided to eligible households whose needs are not met by the market (NPPF, Glossary). Where local planning authorities have identified a need for affordable housing they should: Set policies for meeting this need on site, unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified (for example to improve or make more effective use of the existing housing stock) and the agreed approach contributes to the objective of creating mixed and balanced communities. Such policies should be sufficiently flexible to take account of changing market conditions over time (NPPF, para 50) The NPPF includes guidance on ensuring that development that is sustainable is not threatened by policy burdens and obligations and can be delivered without delay. This approach to viability and deliverability is set out in paragraph 173 as follows: To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable This view is supported by the Royal Institution of Chartered Surveyors guidance note on Financial Viability in Planning (August 2012). The guidance note recognises a degree of knowledge and understanding is required of decision-makers as to the viability implications of all of the requirements placed on development. It is accepted that, in certain instances, financial planning obligations and other requirements may be necessary to mitigate against the impacts of a development and ensure it is acceptable in planning terms. However, the document advises that decision-makers should balance these mitigation measures against ensuring development is deliverable, having specific regard to scheme viability. December 2012 I gva.co.uk 20

24 5.25 The London Plan reflects the NPPF by setting an objective for local planning authorities to negotiate the maximum reasonable level of affordable housing subject to development viability (Policy 3.12) taking account of: Current and future affordable housing requirements Affordable housing targets The need to encourage rather than restrain development The need to promote mixed and balanced communities The size and type of affordable housing The specific site circumstances 5.26 An additional two assessment criteria are being suggested in the London Plan Revised Early Minor Alterations to take account of the resources available to fund affordable housing and the priority to be afforded to the provision of family housing The London Plan has a preference for the on site delivery of affordable housing noting that off site provision or a cash payment in lieu will only be acceptable in exceptional circumstances where it would be possible to: Secure a higher level of provision Better address priority needs, especially for affordable family housing Secure a more balanced community Better sustain strategically important clusters of economic activities 5.28 At the local level LBTH has a strategic target of 50% affordable housing calculated on a habitable room basis (SP02) by To achieve this target the Borough require between 35 50% on sites of 10 homes or more subject to viability testing. Building on this policy which is based upon viability the emerging MD DPD (Post Examination in Public draft, September 2012) includes a requirement for off site affordable housing to only be considered in circumstances where: It is not practicable to provide affordable housing on site December 2012 I gva.co.uk 21

25 To ensure mixed and balanced communities it does not result in too much of any one type of housing in one local area It can provide a minimum of 50% affordable housing It can provide a better outcome including a higher level of social rent family homes Residents on all sites benefit from the same level and quality of services 5.29 Both the LBTH and the London Plan planning policy also make reference to the delivery of family affordable housing which is a priority requirement. LBTH go on to note that they are seeking additional family housing for the social rented tenure against their Core Strategy policy target (SP02) for family homes which is 45% for the social rented tenure The applicant has engaged extensively with officers (both development control and housing) at LBTH as well as officers from the planning decisions unit at the GLA regarding possible affordable housing solutions for the Proposed Development. These discussions are ongoing. A viability toolkit has been prepared, and which accompanies this application, which demonstrates the quantum, of affordable housing that the scheme can afford and the submitted scheme assumes that an element of the intermediate accommodation (6.8% of the total habitable rooms) will be provided on-site with the balance to be provided off-site. The decision to provide a proportion of the affordable housing off-site has been taken in the context of the Borough s policy cascade, the objective to maximise the affordable housing contribution and deliver better outcomes in terms of both quantum and quality of units Further affordable housing provision in the form of an off-site or payment in lieu will be provided by the developer in line with LBTH policy, and are to be agreed with the Borough. Residential Mix and Layout 5.32 The NPPF seeks to deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities in the context of the presumption in favour of sustainable development. December 2012 I gva.co.uk 22

26 5.33 Taking account of the housing requirements of different groups, Policy 3.8 of the London Plan reiterates the importance of new development offering a range of housing choices; that is, housing size and type (taking into account the different housing requirement for different sectors) The Mayor of London s Housing SPG (2012) states that development proposals should seek to ensure they meet local needs by providing an adequate mix of dwelling sizes (in terms of occupancy defined in terms of bedspaces) and mix of tenures to reflect local and strategic demand Saved Policy HSG7 of the LBTH UDP states that new housing developments will be expected to provide a mix of unit sizes where appropriate including a substantial proportion of family dwellings. On developments of 30 dwellings or more, family dwellings should normally be in the form of family houses with private gardens. Exceptions to the policy include main road frontages and other locations where physical conditions are unsuitable for family dwellings The Core Strategy Policy SP02 aims to provide a mixture of small and large housing. This is to be achieved by requiring a mix of housing sizes on all sites and requiring 30% of all new housing to be for family accommodation Emerging policy DM3 of the MD DPD requires a balance of housing types including family homes. Specific guidance is provided on particular housing types and is based on the Councils most up to date Strategic Housing Market Assessment The Proposed Development at the Site will provide a residential mix, as set out in the accommodation schedule at Appendix 1. The proposed mix, across tenures, includes suites, 1 bed, 2 bed, 2 bed premium, 2 bed penthouses, 3 bed and 3 bed penthouses, with the most common units being suites, 1 bed and 2 beds. This mix has been developed to reflect local demand As the Site is physically highly constrained, the Proposed Development has been designed in a way that will optimise its development potential, which has resulted in the final design two slender residential towers, with wrap around private balconies. As a result, the Proposed Development is not considered suitable for family housing, due to the lack of available space for further amenity provision, and this is reflected in the low numbers of 3 bed + units. December 2012 I gva.co.uk 23

