Ailsa Wharf

Affordable Housing Statement

On behalf of London River Lea One Limited
Update August 2023
© 2023 Nathaniel Lichfield & Partners Limited (trading as “Lichfields”), All Rights Reserved, is registered in England, no. 2778116.
Registered office at The Minster Building, 21 Mincing Lane, London EC3R 7AG.
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Ailsa Wharf : Affordable Housing Statement

Contents
1.0 Introduction 3
2.0 Planning Policy Context 4
3.0 Previously Approved Scheme 7
4.0 The Proposed Development and Affordable Housing 8

Proposed Affordable Housing Quantum and Tenure Split Affordable 8

Housing by Phase 9

Locations of Affordable Homes 11

Comparison with Extant Planning Permission 12

5.0 Summary and Conclusion 14

Appendices
Appendix 1 LBTH pre-application response dated 25th May 2021

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List of Figures
Figure 1. Phasing strategy for the scheme

Figure 2 : Locations of the affordable housing units within the proposed

development

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1.0 Introduction
1.1 This amended Affordable Housing Statement has been prepared by Lichfields, on behalf of
London RiverLea One (the ‘applicant’) to accompany the planning application for the
redevelopment of land at Ailsa Wharf, within the London Borough of Tower Hamlets. The
amendment addresses a minor discrepancy identified in the dwelling mix post submission. It
has been updated for completeness.

1.2 The applicant is proposing to redevelop the site for a housing-led mixed-use development.
Planning permission is sought for the following:

“Redevelopment of the Site for a mixed-use scheme providing 952 residential units; 1,548 sqm
GIA commercial floorspace (Use Class E) within a series of buildings up to 23 storeys; the
creation of a new access road and the realignment of Ailsa Street; the provision of
safeguarded land for a bridge landing; the provision of cycle and car parking spaces; and
associated Site-wide landscaping and public realm works.”

1.3 Further detail on the proposed uses within the scheme are provide in the accompanying Design
and Access Statement.

1.4 The site is approximately 2.39 hectares in size and was previously occupied by various industrial
uses. The proposed development is located within an allocated site of residential-led
redevelopment within the Lower Lea Valley Opportunity Area, the Poplar Riverside Housing
zone and the LBTH Local Plan 2020.

1.5 The proposed scheme will provide 285 affordable housing units, including 176 affordable rent
units and 109 intermediate/shared ownership units, which will comprise 36% affordable homes
by habitable room with an affordable rent: intermediate split of 66:34.

1.6 The revised scheme will provide an affordable housing uplift of 53 affordable units (143
habitable rooms) compared to the extant scheme, planning application ref. PA/18/03461.

1.7 The scheme provides an entry point for home ownership for the local residents in Poplar and
provides a significant affordable housing contribution towards the Tower Hamlets housing
targets.

1.8 The proposed development meets the criteria for the Mayor of London’s fast track approach to
affordable housing set out in London Plan Policy H5. Both Tower Hamlets and the GLA have
confirmed that the scheme can follow the fast-track route during pre-application engagement.
As such, the application does not include a viability assessment.

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2.0 Planning Policy Context

2.1 This section sets out the relevant planning policy context in relation to the provision of
affordable housing within the London Borough of Tower Hamlets (LBTH). This section provides
an overview of the planning background relating to the Application. Additional reference should
be made to the Planning Practice Guidance, The London Plan (2021), the Mayor’s Housing SPG
and the London Borough of Tower Hamlets Local Plan (2020).

2.2 A more detailed review of the planning policy context is provided in the accompanying Planning
Statement.

2.3 This affordable housing strategy has been set in accordance with the National and Regional
policy guidance and has regard to the following:
• The London Plan (March 2021)
• Mayor’s Affordable Housing and Viability Supplementary Guidance (August 2017)
• London Borough of Tower Hamlets Local Plan (2020)

Planning Practice Guidance

2.4 The Planning Practice Guidance (PPG) on Planning Obligations (Paragraph 002 Reference ID:
23b-002-20190901) states:

“Planning obligations assist in mitigating the impact of unacceptable development to make it

acceptable in planning terms. Planning obligations may only constitute a reason for granting
planning permission if they meet the tests that they are necessary to make the development
acceptable in planning terms, directly related to the development, and fairly and reasonably
related in scale and kind.”

