Consultation statement

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South Quay Masterplan
Supplementary Planning Document (SPD)
Consultation Statement
October 2015
Regulation 12(a) of the Town and Country Planning (Local Planning) (England) Regulations 2012
1
1.0
INTRODUCTION
Role of the Consultation Statement
1.1 In accordance with Regulation 12(a) of the Town and Country Planning (Local
Planning) (England) Regulations 2012, this Consultation Statement has detailed:
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2.0
the persons the local planning authority consulted when preparing the
supplementary planning document;
a summary of the main issues raised
how those issues have been addressed in the supplementary planning document
CONSULTATION AND ENGAGEMENT APPROACH
Requirements of the Statement of Community Involvement (SCI) (2012) and Town
and Country Planning (Local Planning) (England) Regulations 2012 (“Regulation”)
2.1
The approach to developing and consulting on the SPD was in conformity with the
Council’s SCI. The overarching aim for consultation was to provide an opportunity for
involvement from a wide range of stakeholders including residents, local community
groups, landowners/developers, statutory consultees, and any other individuals or
organisations with an interest in the area. These groups were contacted and
involved at different stages throughout the drafting and formal consultation stages.
Table 1 outlines activities undertaken and persons consulted, which also satisfies
Regulation 12(a.i.) which requires those persons consulted during preparation of the
SPD to be set out.
Engaging the local community and stakeholders
2.2
In undertaking community involvement, the core principles which have governed
the approach to consultation are provided below:
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Appropriate to the level of planning issue and the type of document being
consulted on
From the beginning, giving people the opportunity to shape the documents
and make it their own
A continuous process and not just a one off event
Clear and straightforward by using methods suitable to the communities
being consulted
Planned as a central part of the planning and plan-making process.
How we involved the community and stakeholders
2.3
There are several distinct stages to consultation activities to progress SPDs and
these are set out in Table 1 along with identification of how and where the
community and key stakeholders had the opportunity to get involved.
2.4
Throughout the Masterplan SPD preparation process, a diverse range of
consultation techniques and activities were carried out to ensure an effective and
efficient engagement.
2
2.5
The Council engaged with a number of different audiences throughout the
preliminary (informal) and statutory consultation periods, these are also set out in
Table 1.
2.5
105 people attended the consultation events held by the Council during the
statutory consultation between 5th January and 16th February 2015.
2.6
In addition, over 637 written representations were received from 63 local residents,
businesses, faith and community organisations, statutory consultees,
developers/landowners, and other interested parties.
4.0
REVIEW OF STAGES OF CONSULTATION & ENGAGEMENT PROCESS
Stage 1 – Preliminary (informal) consultation
4.1
A number of key messages emerged out of the preliminary (informal) consultation
stage, including
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4.2
Quality of the public realm
Lack of public open space in the area
Lack of clarity between what is public and private space
Developments not meeting the needs of local people due to overseas purchasers
Need for further social infrastructure (hospitals, doctors, schools and parks) to
address population increase
More sports and social facilities required
Pedestrian access through the area be difficult
The bridge across South Dock needs to be improved
Transport provision needs to be increased as already at capacity
Development benefitting developers rather than local people
Density of development
Build tall buildings elsewhere and not just in the South Quay area
Fear that the Masterplan would have no consideration for local people
Need to consider how family and affordable housing can be successfully delivered
in a high density environment
The key issues and opportunities identified by this preliminary informal
consultation, in addition to evidence base work, then shaped the Draft South Quay
Masterplan SPD which was approved for formal consultation.
Stage 2 – Statutory (formal) consultation
4.3
A summary of key messages from representations received split by subject area is set
out below:
SQ1 – Housing density
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Concern about the impact of high density development on infrastructure
Requesting that density be limited
3
SQ2 – Connections & public spaces
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Need for greater open space
Need for enhanced connectivity especially to the south
Support for additional bridges/bridge capacity
Reservations about the quality of space underneath the DLR
SQ3 – Massing & urban blocks
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Concern about building heights
Illustrative diagrams not being representative of consented schemes
Concern that guidance could be used prescriptively
Consistency with existing policy on height/design
SQ4 – The skyline
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Guidance on respecting the Maritime Greenwich Grand axis welcomed
Requests that the provided view diagram be expanded to show St Anne’s at Poplar
and All Saints at Blackheath
SQ5 – Infrastructure
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Concern about lack of transport capacity
Concern about water/sewerage capacity
Evidence behind table of requirements questioned
Questions as to whether guidance breaches CIL regulations
Introduction/contextual information and other miscellaneous comments
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A number of clarifications and corrections were requested
Requests to clarify the illustrative nature of diagrams
4.4 How the Council considered these comments and other representations made, and
whether amendments were actioned, is set out in Table 2 (Representations received
during statutory consultation and LBTH responses). It also provides information as to
who made each representation.