27 5.40 With regard to residential quality and layouts, Policy 3.5 of the London Plan 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 further states that LDF s should incorporate minimum space standards which conform with those set out in the London Plan as follows at Table 5.1: Table London Plan Minimum Space Standards for New Development Dwelling Type GIA (sqm) Flats 2 storey houses 3 storey houses 1p 37 1b2p 50 2b3p 61 2b4p 70 3b4p 74 3b5p 86 3b6p 95 4b5p 90 4b6p 99 2b4p 83 3b4p 87 3b5p 96 4b5p 100 4b6p 107 3b5p 102 4b5p 106 4b6p The proposed residential accommodation will be of the highest design quality, having been designed in accordance with the unit size standards set by the GLA in the London Plan and London Housing Design Guide. All dwellings achieve or exceed the minimum unit sizes set out in Table 5.1. The Proposed Development has been designed to ensure good levels of daylight to all units. Where possible, dual aspect units have been provided and the scheme ensures that all north facing flats are dual aspect to allow maximum levels of daylight. Please refer to the accompanying Design and Access Statement for further information regarding quality and layout of residential accommodation In addition to the above, it is essential that access is provided to all residents. Policy 3.8 of the London Plan and Policy SP02 of the LBTH Core Strategy require that all new housing is built to Lifetime Homes Standards and that 10% is designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users. December 2012 I gva.co.uk 24

28 5.43 The development has been designed to be in accordance with the requirements of the Lifetime Homes Standards and the Wheelchair Housing Standards. Further information can be viewed in the accompanying Design and Access Statement. Residential Density 5.44 The NPPF includes a requirement for local planning authorities to ensure that proposals optimise the potential of sites to accommodate development (paragraph 58) Density ranges for new residential developments are set out in the London Plan, and relate to the accessibility of a site. As set out above, the Site has a PTAL of 5, indicating very good accessibility to public transport. In accordance with this, and the Site s definition as a central area (areas with very dense development, a mix of different uses, large building footprints and typically buildings of four to six storeys, located within 800 metres walking distance of an International, Metropolitan or Major town centre in this case, Canary Wharf), the guidance set out in the London Plan seeks to provide residential densities of between 650 and 1,100 habitable rooms per hectare on the site. The adopted Core Strategy seeks to secure the creation of sustainable places by ensuring that new developments optimise the use of land, and by corresponding the distribution and density levels of housing to PTAL ratings and the wider accessibility of locations (Policy SP02). The Core Strategy sets out the rationale for the Borough s approach at paragraph 4.3 which states The location, scale, density, and design of new housing developments are principally shaped by the accessibility and urban structure of an area There are no saved UDP policies relating to residential densities but Policy HSG1 of the Interim Planning Guidance Core Strategy has been retained, and seeks to maximise residential densities on individual sites. The policy sets out a number of variables that should be taken into consideration, including local context and character, the need to protect and enhance amenity, and the need to incorporate good design principles. The Interim Core Strategy provides density guidelines that are consistent with those set out in the London Plan The Mayors Housing SPG (2012) notes that there is scope for higher density development beyond the matrix set out in the London Plan. However, it is essential that this is built to a high standard and enhances both the public and the private realm and is based on local circumstances. The exceptional design approach towards the Proposed Development December 2012 I gva.co.uk 25

29 fulfils this policy test through the delivery of an innovative design solution with private and communal amenity delivery throughout the two towers and new open space at ground floor level, to the west of the site, which is publically accessible The scheme proposes a residential density of circa 2,700 habitable rooms per hectare which optimises the use of a brownfield site in accordance with national, regional and local policy guidance, whilst creating a high quality sustainable mixed-use development. As such the Proposed Development will deliver a high density scheme in an accessible location that responds to its setting Furthermore, the scheme has been rigorously tested to ensure that it does not result in any significantly adverse impacts with regards to townscape, environmental or infrastructure capacities. The full results of this testing are set out within the Environmental Statement and Townscape Assessment that accompany the planning application and following this, it is considered that the proposed residenital density of the scheme is suitable in this urban location. Townscape and Design 5.50 The NPPF promotes high quality design and inclusive design for all development, including individual buildings, public and private spaces. It recognises that developments should aim to establish a strong sense of place, using streetscapes and buildings to create attractive and comfortable places to live, work and visit to help achieve sustainable development CABE s guidance, By Design (Urban Design in the Planning System: Towards Better Practice) (2000) lists seven criteria by which to assess urban design principles, as follows: character, continuity and enclosure, quality of the public realm, ease of movement, legibility, adaptability and diversity At the regional level, Policy 7.1 of the London Plan states that the design of new buildings and the spaces they create should help reinforce or enhance the character, legibility, permeability and accessibility of the neighbourhood. Policy 7.2 further states that the Mayor will require all new development in London to achieve the highest standards of accessible and inclusive design. The principles of inclusive design which seek to ensure that developments achieve the following are supported by London Plan Policy 7.2 and have been addressed throughout the evolution of the development proposals for the Site: December 2012 I gva.co.uk 26

