new tower hamlets draft local plan 2031 · 2.for all sites the policies set out in this plan may be...

a

There are a number of large scale developments currently under construction or which have been granted planning permission in the immediate area surrounding Princes Court. The closest and most recent of these schemes is London Dock, Wapping, a residential led, mixed use development extending at its highest point to 25 storeys and comprising of 1,800 units in total, alongside retail, office and educational space. The London Dock site is located 600m to the west of the Princes Court and was granted outline planning permission in January 2014. Our client is currently exploring the future options at Princes Court which has the potential to contribute towards London’s need for both housing and employment uses. New Tower Hamlets Draft Local Plan 2031 – Representations General We consider Emerging Policy D.H6 (2.) (Tall Buildings) of the DLP, which requires development of tall buildings to be directed towards designated Tall Building Zones (TBZs), to be restrictive and inflexible. This policy would have the effect of unnessecarily constraining development and design on sites outside of these zones, and would therefore not be effective in its delivery. Given the prescriptive nature of Emerging Policy D.H6, it could be held that it is not consistent with Draft London Plan Policy D6 (Optimising Housing Density) which seeks to optimise the use of land through a design led approach with regard to context, connectivity, infrastructure and capacity. Given this, we welcome the proposed addition to Emerging Policy D.H6 of (3.) which indicates support in the siting of tall buildings outside of TBZs and proposes a design led approach to mitigating the impact of tall building which makes D.H6 compliant with Draft London Plan Policy D6. Whilst in principle, as stated we support this addition, for greater clarity on circumstances when support for such developments will be given, we propose the following alteration to D.H6 3.:

a.be located in areas with high levels of public transport accessibility (PTAL 4-6) as defined in London Plan Policy 3.4 (Optimising Housing Potential)

Whilst we support strongly, in principle, flexibility in relation to developer contributions and viability, we do not consider Emerging Policy D.SG5 Modifications 2. and 2.46 to be sufficient in relation to flexibility on all sites. These modifications state that for allocated sites only, the policies set out in the DLP may be applied flexibly to ensure that sites are viable and deliverable. To increase the delivery of homes in the borough and bring Policy D.SG5 further in line with Adopted London Plan Policy 3.11 (Affordable Housing Targets), we propose to extend this flexible approach to all sites within the borough through the following alterations:

2.For all sites the policies set out in this plan may be applied flexibly to ensure that the sites are viable and deliverable

2.46 Part 2 seeks to provide flexibility in the determination of planning applications relating to all sites to ensure that development is viable and can be delivered during the plan period, having regard to the provision of infrastructure and other site specific requirements.

Residential As previously stated, we strongly advocate a flexible approach to DLP Policy when considering the viability and deliverability of sites within the borough. In line with this, we welcome DLP Policy S.H1 (Meeting Housing Needs) parts 2. a. ii) and iii) which state affordable housing delivery within the borough will be subject to viability, as well the proposed modification to Paragraph 4.18 of removing ‘in exceptional circumstances’ when describing sites where lower levels of affordable housing may be acceptable. In addition to S.H1 we propose a modification which provides greater clarity to Part a) iv) and makes it consistent with the rest of the policy:

iv)requiring a mix of rented and intermediate affordable tenures to meet the full range of housing needs (subject to viability)

a

We support the proposed modifications to DLP Policy D.H2 (Affordable Housiing and Housing Mix) paragraph 4.37 which seeks to achieve greater flexibility in the private unit mix of developments that propose to deliver at least 35% affordable housing. We believe that this flexibility should be extended to the unit mix for the affordable housing component of developments in order that the Policy further complies with London Plan 3.11 (Affordable Housing Targets) which states that Borough targets for affordable housing (including the tenure and mix of affordable homes) should take account of the viability and deliverability of future developments. Commercial Policy D.ES7 (A Zero Carbon Borough) Part 2 seeks maximum energy efficiency on all ‘major’ non-residential developments within the borough by requiring that those developments meet or exceed a BREEAM rating of ‘excellent’. In order to make this policy effective in its delivery and compliant with the Adopted and Emerging London Plan as well as with the Town and Country Planning (Development Management Procedure) Order 2015, being key regional and national documents which define ‘major development’ as that which exceeds 1,000 square metres, we propose the following alterations to D.ES7:

a.All new non-residential development over 1,000 square metres floorspace must meet or exceed BREEAM ‘excellent’ rating. b.All non-residential refurbishment of existing buildings and conversions over 1,000 square metres floorspace (gross) must meet at least BREEAM non-domestic refurbishment ‘excellent’rating.