4.5 The key amendments made to the final version of the SPD compared to the draft
formal consultation version can be viewed in Table 3 (Key amendments to the
supplementary policy guidance within the South Quay Masterplan SPD). These key
changes relate to amendments to the wording of supplementary policy guidance for
clarity to avoid the misinterpretation of guidance as introducing new policy, which is
outside of the remit of a SPD.
4.6 The structure of the document was also reformatted for improved appearance and
presentation of content.
Stage 3 – Adopting the Masterplan
4.5
An Adoption Statement has been prepared in accordance with Regulation 11.2 of the
Town and Country Planning (Local Planning) (England) Regulations 2012.
4
4.6
The final version of the SPD document along with supporting appendices including the
Adoption Statement and this Consultation Statement will be made available to view on
the Council’s website and at the following locations:
LBTH Planning Reception, Tower Hamlets Town Hall, Mulberry Place, 5 Clove
Crescent, London, E14 2BG
Monday - Friday 9am-5pm
Idea Store Canary Wharf, Churchill Place, London, E14 5RB
Monday – Thursday 9am – 9pm, Friday 9am – 6pm, Saturday 9am – 5pm, Sunday
12pm – 6pm
Cubitt Town Library, Strattondale Street, London, E14 3HG
Monday – Wednesday 10am – 6pm, Thursday 10am-8pm, Friday 10am – 6pm,
Saturday 9am – 5pm, Sunday closed.
Local History & Archives Library, 277 Bancroft Road, E1 4DQ
Monday closed, Tuesday 10am-5pm, Wednesday 9am-5pm, Thursday 9am-8pm,
Friday closed, Saturday (first and third Saturday of the month) 9am-5pm, Sunday
closed.
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Table 1 – South Quay Masterplan SPD key consultation activities and events
Method/Type of
Aim/details
Target Groups
Consultation
Stage 1 – Preliminary (Informal) Consultation: March 2014 - September 2014
Involvement and participation before developing a SPD
Masterplan SPD
Raising awareness amongst the Local community
media public notices
community of development of
and publication on
the Masterplan project and
LBTH website
inviting participation
E-Mail and letters
Raising awareness amongst Local community
individuals and organisations in
the area to inform of informal
public consultation events.
Public Drop-in
To introduce and discuss the
The general public
Sessions
aims and objectives of the
Masterplan SPD and seek
comment.
Meeting with elected
Regular engagement with Mayor Elected Members
Members
and Lead Member for Housing
to ascertain community priorities
and
aspirations,
and
engagement with local ward
councillors to ensure community
issues were fed into the
Masterplan SPD.
Internal staff
Engagement with LBTH Council LBTH staff
engagement
service departments including
drop-in sessions and meetings
throughout the process to obtain
guidance and feedback on
respective specialisms
Stakeholder meetings
To engage with some of the key Key stakeholders including:
stakeholders in the area, to
Canal & River Trust, English
ascertain key issues and
Heritage, Environment
aspirations for the Masterplan
Agency, Greater London
and obtain comment, direction
Authority (GLA), Old Royal
and expertise on content
Naval College Greenwich,
Transport for London (TfL),
Registered Providers,
London City Airport and
Thames Water
Landowner and
To engage and update key
Key landowners and
developer meetings
landowners and developers.
developers in the area.
Separate focused meetings with
key landowners to discuss
specific issues relating to the
Masterplan SPD and aspirations
for their sites.