30 Developments that can be used safely, easily and with dignity by all regardless of disability, age, gender, ethnicity or economic circumstances; Developments that are convenient and welcoming with no disabling barriers, so everyone can use them independently without undue effort, separation or special treatment; Developments that are flexible and responsive, taking account of what different people say they need and want, so people can use them in different ways; and Developments that are realistic, offering more than one solution to help balance everyone s needs, recognising that one solution may not work for all Policy 7.4 of the London Plan goes on to state that developments should have regard to the form, function and structure of an area, including the scale, mass and orientation of buildings. The policy further states that buildings should provide contemporary architectural responses that: Have regard to the pattern and grain of existing spaces and streets in orientation, scale, proportion and mass; Contribute to a positive relationship between the urban structure and local natural landscape features; Are human in scale; Allow existing buildings and structures that make a positive contribution to the character of a place to influence the existing character of the area; and Are informed by the surrounding historic environment Policy 7.6 of the London Plan further states that architecture should make a positive contribution to a coherent public realm, streetscape and wider cityscape, incorporating the highest quality materials and design appropriate to its context The adopted LBTH Core Strategy promotes good design in the creation of buildings, spaces and places that are of a high quality, sustainable, accessible, attractive, durable December 2012 I gva.co.uk 27

31 and well-integrated with their surroundings (Policy SP10.4). The policy further sets out a number of design criteria which developments should adhere to, including: Respecting the local context and townscape, including the character, bulk and scale of the surrounding area; Contributing to the enhancement or creation of local distinctiveness; Being flexible and adaptable to change; Using high quality architecture, urban and landscape design; and Assisting in creating a well-connected public realm that is easy and safe to navigate Policy SP12 of the Core Strategy seeks to ensure that places are well-designed, so as to offer the right layout to support the day-to-day activities of local people Retained Policy DEV1 of the UDP sets out general design and environmental requirements and states that all development proposals should consider and be sensitive to the development capabilities of the site and to the surrounding area in terms of design, bulk, scale and the use of materials The high quality proposals comprise a unique and innovative design solution which responds effectively to the site s location, its capacity, and the character of the surrounding area and recent consents granted on the Isle of Dogs, as set out in Section 2 of this Planning Statement. Furthermore, the buildings have been designed to enhance permeability and accessibility by creating active ground floor uses and public spaces. It is therefore considered that the Proposed Development will significantly enhance the appearance of the Site and surrounding area The principles are in accordance with the design principles set out in national, regional and local planning guidance Further discussion of the design evolution process and the proposals is set out in the Design and Access Statement, prepared by Glenn Howells Architects. The proposals have also been fully assessed as part of the Environmental Impact Assessment. The Townscape and Visual Impact Assessment (Volume III of the Environmental Statement), prepared by Environ and Miller Hare, demonstrates that the proposed development will have a number December 2012 I gva.co.uk 28

32 of significant benefits, and that the development represents an appropriate response to its location and will be strongly beneficial in urban design and townscape terms. Tall Buildings 5.61 As noted previously, the NPPF includes a requirement for local planning authorities to ensure that proposals optimise the potential of sites to accommodate development (para 58) The tall buildings guidance paper prepared by CABE and English Heritage, Guidance on Tall Buildings (2007) recognises that in the right place, tall buildings can make a positive contribution to city life. The document provides advice and good practice guidance in relation to tall buildings and states that all proposals for tall buildings should be accompanied by accurate and realistic representations of the appearance of a building. Guidance on Tall Buildings sets out the following criteria for evaluating proposals: Relationship to context; Effect on historic context; Effect on World Heritage Sites; Relationship to transport infrastructure; Architectural quality of the building; Sustainable design and construction of the proposal; Credibility of the design; Contribution to public space and facilities; Effect on local environment; Contribution made to the permeability of the site and the wider area; and Provision of a well-designed environment The proposals have been developed in accordance with London Plan Policy 7.7 which states that tall and large buildings should relate well to the form, proportion, composition, scale and character of surrounding buildings, urban grain and public realm. The policy promotes the improvement of the legibility of an area and requires proposals to December 2012 I gva.co.uk 29

33 incorporate the highest standards of architecture and materials, including sustainable design and construction practices. The policy seeks to ensure that tall and large buildings contribute to improving the permeability of the site and wider area, which the proposals seek to do. Policy 7.7 states that tall buildings should not affect their surroundings adversely in terms of microclimate, wind turbulence, overshadowing etc and the proposals have been subject to a rigorous Environmental Impact Assessment to ensure accordance with this The adopted Core Strategy indicates that tall buildings outside of the Canary Wharf and Aldgate areas (which are specifically identified as suitable for tall buildings) will be assessed against criteria set out in the emerging Managing Development DPD (Policy DM26). The Post Examination in Public draft of the document notes that building heights will be assessed in accordance with the town centre hierarchy and a number of criteria set out below: Be of a height and scale that is proportionate to its location within the town centre hierarchy and sensitive to the context of its surroundings; Within the Tower Hamlets Activity Area, development will be required to demonstrate how it responds to the difference in scale of buildings between the CAZ / Canary Wharf Major Centre and the surrounding residential areas. Achieve high architectural quality and innovation in the design of the building, including a demonstrated consideration of its scale, form, massing, footprint, proportion and silhouette, facing materials, relationship to other buildings and structures, the street network, public and private open spaces, watercourses and waterbodies, or other townscape elements; Provide a positive contribution to the skyline, when perceived from all angles during both the day and night, assisting to consolidate clusters within the skyline; Not adversely impact on heritage assets or strategic and local views, including their settings and backdrops; Present a human scale of development at the street level; Where residential uses are proposed, include high quality and useable private and communal amenity space and ensure an innovative approach to the provision of open space; December 2012 I gva.co.uk 30