Summary Whilst Aviva Investors are generally supportive of the Draft Local Plan, there are a number policies which require further consideration. These relate to housing / affordable housing, building heights and the definition of‘major’ non residential development. I trust this is acceptable, however should wish to discuss the contents of this letter further, please do not hesitate to contact me. Yours sincerely

Director

cc. Aviva Investors

a

Appendix A – Site Location Plan

For official use only Person ID Rep ID

RESPONSE FORM CONSULTATION ON THE PROPOSED MAIN MODIFICATIONS TO THE TOWER HAMLETS LOCAL PLAN

For official use only

Person ID

Rep ID

Please use this form if you wish to comment on the main modifications.

This form has two parts:

Part A – Personal details

Part B – Your representations

If your comments relate to more than one main modification, you will need to complete part B

of this form for each representation.

Please make your representation using the response form and refer to the accompanying guidance

notes before completing it.

A schedule of the main modifications to the Local Plan and associated documents can be found on our

website at www.towerhamlets.gov.uk/local plan. Hard copies can also be obtained from the town hall

(Mulberry Place, Clove Crescent, E14 2BG) and the borough’s libraries and idea stores.

We can only accept representations that refer to a change detailed in the main modifications schedule.

Please do not repeat or re-submit previous representations on the Local Plan as these have already

been considered as part of the examination process.

We want to know whether you think the main modifications are sound and/or legally compliant (as

defined in the accompanying guidance note).

Comments can also be made on:

the addendum to the Integrated Impact Assessment (which investigates the potential impacts of the main modifications against a range of social, economic and environmental objectives); and

the proposed changes to the Policies Map (as a consequence of the main modifications set out in the schedule).

All forms must be returned to us no later than 5pm on 9 May 2019, either via:

email ([email protected]) or

post (FREEPOST, Main Modification Consultation, Strategic Planning, London Borough of Tower

Hamlets, PO BOX 55739, London, E14 1BY).

Please note: the consultation on the main modifications has now been extended two extra days

(9 May) to take account of the Easter bank holidays on Friday 19 April 2019 and Monday 22

April 2019.


Notification of subsequent stages of the Local Plan

3. Please specify whether you wish to be notified of any of the following:

Yes No

Publication of the inspector’s recommendations (final report) Yes

Adoption of the Local Plan Yes


Dated: 08/05/2019




Person ID

Rep ID


























April 2019.




Yes No




Part B - Your representations

This section will need to be completed for each representation you make.

Please note – comments are restricted to the proposed main modifications only and should not

relate to any other aspect (e.g. site or policy) of the Tower Hamlets Local Plan.

Comments can also be made on the proposed changes to the Policies Map (as a consequence

of the main modifications set out in the schedule). The Policies Map illustrates the policies and

proposals of the Local Plan.

The main modifications have also been subject to an independent appraisal (known as the

Integrated Impact Assessment). The results are set out in the addendum to the Integrated

Impact Assessment.

4. To which main modification to the submitted Local Plan does this representation relate?

Main modification reference MM 3

5. Please provide comments below on the main modifications to the submitted Local Plan. Please be as precise as possible. Do you consider this main modification to be sound? Is the main modification legally compliant?

Whilst we support strongly, in principle, flexibility in relation to developer contributions and viability, we do not consider Emerging Policy D.SG5 Modifications 2. and 2.46 to be sufficient in relation to flexibility on all sites. These modifications state that for allocated sites only, the policies set out in the DLP may be applied flexibly to ensure that sites are viable and deliverable. To increase the delivery of homes in the borough and bring Policy D.SG5 further in line with Adopted London Plan Policy 3.11 (Affordable Housing Targets), we propose to extend this flexible approach to all sites within the borough through the following alterations:

6. Please set out what change(s) you consider necessary to make the main modification sound. It will be helpful if you are able to put forward suggested revised wording for any policy or text. Please be as precise as possible.