Professional forum
To engage expert opinion from a Professional advisors and
(New London
wide range of built environment
bodies
Architecture)
professionals on future
development of tall buildings in
London
One-to-one meetings
The Masterplan project team Interested individuals, groups
has offered bespoke one to and organisations
meetings
throughout
the
informal consultation period
Location and Date
East End Life/LBTH
website
 August 2014
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August 2014
Jack Dash House
 August 28th 2014
 September 4th 2014
LBTH Town Hall
 Between March and
December 2014
LBTH Town Hall
 Between March and
October 2014
LBTH Town Hall
 Between March and
October 2014
LBTH Town Hall
 Informal surgeries in
April 2014
 Pre-application
discussions
throughout 2014
Building Centre
(Tottenham Court Road)
 24 April 2014
LBTH Town Hall
 March-December
2014
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Stage 2 – Statutory (Formal) Consultation: 5 January 2015 – 16 January 2015 (6 weeks)
Community involvement and participation before adopting a SPD
Method/Type of
Aim/details
Target Groups
Consultation
Masterplan SPD
media public notices
and publication on
LBTH website
Raising awareness amongst the
community of statutory
consultation and events, plus
inviting participation
Local community
E-mails and letters
Raising awareness amongst the
community and subscribers to
the Council’s planning policy
contact list of statutory
consultation and events, plus
inviting participation
To discuss the content of the
Masterplan SPD and invite
comment
Local community, statutory
consultees, other interested
parties
Public Drop-in
Sessions
Date and Location
East End Life/LBTH
website
 December 22nd
2014 and January
19th 2015 (East End
Life)
 December - April
2015 (website)
Letters and e-mails sent
2nd January 2015.
E-mails were also sent
on 16th January
The general public
Jack Dash House
 22nd January 2015
Idea Store Canary
Wharf
 30th January 2015
Alpha Grove Community
Centre
 5th February 2015
Public
Meeting/Presentation
session
Presentation of draft Masterplan
to the general public with
Question and Answers session
The general public
Landowner and
developer forum
To engage with and update key
landowners and developers
Key landowners and
developers in the area.
LBTH Town Hall
 13th February 2015
Statutory environmental
bodies (Environment Agency,
English Heritage, Natural
England) and other
interested stakeholders
LBTH website
 15th September –
October 20th 2014
Interested individuals, groups
and organisations
LBTH Town Hall
 March-December
2014
Council’s Mayor in Cabinet
meeting
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Strategic
Environmental
Assessment Screening
Determination
notification email and
scoping report
consultation
It was identified that the
Masterplan SPD required an
SEA, in accordance with the
requirements of regulation 9(1)
of the Environmental
Assessment of Plans and
Programmes Regulations 2004.
The council was keen to
understand whether consultees
agreed with the proposed scope
of the Strategic Environmental
Assessment, or whether
additional information/
assessment was required
One-to-one meetings
The Masterplan project team
has offered bespoke one to
meetings
throughout
the
informal consultation period
Stage 3 - Adopting the Masterplan: October 2015
Final version of SPD
Briefing the elected Mayor and
with accompanying
Lead Member for Housing on
appendices
the Masterplan SPD
8th October 2015
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Table 2: Representations received during statutory consultation and LBTH responses
Please note that this report aims to present a brief summary of every key point for consideration made within each written representation.
Reference
SQFC1.01
SQFC1.02
SQFC1.03
Representor/
Organisation
Local resident
Local resident
English
Heritage
Summary of the comments
Believes there is an urgent need for a new major open
space immediately south of Marsh Wall between
Millharbour and Mastmaker Road down to Lightermans
Road.
All the existing trees, landscaping and the sculpture at the
junction of Marsh Wall and Millharbour should be retained.
Also highlights need for education and doctors surgeries
and the inadequacy of public transport in immediate area
(DLR running at full capacity was cited).
Welcomes a Masterplan but has several concerns.
Found documents difficult to comprehend and suggests the
Council produces more easily understandable and
accessible information.
Building heights – Welcomes that buildings are to step
down from One Canada Square. However, questions
whether this will be adhered to and understands
developments have been approved or are expected which
exceed this height. Requests explanation as to how the
Masterplan will reflect the true height of buildings.
Density – Concerned about creation of unpleasant urban
environment from large density of buildings of 4+ stories.
Does not want a non-British street scene containing a
concentration of taller buildings as it will spoil Canary Wharf
as an iconic and interesting development and the Isle of
Dogs which is low rise. Discusses effects of wind and
“canyon” effect of tall buildings, and requests consideration
of reducing density of buildings over 10 stories in the
Masterplan.