2.5 Furthermore, the Obligations PPG indicates:

“Planning obligations should not be sought where there are clearly not necessary to make the
development acceptable in planning terms; and planning obligations must be justified and
evidenced. Where affordable housing contributions are sought; planning obligations should
not prevent the development from going forward.”

2.6 The Obligations PPG also indicates (Paragraph: 010 Reference ID: 23b-010-20190315), where
the local authorities place affordable housing obligations or tariff style contributions to
infrastructure:

“… they should be flexible in their requirements. The policy should be clear that such planning
obligations will take into account specific site circumstances.”

The London Plan (2021)

2.7 The London Plan (2021) is the Regional Spatial Strategy for Greater London. It sets out a
framework to co-ordinate and integrate the economic, environmental, transport and social
considerations for the next 20-23 years.

2.8 The London Plan builds upon many of the policies set out in the National Planning Policy
Framework, providing emphasis on achieving development in the most suitable locations in a
sustainable manner, by prioritising development upon previously developed land and
brownfield sites and making the most efficient use of the land available.

2.9 The London Plan sets out the Good Growth strategy to re-balance development in London
towards more genuinely affordable homes for working Londoners to buy and rent. The strategy

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aims to create a more socially integrated and sustainable city, where there is growth and new
opportunities are provided. Planning for ‘Good Growth’ ensures right number of homes and
higher levels of affordable housing will take advantage of London’s growth to rebalance the
housing market.

2.10 The affordable housing policy within the London Plan (2021) is as follows:
• Policy H4 Delivering affordable housing, provides a strategic target of 50% of all new homes
delivered across London to be genuinely affordable.
• Policy H5 threshold approach to applications: the threshold level of affordable housing on
gross residential development is initially set at a minimum of 35%. To follow the fast-track
route, applications must meet the affordable housing threshold and be consistent with the
relevant tenure split highlighted in policy H6.
• Policy H6 affordable housing tenure: a minimum of 30% low cost rented homes as either
affordable rent or social rent, a minimum of 30% intermediate products which meet the
definition of genuinely affordable housing, including London living rent and shared
ownership, the remaining 40% is to be determined by the borough as low cost rented homes
or intermediate products.
• Policy SD1 Opportunity Areas: this policy ensures opportunity areas fully realise their
growth and regeneration potential, the mayor will ensure that opportunity areas maximise
the delivery of affordable housing and create mixed and inclusive communities.

Affordable Housing and Viability SPG (2017)

2.11 The SPG provides guidance on a range of policies including housing supply, residential density,
housing standards, build to rent developments, student accommodation and viability appraisals.

2.12 The SPG reiterates the London Plan’s approach to tenure; which should be broken down as
follows:
• 30% low cost rent (social or affordable rent) with rent set at levels the LPA considers
genuinely affordable;
• 30% as intermediate products, London Living rent and/or shared ownership; and
• The remaining 40% is to be determined by the LPA.

LBTH Local Plan (2020)

2.13 The LBTH Local Plan provides guidance on development in the borough until 2031.

2.14 Tower Hamlets has played a significant role in the social, political and economic history of
London, over the years becoming a focal point for London and the UK, as a key trading route
and today has grown into a world class hub for financial, technological and creative industries.
However, this growth has brought on stresses, the borough still has high levels of deprivation
and with an ever-growing population- a strain on local services. Providing enough new homes,
including affordable housing, is a key challenge for the borough to meet the rising demands of
housing.

2.15 The Local Plan Policy D.H2 outlines the affordable housing guidance within the document. The
policy states:
• Development should seek to maximise the provision of affordable housing by providing a
70% rented and 30% intermediate products split.
• The development is required to maximise the number of affordable housing on site, with
calculations of these units based on the number of habitable rooms.

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• Developments should provide an appropriate mix of unit sizes, including larger family
homes, in accordance with the local housing needs, as outlined in the table below.
Table 1: LBTH required Residential Mix

Unit size Market Intermediate Affordable rented

1 bed 30% 15% 25%
2 bed 50% 40% 30%
3 bed 20% 45% 30%
4 bed 15%

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3.0 Previously Approved Scheme

3.1 The site has previously received planning permission for a residential led scheme (the scheme
known as ‘Ailsa Wharf’) which was approved in October 2018. The approved scheme comprised
a housing-led mixed use proposal of 785 residential units and 2,954sqm commercial floorspace
(ref. PA/16/02692).