34 Not adversely impact on the microclimate of the surrounding area, including the proposal site and public spaces; Not adversely impact on biodiversity or open spaces, including watercourses and waterbodies and their hydrology, as well as their settings and views to and from them; Provide positive social and economic benefits and contribute to socially balanced and inclusive communities; Comply with Civil Aviation requirements and not interfere, to an unacceptable degree, with telecommunication, television and radio transmission networks; and Demonstrate consideration of public safety requirements as part of the overall design, including the provision of evacuation routes In accordance with national, regional and local policy guidance in respect of tall buildings, the proposal has been designed to provide a world-class standard of architecture, assessed through accurate visual representation and microclimate impact assessments to ensure the building is appropriate for its context. The Proposed Development is delivered in a location with very good transport accessibility, will ensure the safety of occupiers, includes a mix of uses and contributes to the public realm including the provision of new public amenity and hard landscaping that integrate the Site to its surroundings The Townscape and Visual Assessment which accompanies this application demonstrates that the scheme has been designed to accord with the principles and objectives of the relevant design, townscape and heritage guidance. Open Space and Amenity 5.67 The NPPF recognises that the provision of accessible and high quality open space contributes towards the health and well-being of communities. It also outlines the importance of incorporating green and other public space to support local facilities (Paragraphs 73-74). December 2012 I gva.co.uk 31

35 5.68 London Plan Policy 7.5 seeks to ensure that London s public spaces 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 and the development proposals will accord with the objectives of this policy. The policy further states that developments should make the public realm comprehensible at a human scale Policy SP09.5 of the adopted Core Strategy seeks the creation of a high quality public realm network which provides a range of sizes of public space that can function as places for social gathering. Policy SP12 further seeks to ensure that places have a range and mix of high-quality, publicly accessible green spaces These approaches are inherent in the design strategy to the landscaping around the Site. The Proposed Development also provides an innovative solution to the delivery of amenity space in both towers by providing communal amenity space and children s play space at podium level on the second floor. Communal and Public Amenity Space 5.71 Policy 3.5 of the London Plan seeks to enhance the quality of local places by ensuring that new housing developments take into account the provision of public, communal and open spaces At the local level, Policy SP02.6 of the adopted Core Strategy requires adequate provision of housing amenity space for new homes, including private amenity space in every development, and communal amenity space for developments providing 10 units or more An innovative and sophisticated amenity strategy has been developed to provide a range of amenity space for the residents at the Site. Full details of the proposed amenity strategy are provided in the accompanying Design and Access Statement prepared by Glenn Howells Architects. The key details of the proposals are summarised below ,053 sqm of communal amenity spaces is incorporated within the buildings themselves. These spaces comprises: Communal amenity space (including children s playspace) at podium level on the second floor; and December 2012 I gva.co.uk 32

36 A sky garden on the 53rd floor of the east tower In addition to this, there is a residents pool and gym located at ground and first floor level, a residents cinema and business suite at the second floor as well as a residents lounge at ground floor (plus mezzanine level) In addition to amenity space within the towers, the Proposed Development also includes publicly accessible open space at the ground floor including the western garden, which totals 3,126 sqm. This area will provide planting and seating as well as child play areas. Private Amenity Space 5.77 The London Housing Design Guide recommends that a minimum of 5 sqm of private outdoor space should be provided for 1-2 person dwellings and an extra 1 sqm should be provided for each additional occupant At the local level, Policy DM4 of the draft MD DPD sets out standards for new housing developments with relation to private and communal amenity space. These standards are in line with the Mayor s Housing Design Guide (2010), recommending that a minimum of 5 sqm of private outdoor space is provided for 1-2 person dwellings and an extra 1 sqm is provided for each additional occupant In the Proposed Development, all residential units will have access to private amenity space, with a minimum of 5 sqm per unit, in accordance with the London Housing Design Guide standards. This will be provided as balconies, though as discussed above, there will also be shared amenity spaces and a sky garden The proposed provision of private amenity space exceeds the policy guidance requirements set out above and will result in the provision of a high quality environment for residents. Child Play Space 5.81 Policy 3.6 of the London Plan sets strategic guidance stating that the Mayor and appropriate organisations should ensure that all children and young people have safe access to good quality, well-design, secure and stimulating play and informal recreation provision, incorporating trees and greenery. December 2012 I gva.co.uk 33

37 5.82 The Mayor s SPG Shaping Neighbourhoods: Play and informal recreation (September 2012) states that children s play space should be provided in new developments with a standard target of 10 sqm per child. The SPG further recommends the following accessibility requirements for children s play space: 100 metres maximum walking distance from a residential unit for under 5s; 400 metres maximum walking distance from a residential unit for 5-11 year olds; and 800 metres maximum walking distance from a residential unit for 12+ year olds At the local level, Policy SP02.6 of the adopted Core Strategy requires sites that are providing family homes, to provide adequate play space for children Policy DM4 of the emerging MD DPD specifically advises that applicants apply LBTH child yields and the guidance set out in the Mayor of London s SPG on Shaping Neighbourhoods: Play and informal recreation which sets a benchmark of 10 sqm of useable child play space per child as stated above With regard to the scheme s provision of child play space, the child yield of the proposed development has been calculated for the purposes of the Environmental Impact Assessment and the results of this are presented in Chapter 7 (Socio-Economics) of Environmental Statement Volume II. Using LBTH child yields, it is expected that up to 50 children between 0 and 15 years may live in the Proposed Development, thus generating a requirement for circa 500 sqm of child play space in accordance with the guidance set out in the Mayor of London s SPG on Shaping Neighbourhoods: Play and informal recreation. This is be broken down in to age groups in Table 5.2 below. Table 5.2: Child Play Space Generation 0-5 years 5-11 years 12+ years LBTH Expected Child Yield GLA Play Space Requirement sqm 80 sqm 90 sqm Off-site provision December 2012 I gva.co.uk 34