High street along Marsh Wall – Claims proposal is
“ridiculous and ill thought”. Questions whether team have
studied what makes successful UK high streets, suggesting
they are pedestrianised and where traffic is allowed should
be single file and slow moving. The latter makes Marsh
Wall a terrible choice and any efforts to limit traffic will have
a “catastrophic” impact on those using the island. Suggests
an alternative route such as Mastmaker Terrace to the edge
of South Dock.
Public transport – Public transport is already stretched.
Could not see sufficient modelling and planning for public
transport provision. Questions whether the document can
be called a Masterplan without adequate and detailed
public transport planning within.
Considers area suitable for residential development subject
to appropriate assessment for tall buildings. Supports the
Council’s aim of producing the Masterplan.
While 19th Century Glengall Terrace is excluded from
boundary, recommends further illustration/explanation of
likely impacts on conservation area and setting from
adjacent development and recommends guidance to
mitigate harmful impacts.
South Dock although unlisted must be considered a
heritage asset as “exceptional reminder” of London’s
economic and historic development along with Millwall Inner
Dock and West India Dock. Vital that new development
draws on contribution made by these heritage assets to
enhance the attractiveness of public realm and the leisure
and health opportunities afforded by waterside locations.
Pleased to note inclusion of guidance in respect of skyline
and relationship in views towards Canary Wharf cluster
from General Wolfe statue within the setting of Maritime
Greenwich World Heritage Site. Also welcomes aim of
seeking to define the Maritime Greenwich Grand Axis
through the design of future development. Recommends
reference to development also potentially appearing in
River Prospect views from London Bridge (LVMF 11.B) and
that development will need to demonstrate impact in
relation to associated policies.
Would encourage the Council to formally identify public
house and warehouse at western end of Marsh Wall as
making a positive contribution to local character.
Would recommend formal identification of Glen Terrace and
the setting of Coldharbour Conservation Area, and
undesignated pub/warehouse within Heritage section of
Current Context.
Recommend referring to docks as ‘heritage assets’ rather
than ‘historic environments’ (better reflection of NPPF
policies)
Recommend that wider traffic and transport infrastructure
are coordinated over a wider area and that related
strategies are signposted in the Masterplan.
Council's response
Action - Proposed
changes
Part of Millennium Quarter site allocation and
potential delivery through submitted application
No action required
Can be managed through Development Management
process
Education and health facilities addressed by SQ1,
SQ5 and existing adopted policy. Transport to be
addressed by forthcoming Isle of Dogs OAPF
Concern noted
The document has been written in the clearest
language possible and where technical terms are
used they have in most cases been explained.
No action required
No action required
No action required
No action required
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
There are many successful non-pedestrianised
retail/high street environments across London and
UK.
No action required
Transport to be addressed by forthcoming Isle of
Dogs OAPF as a wider strategic consideration
No action required
Support noted
No action required
Managed through adopted Local Plan policies
No action required
Heritage assets acknowledged in Masterplan
No action required
Assessed in accordance with adopted Local Plan
policy
No action required
Outside remit of Masterplan.
No action required
Cannot allocate through SPD
No action required
Text amended in final version
Actioned
Transport to be addressed by forthcoming Isle of
Dogs OAPF as a wider strategic consideration
No action required
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Would recommend that design of new open space (p32)
should state “sustain the significance of, and seek
opportunities to enhance, designated and local heritage
assets” rather than “acknowledge local heritage assets” as
currently doesn’t imply a positive strategy for historic
environment.
Recommend inclusion of a design requirement for new
blocks to contribute positively to skyline and townscape
through 360 degrees.
Suggest it may be beneficial for new development to model
the impact on sunlight and demonstrate how massing will
maximise the opportunity for sunlight and provision of open
space (p35)
Important to recognise pressure for development south of
Masterplan area in context of impact on WHS buffer zone.
Important to consider impact of wider pressure on visual
layering. (p45)
Suggest an urban design strategy for ensuring a
coordinated and cohesive approach to streets is prepared
which could include a public realm strategy for enhancing
appearance and quality of public realm at Marsh Wall and
on docksides.
SEA – Would draw attention to comments in respect of
impact on Coldharbour Conservation Area and Glen
Terrace.
SQFC1.04
Dr Pieter van
der Merwe
MBE DL on
behalf of Royal
Museum
Greenwich
SQFC1.05
Local resident
Text amended in final version
Actioned
This is covered by existing adopted policy
No action required
Already a requirement through the Development
Management process
No action required
To be considered in development of Isle of Dogs
OAPF
No action required
This is being developed by TfL in conjunction with
LBTH
No action required
Noted
No action required
Would value opportunity to discuss further with the Council.