3.2 An application for minor material amendments to planning permission PA/16/02692 was
submitted in respect to minor amendments to the internal layout and external elevations of
Blocks IJKL, EFGH and M and to the footprint and layout of all basements within the
application site. Additionally, minor amendments were also proposed to the residential tenure
mix by block (around 35% affordable units (by habitable room) was retained), and the detailed
design of the landscape and public realm. The application under s73 was approved in January
2020.

3.3 The extant Section 73 permission (ref.PA/18/03461/S) continued to provide 785 residential
units and a consistent number of affordable housing units. Within the extant permission, 35% of
the accommodation is affordable by habitable room with a low-cost rent: intermediate split of
69:31. The low cost rented element of the extant permission was broken down into 50% London
Affordable Rent and 50% Tower Hamlets Living Rent. The approved scheme provides 232
affordable units; including 152 affordable rented units (491 habitable rooms) and 80
intermediate units (224 habitable rooms). The permission remained in accordance with the
Council’s affordable housing policy. The table below shows the approved housing mix for the
previous permission by tenure and unit size:
Table 2: Residential mix of the extant scheme (ref.PA/18/03461/S)

Studio 1 2 3 4 Total
Affordable - 38 63 34 17 152
Rent
Intermediate - 38 20 22 - 80
Private 73 219 181 76 4 553
Total 73 295 264 132 21 785

3.4 The s73 application including this mix, affordable housing quantum and tenure split was
approved by the council in January 2020. It sets a benchmark for the amended and enhanced
development now proposed at the site.

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4.0 The Proposed Development and Affordable

Housing
Proposed Affordable Housing Quantum and Tenure Split
4.1 This section of the report provides a detailed review of the affordable housing quantum and
tenure split proposed as part of the new application to redevelop Ailsa Wharf. The scheme
proposes a total of 952 residential units which will make a valuable contribution to acute local
and strategic housing needs. 285 of the new homes proposed will be delivered as affordable
housing.

4.2 LBTH Local Plan policy D.H2 states that affordable housing provision must be calculated by
using habitable rooms as a primary measure for the mix of affordable housing provided within a
development. In accordance with policy, the scheme will provide 36% affordable homes by
habitable room, exceeding the minimum threshold of 35% as identified in the London Plan
(2021) Policy H5. The scheme proposes the affordable housing delivery of 897 habitable rooms,
split 66:34 in favour of affordable rent (broken down into 50% LAR and 50% Tower Hamlets
Living Rent) with the remaining being intermediate shared ownership units. This is an uplift in
terms of the quantum of affordable homes and low cost rented homes compared to the extant
permission, as discussed further below.

4.3 In the pre-application discussions Tower Hamlets’ officers confirmed that a development
providing an affordable housing quantum exceeding 35% and with the proposed tenure split
would be eligible for the fast-track route, given the extant residential-led mixed use planning
permission (Appendix 1 LBTH pre-application response dated 25th May 2021). The proposed
development complies with these requirements (36% affordable housing and seeks a 66:34
tenure split.

4.4 The table below provides an outline of the proposed number of units and habitable rooms
provided within the entire scheme.

4.5 Following the submission of the scheme in January 2022, there was a minor update to the
housing mix and slight variations in numbers in comparison the assessment of the affordable
Housing Statement submitted to support the application.

4.6 The updates to the scheme have been reviewed by the GLA at Stage 1 review. There is only one
minor change since, with the movement of one two-bed unit shifting from market to
intermediate provision. This change is considered a minor but positive shift, providing an
additional affordable unit.

4.7 Updates to the originally submitted Affordable Housing Statement have been submitted for
completeness. The changes are minimal and do not impact the assessment of the affordable
housing provision, nor affect the quantum of delivery. Overall, the changes provide an
additional five habitable rooms, increasing the number of family units provided within the
scheme, as favoured by the LBTH. The changes are considered de minimis and do not impact
the proportion of affordable housing delivered.