38 5.86 The Proposed Development will provide 526 sqm of play space for children on site. This comprises: 334 sqm for under 5 year olds; 96 sqm for 5-11 year olds; and 96 sqm for 12+ year olds This provision exceeds the requirements for play space for all the above age groups. The play space provided will be of a high standard, with emphasis placed on the quality of equipment which will be stimulating and educational The child playspace is located at podium level as well as within the western garden at ground floor level As set out above, further details of the landscape proposals and amenity space provision are set out within the Design and Access Statement, prepared by Glenn Howells Architects. Transport and Access 5.90 This section sets out the merits of the scheme with reference to transport, connectivity and access NPPF policy directs new development to locations that are highly accessible by public transport, walking and cycling, recognising that an integrated transport system is necessary to support a strong and prosperous economy (paragraphs 31-35). It also encourages solutions which support reductions in greenhouse gas emissions and reduce congestion (paragraph 30) At the regional level, London Plan Policy 6.1 seeks to encourage patterns and nodes of development that reduce the need to travel, especially by car. The Site has a PTAL of 5. As such, the Proposed Development, which seeks to intensify the use of the Site is in accordance with Policy 6.1 of the London Plan which supports development that generates high levels of trips at locations with high public transport accessibility. In accordance with Policy 6.3, an assessment of the proposals has been undertaken to December 2012 I gva.co.uk 35

39 ensure that the impacts on transport capacity and the transport network are not adversely affected. The results of this testing are set out in the accompanying Transport Assessment, prepared by WSP. A Travel Plan has also been prepared, in accordance with the London Plan The adopted Core Strategy aims to deliver an accessible, efficient, high quality, sustainable and integrated transport network (Policy SO19). Through Policy SO20, the Council seeks to deliver a safe, attractive, accessible and well-designed network of streets and spaces that make it easy and enjoyable for people to move around on foot and bicycle Policy SO21 of the Core Strategy further aims to create streets, spaces and places which promote social interaction and inclusion. Policy SP09 supports the creation of new routes through identified development sites, and the improvement of accessibility between the parts of the Borough that suffer from barriers to movement. Policy SP12 seeks to ensure that places provide for a well connected, safe and attractive network of streets and spaces that make it easy and pleasant to walk and cycle. The policy further promotes places which have access to a range of public transport modes Saved UDP policies T16, T18, T19 and T21 and Policy DM20 of the MD DPD further promote the delivery of an accessible, efficient and sustainable transport network, ensuring that new development has no adverse impact on safety and road network capacity, requiring the assessment of traffic generation impacts and also prioritising and encouraging improvements to the pedestrian environment The Site has a PTAL of 5, which indicates very good accessibility to public transport. Access to the Docklands Light Railway is provided at both Heron Quays and South Quay DLR stations, which are located in close proximity of the site, while Canary Wharf (Jubilee Line and DLR services) are directly accessible from the Site on foot. The Site is also readily accessible by bus services, providing services towards the south of the Isle of Dogs, Stratford, Hackney, and Islington The Proposed Development makes a positive contribution to improving pedestrian access, connectivity, permeability and space both within the Site and in the surrounding area. Excellent connections are also provided to the National and London Cycle Networks, which run along Westferry Road and Heron Quays. In addition, cycling is encouraged December 2012 I gva.co.uk 36

40 along the dockside walkways and residential streets in the area, which increases the penetration of cyclist activity within the area Overall, the Proposed Development at the Site would benefit from very good levels of public transport accessibility, pedestrian provision and cyclist provision. As such the Proposed Development supports the use of sustainable modes of travel and the proposals optimise the use of this accessible brownfield location, in accordance with planning policy guidance The submitted Transport Assessment concludes that the close proximity of the proposed residential development to large-scale employment and retail areas will help reduce the overall need to travel and encourage the use of sustainable modes for trips. In addition, the generated trips by each of the different modes of transport can be accommodated on the surrounding transport infrastructure. The Transport Assessment concludes the Proposed Development fully meets the transport aspirations of Tower Hamlets and current Governmental guidance in respect of sustainable development and will, through its design, encourage the use of sustainable modes of transport. Parking and Servicing The NPPF states an overarching need to reduce the use of high-emission vehicles and impacts of traffic congestion Policy 6.13 of the London Plan seeks to ensure that on-site car parking at new developments is the minimum necessary and that there is no over-provision that could undermine the use of more sustainable non-car modes. The only exception to this approach will be to ensure that developments are accessible for disabled people This approach is reiterated in the Core Strategy SP09, which promotes car-free development to minimise on-site and off-site car parking provision in locations with good transport access and help address issues of congestion and air pollution Core Strategy SP09 is clear that the Borough will promote car free developments and developments that minimise on and off site parking provision in locations with good transport accessibility The emerging MD DPD Parking Standards sets specific parking ratios based on the PTAL rating for different locations. The ratio for sites with a PTAL rating of 5-6b are 0 spaces per December 2012 I gva.co.uk 37