The Masterplan team is keen to continue to engage
with stakeholders
No action required
Incorrect spelling of separation and coherent
One example of each word incorrect - text amended
in final version
Actioned
Would like to know details about regeneration on
Barkantine Estate, which of four estates would start first
More content about disabled facilities
Some contents could be in plain English for consultation
(official document being more sophisticated)
SQFC1.06
SQFC1.07
Local resident
Local resident
More greenery along riverside
Improved docksides are an aspiration of the
Masterplan
No action required
Feels planners not driving the developers when the Council
has capacity and ability to insist on schools at the outset;
not allowing more development until facilities are built and
in place.
Addressed by SQ1, SQ5 and existing adopted policy
No action required
Planning permissions should not be granted until water and
sewerage problems are resolved
Shouldn’t the Section 106 money be spent to mitigate
impact on the Isle of Dogs
South Quay DLR cannot cope with rise in users implied by
development
Simpler or explanatory English should be used – example
of ‘Pneumatic waste collection system’ given as example
Local resident
Local resident
Building heights are assessed in accordance with the
Local Plan policies through development
management process
This is a driver behind development of the
Masterplan
Managed through Development Management
process
Section 106/CIL receipts are managed according to
adopted procedures
Matter for enforcement
Transport to be addressed by forthcoming Isle of
Dogs OAPF as a wider strategic consideration
The document has been written in the clearest
language possible and where technical terms are
used they have in most cases been explained.
No action required
No action required
No action required
No action required
No action required
No action required
No action required
Greater consideration should be given to high densities of
development in excess of many forms of guidance. Risk
going to appeal.
To be managed through Development Management
process
No action required
Should be more accountability of how S106 is spent locally
The Council publishes details of spending quarterly
on its website
No action required
Addressed by SQ1, SQ5 and existing adopted policy
No action required
Support noted
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
Underestimation and insufficient focus on education
provision. More needs to be done in wider Isle of Dogs
area to encourage all sorts of school providers.
Draft is well written and structured
Questions ability of developers to go outside of the plan and
build as high and dense as possible, for example Ballymore
at Lincoln Plaza
The three Millharbour sites should have no more than one
high rise section of development on each and they should
not be right next to existing ones (plans show a high rise
section around 60ft from Pan Peninsula.
Supportive of green areas highlighted
SQFC1.10
No action required
No action required
Roadways are not wide enough to take increased traffic;
delivery vehicles park on double yellow lines outside Tesco
SQFC1.09
No action required
Addressed through SQ2
Not enough open space or playspace
Local resident
No action required
Cycling routes need to be improved
Buildings are much too high
SQFC1.08
Managed through Development Management
process
Managed through adopted Local Plan policies
The document has been written in the clearest
language possible and where technical terms are
used they have in most cases been explained.
Transport and water are a concern for residents
Plan looks scarce on detail for schools, health, transport
etc., which requires serious planning as population could
rise from 3,000 to 30-60,000 in fifteen years
The way Canary Wharf manage their estate should be
replicated in terms of managing shop fronts and green
spaces. Highlights issue of little around South Quay DLR
and cleanliness improving quality of life.
Diagrams are indicative only and this is being better
reflected in final version
Support noted
Concern noted. To be considered in development of
Isle of Dogs OAPF
Local infrastructure such as schools and health is
addressed by SQ5. Wider strategic infrastructure
such as transport to be addressed by the GLA's Isle
of Dogs OAPF
Managed through Development Management
process
No action required
Actioned - text amended
to emphasise indicative
nature of diagrams
No action required
No action required
No action required
No action required
9
SQFC1.11
Greater
London
Authority
Strongly support the principles embedded in document.
Podium-plinth typology is sound and should be actively
promoted.
Massing allows for sufficient pragmatism by not being
overly prescriptive
Delivery of high quality public realm and active and legible
routes is critical and should remain a priority.
SPD should be seen as a first step in production of an
Opportunity Area Planning Framework for the wider Isle of
Dogs
Dock crossings are critical to improve connections and
relieve pressure on the DLR; it is vital that the Council and
GLA work together to secure their delivery as a priority.