4.8 The updates to the scheme have been addressed within this updated report.

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Table 3: Site Wide Residential Mix

Market Affordable rent Intermediate Total

Hab Hab Hab Hab

Unit size Unit Room Unit Room Unit Room Unit Room
Studio 139 139 0 0 0 0 139 139
1 bedroom 195 390 24 48 55 110 274 548
2 bedroom 238 714 75 225 23 69 336 1008
3 bedroom 91 364 67 268 28 112 186 744
4 bedroom 4 20 10 50 3 15 17 85
Total 667 1627(65%) 176 591(23%) 109 306(12%) 952 2524

Affordable Housing by Phase

4.9 The tables below highlight the residential mix that will be provided in each of the development
phases. Phase 1 comprises the courtyard blocks. Phase 2 comprises Building M on the west of
the site and the riverside blocks on the east of the site. For further details, please see the
Planning Statement. The majority of the affordable homes are located within Phase 1. This
element of the scheme has been implemented and this affordable housing is already being
delivered on site. Phase 2 will follow with a complementary mix of homes, including further
affordable housing.
Table 4: Phase 1 Residential Mix

Market Affordable rent Intermediate Total

Hab Hab Hab Hab
Unit size Unit Room Unit Room Unit Room Unit Room
Studio 24 24 0 0 0 0 24 24
1 bedroom 64 128 24 48 24 48 112 224
2 bedroom 38 114 40 120 22 66 100 300
3 bedroom 18 72 37 148 21 84 76 304
4 bedroom 4 20 10 50 3 15 17 85
Total 148 358 111 366 70 213 329 937

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Table 5: Phase 2 Residential Mix

Market Affordable rent Intermediate Total

Hab Hab Hab Hab
Unit size Unit Room Unit Room Unit Room Unit Room

Studio 115 115 0 0 0 0 115 115

1 bedroom 131 262 0 0 31 62 162 324

2 bedroom 200 600 35 105 1 3 236 708

3 bedroom 73 292 30 120 7 28 110 440

4 bedroom 0 0 0 0 0 0 0 0

Total 519 1269 65 225 39 93 623 1587

4.10 The changes provided within the phased elements of the scheme, were largely picked up during
the consultation period and addressed within the stage 1 report. The overall mix and tenure of
the scheme remains largely unchanged.

4.11 The table below outlines the overall mix of dwelling sizes in comparison with LBTH Local Plan
policy D.H2. The mix is expressed as a percentage. The development addresses the
requirements of LBTH Local Plan policy D.H2 for the low cost rented and private
accommodation and includes an appropriate size mix within the intermediate component of the
scheme. Within the Market Sale and Affordable Rent units, there is an over provision of 3+
bedrooms units in comparison to policy requirements. There is also an overprovision of
2bedroom units within the affordable rent component. The family housing provision within all
tenures is a material improvement on the extant permission. The schemes response to policy
and the improved mix compared to the earlier extant permission constitute benefits associated
with the amended, enhanced development.
Table 6: Residential Mix compared to LBTH Local Plan policy D.H2

1 bedroom % 2 bedroom % 3+ bedrooms %

Policy Proposed
Tenure Policy Proposed Policy Proposed (3-4 beds) (3-4 beds)

Market 30 33 50 44 20 23

Affordable Rent 25 8 30 38 45 54

Intermediate 15 36 40 22 45 42

4.12 The LBTH Local Plan states there is an increased need for larger family sized dwellings within
the borough. In response, the overall residential mix provides a high level of 3-4 bed units. This
is particularly focused in the affordable rent and market provision. The mix of intermediate
homes includes a higher proportion of smaller 1 bedroom units which are affordable and
accessible, alongside a good level of family sized intermediate homes.

4.13 The majority of affordable housing and most family homes are being delivered within phase 1
which has already been implemented on site. This initiating phase of development will provide
181 affordable units (579 habitable rooms). Phase 2 will also include family housing and
affordable homes, but with a mix which reflects the character and form of phase 2 (104
affordable units; 318 habitable rooms). Officers noted during pre-application discussions that

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the early delivery of affordable housing and the family provision within phase 1 was welcomed
and it was acknowledged that phase 2 of the development will include a higher proportion of
smaller private units. Officers stated at the LBTH pre-application meeting held on 25 May 2021
that:

“…it is not feasible or financially viable for phase 2 to fully balance the mix within phase 1.
Furthermore, the tower arrangement and typology is better suited to smaller households and
it would not therefore be appropriate to provide high proportions of family-sized
accommodation in this Phase, explaining the reduced number of large dwellings are presented
in phase 2”.