41 residential unit of less than 3 bedrooms, and 0.1 spaces per residential unit for 3 bedrooms plus The scheme proposes 102 off-street car parking spaces which conforms to the adopted maximum parking standards of both TfL and LBTH. These spaces will be provided at basement level the basement has already been part constructed under extant planning permission (ref. PA/07/00347). 14 of these spaces will be conventional parking spaces (of which 10 will be suitable for wheelchair users) and 88 spaces will be provided as a pallet system (of which 88 will be suitable for wheelchair users). The provision of disabled parking spaces exceeds the 10% requirement as set out within Policy 6.13 of the London Plan To ensure that the Proposed Development does not result in off site parking demand, the applicant will enter into a car-free agreement with the Borough The accompanying Transport Assessment prepared by WSP demonstrates that the proposed provision of car parking spaces and servicing arrangements are considered to be sustainable and appropriate for the Site A delivery and servicing management plan has been prepared by WSP and is included as an appendix within the Transport Assessment. It is intended that all deliveries to the site can be undertaken using the basement servicing area for both the residential, ancillary residential and commercial uses. In addition, refuse collection will be undertaken from within the basement A Travel Plan has been produced for the residential land use, with the document being prepared in accordance with the Transport for London (TfL), Travel Planning for New Development in London; incorporating deliveries and servicing (February 2011) as well as the DfTs Good Practice Guidelines: Delivering Travel Plans through the Planning Process (DfT, 2009). The Travel Plan sets out the site wide management structure for the site and outlines the sustainable travel principles and measures to be incorporated within the proposals. Please refer to the Transport Assessment for further details regarding the Travel Plan. Cycle Parking With regards to cycle parking, the London Plan states at Policy 6.9 that developments should provide secure, integrated and accessible cycle parking facilities in line with the minimum standards set out in Table 6.3 of the Plan. DM22 of the LBTH MD DPD states that December 2012 I gva.co.uk 38

42 new developments should meet and preferably exceed cycle parking standrds as set out in Appendix 2 of the document Table 5.3 below shows that the cycle parking proposed at the Site meets the necessary minimum standards. Table 5.3 Cycle Parking Provision Land Use Quantity Required Standards for LBTH/TfL Residential 792 units 783 < 2 bed 9 > 3 bed Ancillary residential Commercial 701 m² 140m² Retail Unit A 162m² Retail Unit B 399m² Café Visitor Residential Retail/Cafe Provided within Landscaping Area The Proposed Development has been designed to ensure that the 808 cycle spaces required by policy for the residential and commercial elements of the scheme could be accommodated within the basement mezzanine. However, Ballymore has observed that within its neighbouring recent development at Pan Peninsula on Marsh Wall/Millharbour, only 71 bicycles are stored within the basement cycle store for a development of circa 800 units. Notwithstanding policy requirements, it would seem illogical to provide the 808 basement cycle racks to have an occupancy of less than 10%. As such, it is proposed that Ballymore will provide storage lockers in lieu of cycle stands which are suitable for bike storage. The accompanying Transport Assessment suggests a suitable obligation for the developer could be made for cycle storage requirements such that bike storage will be provided at a minimum level of 0.65 spaces per unit but will be evaluated annually in perpetuity and increased to a level of 15% greater than demand up to a provision of 808 spaces. This will meet the needs of the proposed development and also meet with the aims of relevant planning policy visitor cycle parking spaces will be provided in the landscaping areas in order to provide for residents, visitors to residences and customers to the retail and cafe uses. This is in accordance with TfL and LBTH policy requirements. December 2012 I gva.co.uk 39

43 5.114 Further details of the cycle parking provision are outlined in the Transport Assessment, prepared by WSP. Sustainability and Energy At the national level, the NPPF supports the Government s stated intention to deliver sustainable development. This is most evident through the delivery of renewable and low carbon energy and associated infrastructure which is considered central to each of the economic, social and environmental dimensions. As such, development proposals will be expected to comply with local requirements and should take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption and to increase the use and supply of renewable and low carbon energy (Paragraphs 93-97) In keeping with the NPPF, achieving sustainable development is a key objective of the London Plan. This is guided by Policy 5.2 which states that development proposals should make the fullest contribution to minimising carbon dioxide (CO2) emissions in accordance with the following energy hierarchy: Be Lean: use less energy; Be Clean: supply energy efficiency; and Be Green: use renewable energy The above policy also requires major developments to deliver a 25% carbon dioxide emissions reduction improvement on 2010 Building Regulations between and 40% between The CO2 reduction targets should be met on-site. However, where it is clearly demonstrated that the specific targets cannot be fully achieved on-site, any shortfall may be provided off-site or through a payment in lieu contribution. It is also stated that Boroughs should require all developments to demonstrate how the targets for CO2 emissions reduction are to be met by including detailed energy assessments Policy 5.7 of the London Plan seeks to increase the proportion of energy generated from renewable sources Policy 5.3 of the London Plan further states that the highest standards of sustainable design and construction should be achieved in London to improve the environmental December 2012 I gva.co.uk 40

44 performance of new developments and to adapt to the effects of climate change over their lifetime. Policy 5.6 of the London Plan requires development proposals to evaluate the feasibility of Combined Heat and Power (CHP) systems and states that major development proposals should select energy systems in accordance with the following hierarchy: Connection to existing heating or cooling networks; Site-wide CHP network; Communal heating and cooling At the local level Policy SO3 of the Core Strategy seeks to incorporate the principle of sustainable development, including limiting carbon emissions from development, delivering decentralised energy and renewable energy technologies and minimising the use of natural resources. Policy SO9 seeks that all new housing in the Borough is high quality, well designed, energy efficient, sustainable and durable. Policy SP2 clarifies this further stating that new homes are required to respond to climate change, including achieving a stepped-target for carbon emissions standards in-line with government guidance Policy SP11 of the adopted Core Strategy sets a borough-wide carbon emission reduction target of 60% below 1990 levels by It also requires all new developments to provide a 20% reduction of CO2 emissions through on-site renewable energy generation where feasible Policy SP12 further seeks to ensure that places promote wider sustainability and assist in the overall reduction in consumption of resources Retained Policy DEV2 of the LBTH UDP seeks to incorporate the principle of sustainable development into new proposals and supports the use of energy efficient design and materials Policy DM29 of the emerging MD DPD requires compliance with the following: = 35% CO2 emissions reduction; = 50% CO2 emissions reduction; and December 2012 I gva.co.uk 41