SQFC1.12
SQFC1.13
SQFC1.14
Local resident
Local resident
Local resident
Concerned that plans to widen the road outside of Glen
Terrace would result in it becoming a less safe area,
increase traffic noise and impact on parking of which there
is already a shortage.
Worried about pressure on existing facilities (GPs, dentists
and shops) which are already at high capacity.
Concerned about the scale of the project with development
creating a greater population density issue.
Does not want the A1206 widened as current levels of
pollution are already too high, and will make it an even
more dangerous and busy road.
Building heights – Podium and plinth components refined
by relationship to streets, but there is no limit on the height
of the taller elements.
Masterplan seems to suggest normal density limits can be
exceeded with little justification.
Feels the guidance on stepping down from One Canada
Square is too vague. Would like to see the Masterplan
specify the maximum height of buildings at each
development site and for those to conform to steppingdown guideline
Provision of high-speed broadband to residences and
businesses – Limited mention of utilities infrastructure.
Current broadband provision to South Quay is poor. Would
like to see reference to encouraging BT to provide fibre-tothe-premises infrastructure and encourage developers to
liaise with BT to include such infrastructure within their
buildings.
Local resident
No action required
Support noted
No action required
Support noted
No action required
Support noted
No action required
Council intends to progress on that basis
No action required
Work being taken forward by TfL as part of Isle of
Dogs OAPF
No action required
Managed through Development Management
process
No action required
Addressed by SQ1, SQ5 and existing adopted policy
No action required
Concern noted. This is a driver for development of
the SPD
No action required
To be considered in development of Isle of Dogs
OAPF
No action required
Building heights are assessed in accordance with the
Local Plan policies through development
management process
SQ1 requires robust demonstration of mitigation of
impacts
No action required
No action required
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
To be addressed by Isle of Dogs OAPF
No action required
Welcomes and supports the principles outlined in the
Masterplan.
Support noted
No action required
A rebalancing of landuse with an emphasis on meeting
housing demand is welcomed, but the Masterplan must
allow for flexibility and avoid over-prescription in the event
of changing market or social and economic conditions
Landuse principles for the area to include nonresidential uses have been established through the
Millennium Quarter and Marsh Wall East site
allocations within the adopted Managing
Development Document (2013)
No action required
Can be managed through Development Management
process
No action required
Commercial uses are supported in Masterplan area.
Tenure/dwelling mix in line with Local Plan policies.
No action required
Securing benefits for the wider community is already
referenced
No action required
Noted
No action required
Need for improved connectivity, enhanced public realm and
coherent hierarchy in built environment endorsed
Support noted
No action required
Masterplan must allow flexibility in density for good design
and juxtaposition with Canary Wharf.
Managed in accordance with Local Plan policies and
development management process
No action required
Noted
No action required
Occupation of units not a planning matter
No action required
Support noted
No action required
Managed through Development Management
process
No action required
Managed through Development Management
process
No action required
Active frontages are promoted in Masterplan
No action required
Improvement to existing bridge capacity is welcomed.
Support noted
No action required
Maximum public access should be made to dock frontages,
but notes South Dock is less attractive for outdoor uses due
to northerly aspect.
Activating docksides is an aspiration of the
Masterplan
No action required
Important to ensure estate management with public realm
and facilities maintained; much of area currently suffers
neglect.
Need for family accommodation and services are limited in
South Quay, with current population statistics cited. Places
emphasis on need for vibrant convenience shopping,
eateries and service support.
Crèche/primary school facilities are important but suggests
evidence shows that affordable and family accommodation
is better located in less dense environments. Suggests
regeneration benefits should be extended into new and
existing neighbouring communities.
Need for joint public/private partnership should be
acknowledged and nurtured.
SQFC1.15
Support noted
Suggested that development consultancy advice be
provided to Design Advisory Panel and RP Panel.
Developers should be encouraged to address need to
integrate owner-occupier, private rent and social rented
accommodation and look for new funding and crosssubsidy models with RPs.
Principles of enhancing connections from the south to
Canary Wharf are endorsed.
For non-residential frontages allowances should be made
for innovative individual site design, internal connections
and public spaces.
‘Blight’ of empty linear retail and service frontages should
be avoided. Not all principle walkways will be suitable for
such activities and demand may be limited.
Argues for café/retail courtyards or podiums woven into
new developments.