Location of Affordable Homes

4.14 Figure 1, below, illustrates the phasing strategy for the scheme. Figure 2 shows the tenure within
each component building.
Figure 1. Phasing strategy for the scheme

Figure 2. Locations of the affordable housing units within the proposed development

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4.15 The location of the proposed affordable housing remains largely consistent with the distribution
of tenures in the extant consent (ref.PA/18/03461/S).

4.16 Building M accommodates much of the proposed affordable housing, as was the case with the
previous permission. The building provides high quality residential accommodation. All units
will meet or exceed space standards, all will have a good outlook and good daylight and sunlight
levels, and all will have access to generous dedicated amenity space. The current amended
iteration of Block M has improved in design to the extant approved scheme
(ref.PA/18/03461/S). The building’s lower more sensitive floors will accommodate workspace,
meaning that residential units are only located at the third storey and above; resulting in
benefits of reduced noise and improvements in air quality. Additionally, changes in the design of
this block ensures high residential quality with regard to acoustic and air quality factors. All of
the proposed affordable units in this block have been assessed against noise and overheating
and is confirmed that the units comply with policy requirements and building regulation
requirements, please see the Environmental Statement chapters for further detail. The proposed
development has a tenure blind design, with all residential units of the same standard in terms
of floorspace, amenity space and residential quality. The units will benefit from shared
entrances and all homes will have equitable access to the proposed communal amenity space,
play space and public realm. The scheme will provide an integrated, balanced and equitable
residential mix.

Comparison with extant planning permission

4.17 The development exceeds the local and strategic policy requirement of 35% of affordable
housing, on a habitable room basis. This is a key benefit of the scheme. Table 7 provides a
comparison of the residential mix provided in the extant S73 scheme and within the proposed
development.
Table 7: Comparison of Residential Mix between extant S73 and proposed development

Tenure Market Affordable Rent Intermediate Total

Extant S73 Proposed Extant S73 Proposed Extant S73 Proposed Extant S73 Proposed

Unit (Hab Unit (Hab Unit (Hab Unit (Hab Unit (Hab Unit (Hab Unit (Hab Unit (Hab
Unit size Room) Room) Room) Room) Room) Room) Room) Room)

Studio 73 (73) 139 (139) 0 (0) 0(0) 0 (0) 0 (0) 73 (73) 139 (139)

1 bedroom 219 (438) 195 (390) 38 (76) 24 (48) 38 (76) 55 (110) 295 (590) 274 (548)

2 bedroom 181 (543) 238 (714) 58 (174) 75 (225) 20 (60) 23 (69) 259 (777) 336 (1008)

3 bedroom 76 (304) 91 (364) 39 (156) 67 (268) 22 (88) 28 (112) 137 (548) 186 (744)

4 bedroom 4 (20) 4 (20) 17 (85) 10 (50) 0 (0) 3 (15) 21 (105) 17 (85)

553 (1378) 667 (1627) 152 (491) 176 (591) 80 (224) 109 (306)
Total (66%) (64%) (23%) (24%) (11%) (12%) 785 (2093) 952 (2524)

4.18 The proposed development exceeds the quantum of affordable housing, affordable rented
homes and intermediate homes approved under the extant planning permission. Given the
optimisation and uplift in homes achieved through the new application, the development
delivers an increase in affordable housing of 53 units compared to the extant permission (24

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additional affordable rented homes and 29 additional intermediate homes compared to the
extant permission). This uplift in affordable housing is a significant benefit associated with the
new enhanced planning application. The increase in affordable homes will make a significant
contribution towards acute local and strategic need for affordable housing.

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5.0 Summary and Conclusion

5.1 The proposed scheme comprises the redevelopment of the site at Ailsa Wharf for a housing-led
mixed-use development. The description of development is as follows:

Redevelopment of the Site for a mixed-use scheme providing 952 residential units; 1,548 sqm
GIA commercial floorspace (Use Class E) within a series of buildings up to 23 storeys; the
creation of a new access road and the realignment of Ailsa Street; the provision of
safeguarded land for a bridge landing; the provision of cycle and car parking spaces; and
associated Site-wide landscaping and public realm works.

5.2 In accordance with LBTH’s affordable housing policy, the application proposes 36% affordable
housing by habitable room (897 out of 2524 habitable rooms), exceeding the minimum
threshold provision as outlined in the London Plan policy H5. The proposed low cost rented:
intermediate tenure split is 66:34 The development qualifies for the fast-track affordable
housing route, as confirmed during pre-application discussions with Officers from Tower
Hamlets and the GLA.