45 = Zero Carbon The Proposed Development includes a commitment to achieving a highly sustainable development. The development targets as a minimum, a Code for Sustainable Home Level 4 rating for the proposed residential apartments and a BREEAM rating of Very Good for the proposed non-residential accommodation For further information regarding the energy efficiency measures for the Proposed Development, please refer to the accompanying Energy Statement prepared by Hoare Lea. Development and Flood Risk NPPF paragraph 100 (along with Technical Guidance on flood risk published alongside the Framework) and Policy 5.12 of the London Plan relate to the need to consider flood risk at all stages of the planning process Policy 5.13 of the London Plan states that development should utilise sustainable urban drainage systems (SUDS) unless there are practical reasons for not doing so, and should aim to achieve surface water run-off rates Policy SO13 of the Core Strategy seeks to reduce the risk and impact of flooding on people, property and the environment As required by the NPPF, a Flood Risk Assessment has been carried out following an approach agreed with the Environment Agency, and attached as an appendix to the Environmental Statement. Please refer to this for further information The assessment considers a number of sources of flooding, and provides suitable measures to ensure that they will not adversely affect the Site. The implementation of measures is consistent with the LBTH Code of Construction Practice and the sustainable site wide Surface Water Drainage Strategy provides mitigation against surface water flooding and is not considered to be significant. The proposals are therefore considered to be fully in accordance with relevant policy guidance For further information please refer to ES Chapter 13: Water Resources and Flood Risk. December 2012 I gva.co.uk 42

46 Daylight, Sunlight and Overshadowing Guidelines relating to daylight and sunlight are contained within the Building Research Establishment (BRE) Handbook Site Layout Planning for Daylight and Sunlight (1991). This guidance includes discussion on how to protect the daylighting and sunlighting of existing buildings when new developments are proposed. Details are also included on rights to light and indicators to calculate access to skylight, sunlight and solar radiation Policy 7.6 of the London Plan requires new buildings and structures to ensure that they do not cause unacceptable harm to the amenity of surrounding land and buildings in relation to a number of factors, including overshadowing. The policy makes reference to this being particularly important for tall and residential buildings. Policy 7.7 further states that tall buildings should not adversely affect their surroundings in terms of overshadowing and reflected glare Core Strategy Policy SP10 and Policy DM25 of the emerging MD DPD seek to protect amenity, by ensuring development does not result in an unacceptable material deterioration of the sunlight and daylight conditions of surrounding development. MD DPD Policy DM25 also seeks to ensure adequate levels of light for new residential developments Throughout the evolution of the Proposed Development, consideration has been given to the daylight and sunlight effects on the neighbouring residential properties Consideration has also been given to the positioning of the massing upon the Site of the Proposed Development A full assessment of the daylight and sunlight impacts of the proposed development has been undertaken and is included within the Environmental Statement (Chapter 12: Daylight, Sunlight and Overshadowing as well as within the Technical Appendix of ES Volume IV). Please refer to this document for further information. Ecology The NPPF states new development should be planned to avoid increased vulnerability to the range of impacts arising from climate change including changes to biodiversity and landscape. When new development is brought forward in areas which are vulnerable, December 2012 I gva.co.uk 43

47 care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure (Paragraph 99) The Framework promotes minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures (Paragraph 109) Policy 7.19 of the London Plan seeks a proactive approach to the protection, enhancement, creation, promotion and management of biodiversity and states that development proposals should wherever possible, make a positive contribution to the protection, enhancement, creation and management of biodiversity This approach is reflected at a local level as SP04 Core Strategy seeks to protect and enhance biodiversity value through the design of open space and buildings and by ensuring that development protects and enhances areas of biodiversity value in order to achieve a net gain in biodiversity This theme is carried forward in the emerging MD DPD. Policy DM11 also requires elements of living buildings, include living roofs, walls, terraces and other building greening techniques The Proposed Development has been designed to address the requirements set out in planning policy and guidance The Ecology Chapter of the accompanying ES concludes that the site has virtually no vegetation and is of negligible importance for nature conservation and the site is unlikely to support protected or notable species. However, once completed, the Proposed Development s landscape proposals would increase the vegetation cover at the site by approximately 20% and would make a meaningful contribution to the green infrastructure of the local area, which at present is sparsely vegetated. This is also expected to be beneficial to local wildlife including invertebrates Further information regarding the proposed measures to protect ecology is provided within the accompanying Environmental Statement (Chapter 14, Volume II). December 2012 I gva.co.uk 44

48 Noise Government guidance within the NPPF recognises that development will often create some noise. However, it also makes clear that existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established (Paragraph 123) The NPPF also recognises that permitted operations should not have unacceptable adverse impacts on the natural and historic environment or human health, including from noise (Paragraph 143). It is therefore considered important to avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development (Paragraph 123) In keeping with this, Policy 7.15 of the London Plan states that development proposals should seek to reduce noise by minimising the existing and potential adverse impacts of noise on, from, within, or in the vicinity of, a development and promoting new technologies and improved practices to reduce noise Core Strategy policies SP03 and SP10 further seek to ensure that development proposals reduce noise by minimising the existing and potential adverse impact and separate noise sensitive development from major noise sources The protection of the amenity of surrounding existing and future residents is reinforced in emerging policy DM25 of the MD DPD which seeks to not create unacceptable levels of noise and vibration during the construction and life of developments The Proposed Development has been designed to mitigate against any negative effects of noise and accords with the requirements set out in planning policy and guidance. Information on the mitigation measures for noise and vibration for the Proposed Development at the site are detailed in Chapter 9: Noise and Vibration of the accompanying ES. Planning Obligations In relation to the negotiation of planning obligations, Regulation 122 (2) of the Community Infrastructure Levy of the Regulations states that: December 2012 I gva.co.uk 45