2.46 Part 2 seeks to provide flexibility in the determination of planning applications relating to all sites to ensure that development is viable and can be delivered during the plan period, having regard to the provision of infrastructure and other site specific requirements.




Person ID

Rep ID


























April 2019.




Yes No













Impact Assessment.




We consider Emerging Policy D.H6 (2.) (Tall Buildings) of the DLP, which requires development of tall buildings to be directed towards designated Tall Building Zones (TBZs), to be restrictive and inflexible. This policy would have the effect of unnessecarily constraining development and design on sites outside of these zones, and would therefore not be effective in its delivery. Given the prescriptive nature of Emerging Policy D.H6, it could be held that it is not consistent with Draft London Plan Policy D6 (Optimising Housing Density) which seeks to optimise the use of land through a design led approach with regard to context, connectivity, infrastructure and capacity. Given this, we welcome the proposed addition to Emerging Policy D.H6 of (3.) which indicates support in the siting of tall buildings outside of TBZs and proposes a design led approach to mitigating the impact of tall building which makes D.H6 compliant with Draft London Plan Policy D6. Whilst in principle, as stated we support this addition, for greater clarity on circumstances when support for such developments will be given, we propose the following alteration to D.H6 3.


a.be located in areas with high levels of public transport accessibility (PTAL 4-6) as defined in London Plan Policy 3.4 (Optimising Housing Potential)




Person ID

Rep ID


























April 2019.


Unfortunately, we cannot accept late responses.

Your comments (once registered) will be made publicly available online at the end of the consultation period. However, your personal details (apart from your name or the organisation you represent) will not be disclosed.

If you wish to provide more than one representation, please only fill in part A once. For each representation, please complete an individual copy of part B.

Data protection statement

The information collected will be processed in accordance with the Data Protection Act 1998.

Information provided in this form will not be kept confidential. Copies of representations will be made

available for public inspection, and cannot be treated as confidential. They will also be available to

view on our website once the consultation period has closed.


1. Personal details 2. Agent’s details (if applicable)

Title

First name

Last name

Job title (where relevant)

Organisation (where relevant)

Address line 1 Finsbury Circus House

Address line 2 15 Finsbury Circus

Address line 3 London

Address line 4

Postcode

Telephone number

Email address




Yes No













Impact Assessment.




As previously stated, we strongly advocate a flexible approach to DLP Policy when considering the viability and deliverability of sites within the borough. In line with this, we welcome DLP Policy S.H1 (Meeting Housing Needs) parts 2. a. ii) and iii) which state affordable housing delivery within the borough will be subject to viability, as well the proposed modification to Paragraph 4.18 of removing ‘in exceptional circumstances’ when describing sites where lower levels of affordable housing may be acceptable. In addition to S.H1 we propose a modification which provides greater clarity to Part a) iv) and makes it consistent with the rest of the policy:


iv)requiring a mix of rented and intermediate affordable tenures to meet the full range of housing needs (subject to viability)




Person ID

Rep ID


























April 2019.




Yes No













Impact Assessment.




Policy D.ES7 (A Zero Carbon Borough) Part 2 seeks maximum energy efficiency on all ‘major’ non-residential developments within the borough by requiring that those developments meet or exceed a BREEAM rating of ‘excellent’. In order to make this policy effective in its delivery and compliant with the Adopted and Emerging London Plan as well as with the Town and Country Planning (Development Management Procedure) Order 2015, being key regional and national documents which define ‘major development’ as that which exceeds 1,000 square metres, we propose the following alterations to D.ES7:


a.All new non-residential development over 1,000 square metres floorspace must meet or exceed BREEAM ‘excellent’ rating.

b.All non-residential refurbishment of existing buildings and conversions over 1,000 square metres floorspace (gross) must meet at least BREEAM non-domestic refurbishment ‘excellent’rating.

7. Declaration:


I/we understand that all comments submitted will be considered in line with this consultation, and

that my comments will be made publicly available and may be identifiable to my name /

organisation

Signed:

Dated: 08/05/2019

new tower hamlets draft local plan 2031 · 2.for all sites the policies set out in this plan may be...

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