5.3 The development provides a comparable proportionate level of affordable housing to that
approved under the extant permission for the site’s redevelopment (ref.PA/18/03461/S).
However, owing to the optimisation and uplift in homes being delivered under the current
amended proposals, this equates to an additional 53 affordable homes compared to the extant
permission.

5.4 The affordable housing quantum, tenure split and dwelling mix proposed have been derived
having regard to the benchmarks set by the extant permission at the site and the fact that phase
1 of the scheme has already been implemented (and hence its affordable homes are already
being delivered), as well as policy objectives and the site’s character and context. This is a high-
quality mixed tenure development which will contribute meaningfully towards the acute need
for affordable homes in Tower Hamlets and across London. It will contribute towards the
development of a genuinely mixed and balanced sustainable new community in this area of
Poplar Riverside; complementing adjacent developments and the wider estate regeneration
proposals emerging at the Aberfeldy and Teviot Estates.

5.5 The development will yield a wide range of benefits for this area of Tower Hamlets, the
affordable housing quantum and mix is supported by relevant local and strategic policy and the
scheme will make a significant contribution to Tower Hamlets’ affordable housing targets. The
benefits of the proposed affordable housing at Ailsa Wharf militate in support of the planning
application.

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Appendix 1 LBTH pre-application

response dated 25th May 2021

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Briefing Note
Our ref 62545/01/BK/JFi
Date 25 May 2021
To Aleksandra Milentijevic, LBTH
From Jonathan Finch

Subject Ailsa Wharf 2020 - pre-application response and clarifications

1.0 Purpose of note

1.1 The following note comprises a short response to the LBTH pre-application advice note of 6 May
2021. We are pleased to see that the response overall, provides strong support for the revised
proposals for Ailsa Wharf, noting the positive design development in response to extensive pre-
application discussions with officers to date. We look forward to presenting further updated
material at the forthcoming and final pre-application meeting of 7 June 2021 which will address
a number of key comments outlined with the advice.

1.2 However, on review, there are certain comments within the advice that are considered
inconsistent with previous officer advice, or are based on now outdated, earlier submissions and
the remainder of this note seeks to provide clarification on these matters.

2.0 Urban design

Scale, massing and layout

2.1 We note the that officers are now supportive of the proposed scale and massing of the riverside
towers and their relationship with Islay Wharf and acknowledge that further increases in height
will not be supported.

2.2 The strong support for the revised landscape-led design approach is welcomed, as is the
acknowledgement that the new consolidated riverside park will not only deliver significant
benefits for future residents of the Ailsa Wharf development but will provide a strategic offer for
the wider Poplar Riverside area.

2.3 It is clear that officers now require a detailed ground floor use strategy to demonstrate the
successful relationship between the proposed building forms and the surrounding public realm
and key routes to create safe and attractive spaces. Further detail on the play space strategy and
how this considers vehicle movements throughout the site is also required. This next level of
detail will be provided at the forthcoming and final pre-application meeting of 7 June 2021.

Residential design/outlook

2.4 The pre-application feedback comments on the orientation of the towers and considers that this
creates a number of north-facing single aspect units. The outlook was discussed with Officers at
the workshop of 11 March 2021 and a specific follow-up study was issued to officers on 12 March
2021 for comment. Appendix A to this note contains an updated study demonstrating that no
north facing single aspect units will be provided, as per the guidance in the Mayor’s Housing
SPG and London Plan. We welcome confirmation from LBTH following the issue of this update
that this issue is now resolved.

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19750921v1 Registered office at The Minster Building, 21 Mincing Lane, London EC3R 7AG
3.0 Housing and affordable housing

Housing mix

3.1 The pre-application feedback helpfully acknowledges the constraints and limitations to revising
the housing mix in Phase 1 and this follows the feedback provided by LBTH Housing officers at
the Housing Workshop of 11 March 2021. However, the recent note suggests that Phase 2 should
be recalibrated to achieve a site wide policy compliant residential mix. This is at odds with the
clear feedback provided during the workshop which suggested that best efforts should be made
to deliver a betterment to the consented housing mix and move positively towards the target mix
with a focus on family homes in the scheme’s low cost rented component.