49 A planning obligation may only constitute a reason for granting planning permission for the development if the obligation is a) necessary to make the development acceptable in planning terms; b) directly related to the development; and c) fairly and reasonably related in scale and kind to the development, Draft Heads of Terms The Applicant has engaged in preliminary discussions with the Council regarding the planning obligations which may be required in the event that the Council is minded to grant planning permission for the redevelopment of the Application Site. Discussions to date have been focused around the Council's Planning Obligations SPD, which was adopted in It is anticipated that an appropriate package of Section 106 contributions, which will be subject to scheme viability, will be discussed with officers following submission of the application. Pre-application discussions with officers and the heads of terms set out in the SPD have identified the following draft heads of terms: Affordable housing Employment, Skills Training and Enterprise Community Facilities Education Health Sustainable Transport Public Realm including dockside walkway Environmental Sustainability Monitoring and Implementation Following submission of the planning application for the redevelopment of the Site, the applicant shall continue to engage with LBTH on planning obligations to mitigate the December 2012 I gva.co.uk 46

50 effects of the Proposed Development. In this regard and, at the appropriate time our client shall enter into detailed negotiations with the Council concerning the set of planning obligations which will be required, in this case having regard to the particular characteristics of the development proposals, the statutory tests for planning obligations contained in Regulation 122 of the Community Infrastructure Levy Regulations 2010, any relevant Circular guidance on the need for planning obligations, and the overall viability of the development proposals The agreed Section 106 package should take account of payments already made in relation to extant planning permission PA/07/00347 which should be offset against any required contribution. December 2012 I gva.co.uk 47

51 6. CONCLUSIONS 6.1 This Planning Statement has been prepared by GVA and is submitted in support of a full planning application made on behalf of Arrowhead Commercial Ltd (the Applicant), part of the Ballymore Group of companies, for the redevelopment of the site (the Site). This statement demonstrates the planning case in support of the proposals in the context of relevant national, regional and local planning policy, and other best practice guidance and material considerations. 6.2 The Proposed Development seeks to optimise the potential of this under-utilised brownfield site by delivering a high quality scheme on previously developed land. The scheme would provide 792 high quality residential units, which will contribute significantly to the Borough s housing targets. In addition, the scheme proposes a range of ancillary residential uses, including a gym, pool, cinema, business suites and residents lounge as well as nonresidential uses including retail units and a café. This ensures a mix of uses to support the aims and function of the Canary Wharf Activity Area. 6.3 The scheme incorporates communal amenity provision and child play space at podium levels on the second floor as well as a sky garden located within the east tower. The proposal also delivers a publicly accessible western garden at ground floor level which incorporates planting, seating and child play space. This will help to enliven the ground floor and create a more pleasant pedestrian environment. 6.4 The Proposed Development also creates an opportunity to create linkages from Marsh Wall to the dock, via the western garden, but also via the eastern edge of the building which has been designed to provide an animated and active frontage to the area under the DLR. A public dockside walkway is also included within the proposals. 6.5 The principles of sustainable development have been integral to the design evolution of the Proposed Development and the density of development has responded to the Site s environment. The Proposed Development incorporates a range of sustainable design and construction measures and has been designed to make use of energy efficient building techniques. As such, the Proposed Development will achieve a Code for Sustainable Home Level 4 rating for the proposed residential units and a BREEAM rating of Very Good for the proposed non-residential accommodation. December 2012 I gva.co.uk 48

52 6.6 The Proposed Development at the site represents the highest design quality and the proposals have developed through close consultation with officers at LBTH. The proposals seek to deliver high quality inclusive design that responds to the local context. The massing, scale, height and design of the buildings are fully justified within the supporting documentation through detailed contextual analysis taking account of the planning policy and other relevant environmental and infrastructure considerations. 6.7 The Proposed Development would provide a number of benefits for the Site and surrounding area, as set out below: The scheme will deliver a significant number of high quality homes, which is the Borough s priority land use. The proposal will ultimately deliver a number of affordable homes to meet the Borough s identified need. The redevelopment of the Site will optimise the potential of a previously developed brownfield site and will contribute to ongoing improvement of the surrounding area. The Proposed Development will open up linkages from Marsh Wall to the dockside, creating a more pleasant urban environment. The environment under the DLR will be greatly improved and will encourage pedestrian movement through this area. The proposals will further enhance the public realm through the creation of a publicly accessible open space to the west of the site which will include planting, seating and child play space. The scheme will provide residential accommodation of an exemplary standard which will comply with and exceed the Mayor s residential unit size standards and will provide large and high quality amenity spaces and child play spaces. The Proposed Development will utilise sustainable and energy efficient building techniques and will combine this with renewable energy technologies to ensure that the development achieves a significant reduction in potential carbon dioxide emissions. Substantial section 106 financial contributions towards education, healthcare, local community facilities, the environment, public transport improvements December 2012 I gva.co.uk 49

53 and training and skills provision (taking account of previous contributions already paid in relation to extant permission PA/07/00347 which should be offset against any required contributions). 6.8 On balance, the Proposed Development is fully in accordance with the overall objectives of national, regional and local policy guidance, as has been demonstrated in this Planning Statement. December 2012 I gva.co.uk 50

54 Appendices

55 Appendix 1