3.2 The design has been developed and the residential mix interrogated further on the basis of the
previous feedback and a betterment has been achieved which will be presented to officers at the
next pre-application meeting. However, it is not feasible or financially viable for Phase 2 to fully
balance the mix within Phase 1, as was previously acknowledged by officers. Furthermore, the
tower arrangement and typology is better suited to smaller households and it would not
therefore be appropriate to provide high proportions of family-sized accommodation in this
Phase.

Affordable housing and viability

3.3 Similarly, it was suggested at the previous workshop that the proposed 35% affordable housing
offer would be eligible for the Fast Track Route, given the extant residential-led, mixed use
planning permission. However, the latest feedback considers that the 50% industrial/public
land threshold is applicable here which contradicts the previous advice. The note separately
indicates that a lower threshold may be acceptable given the existence of the extant permission
but further details on the compliance of the overall housing mix is required.

3.4 Following the GLA pre-application advice which proposes that the implementation of the extant
planning permission will be a material consideration when establishing the FtR threshold
(35%), can LBTH provide further clarify its position with regards to viability testing for the
revised proposals. The current advice is not clear and appears to contradict previous officer
advice on the matter. This ambiguity should be clarified prior to submission.

3.5 As set out, the intention is to implement the extant planning permission imminently and prior
to the determination of the revised planning application triggering the change of use from
industrial land to residential. On this basis and in accordance with the GLA Practice Note the
appropriate FtR threshold should be 35% affordable housing and the application should follow
the FTR.

Building M

3.6 On other matters, the environmental challenges of the most western portion of the site where
Building M is located are fully acknowledged and further detail on the mitigation strategies that
will be delivered to ensure a satisfactory living environment will be achieved here will be
provided in support of the future application.

4.0 Parking strategy

4.1 We note the proposed reduction of car parking and overall basement parking strategy is strongly
supported and the servicing strategy is considered an improvement over the consented scheme.

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 As requested, further details will be provided to LBTH when they become available and as part
of the forthcoming pre-application meeting and subsequent planning application submission.

4.2 For clarification, the accessible parking strategy seeks to deliver 3% blue badge provision at the
outset, with the remaining 7% to be delivered as required through a monitoring and
management strategy in accordance with London Plan policy.

5.0 Energy strategy

5.1 The comments provided by energy officers are referring to a now outdated energy strategy,
which was updated following the LBTH Energy Workshop (17 March 2021) and presented at the
GLA pre-application meeting of 30 March 2021. Following advice from LBTH officers, the
strategy was amended to omit the use of CHP to meet peak loads, and now comprises a dual
ASHP and high efficiency gas boiler solution. The ASHP will be the primary technology to meet
the base heat load, with the gas boilers used to top up the system to meet peak demand.

5.2 It is therefore requested that LBTH energy officers update and reissue these comments to reflect
the current strategy.

6.0 Planning Strategy

6.1 The pre-application feedback remains somewhat ambiguous on LBTH’s preferred planning
application strategy in light of the potential non-compliance of the fixed Phase 1 blocks when
incorporated into a site-wide planning application assessed against current Local Plan policy. It
should however be noted that the proposals have been refined to broadly limit such areas of
marginal departure to housing mix and overheating and would in any case deliver a betterment
over the consented position in these policy areas.

6.2 LBTH officers do however acknowledge that a site-wide application would be beneficial with
regards to a comprehensive assessment of a number of planning considerations such as housing
mix, amenity/play space and EIA. The benefits of a single s106 are also acknowledged, as is the
early delivery of AH in Phase 1.

6.3 Notwithstanding the above, it is our strong view that the wider reaching planning benefits of
increased housing and affordable housing delivery (expedited by the early delivery of Phase 1),
provision of a well-activated strategic riverside park and overall design enhancements far
outweigh the limited compliance issues. The delivery of these benefits should not therefore be
stifled by the commitment to imminently deliver Phase 1 of the extant permission (which
includes a significant quantum of affordable housing) and it is therefore the intention of the
applicant to submit the proposals on the basis of a robust and well-evidenced site wide planning
application as previously presented in detail to LBTH.

7.0 Next steps

7.1 As set out above, we welcome updated comments on those mattes raised with regards to
residential outlook (see Appendix A), housing mix, viability matters and the proposed energy
strategy.

7.2 Further information on those areas requested within the pre-application note will be provided at
the next pre-application meeting and/or as part of the subsequent planning application
submission.

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