10
Permanent moorings and water-borne business users must
be controlled to avoid conflict and safeguard amenity and
quality of the public realm.
Managed through Development Management
process
No action required
Text amended in final version
Text amended
Noted; this is the aspiration of the Masterplan and will
be delivered on a site by site basis
No action required
Managed through Development Management
process
No action required
Final version has put increased emphasis on
indicative nature of diagrams
Text/diagram
amendments
Text amended in final version
Actioned
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Maritime Greenwich grand axis should be taken into
account only insofar as development proposals intrude
above existing structures on alignment.
Heights assessed in accordance with adopted Local
Plan policy
No action required
Priority should be placed on footbridge link improvements to
Canary Wharf.
This is an aspiration of the Masterplan
No action required
Marsh Wall is an ‘easy win’ for public realm action.
Support noted
No action required
Support noted
No action required
The Masterplan team is keen to continue to engage
with stakeholders
No action required
Identified by Millennium Quarter Masterplan and can
be further considered as part of Isle of Dogs OAPF
No action required
Can be managed through Development Management
process
No action required
Provision can be managed through Development
Management process
No action required
Support noted
No action required
Figure 4.1 amended for final version
No action required
Assessed in accordance with adopted Local Plan
policy
No action required
Recommend the plan includes a transverse section St
Anne’s – All Saints (also showing relative contours of
Docklands and Greenwich Parks) of existing buildings on
grand axis to set a framework limiting the height for any
future tall buildings.
Figure 4.1 amended for final version
No action required
Feel it would be helpful to provide an interpretation of
building height recommended for each line along contour
lines, giving a stepping down of building heights from east
to west to east and north to south plus avoiding a ‘table-top’
block effect when seen from Wolfe.
Assessed in accordance with adopted Local Plan
policy
No action required
Would be helpful to have the line of the Grand Axis on both
Fig VI vision map and Fig 3.1.
Amended for final version
No action required
Would be helpful to have display showing all developments
in the Masterplan as was shown at public events.
Not possible as document will be static whereas such
a document would require updating
No action required
Feels Masterplan should be approved without delay
Welcomes holistic approach to height and massing; is
desirable to allow some flexibility concerning exact
placement of buildings at various sites.
Welcomes importance given to respecting the Grand Axis
sight line.
Support noted
No action required
Support noted
No action required
Support noted
No action required
Would be useful to include development site map from Fig
1.2 of SEA.
Not possible as document will be static whereas such
a document would require updating
No action required
Boundary of Sites 12/13 not accurately represented – would
be useful to treat as one area
Site map will not be included in final document
No action required
Text amended in final version
Actioned
Support noted
No action required
Support noted
No action required
Amended for final version
No action required
NY link to DLR space is tenuous
Development blocks within the area are generally large –
focus on creating meaningful public space within innovative
development schemes.
The Masterplan should not constrain good architecture,
innovation and sound development practice through
formulaic approach.
Site owners and developers should not be constrained in
determining appropriate site content and mix meeting
market demand – flexibility is required to enable inclusion of
commercial uses.
Admirals Way might be replaced by ‘Waterside Estate’
(current recognised name).
Comprehensive redevelopment of Admirals Way wouldn’t
require retention of existing access, so this should not be
taken as a constraint as it appears in Figure 3.1
Potential to use the Council’s powers in land assembly will
be welcomed (as last resort)
Recommends a regular Masterplan development forum
between site owners, representatives and developers.
Given scale of proposed development would expect more
proposals for the provision of accessible green and open
spaces. Natural England considers the Masterplan area
could benefit from enhanced green infrastructure provision
and would encourage the incorporation of this into the plan.
SQFC1.16
SQFC1.17
SQFC1.18
SQFC1.19
Natural
England
Friends of
Greenwich
Park
Richard A.
Cowan on
behalf of Sof
tware Systems
& Services
Limi ted
The
Greenwich
Society
Supportive of inclusion of green roofs but advice some
types such as sedum matting have limited biodiversity
value. Encourage consideration of bespoke solutions
based on needs of wildlife specific to sites and area.
Health benefits of natural green spaces are emphasised,
which should be of at least 2ha in size and not more than
300m walk from home.
Welcome the inclusion of SQ4. Plan acknowledges and
reflects issues made by Greenwich Amenity Societies.
Figure 4.1 does not extend sufficiently far to the south to
enable a sight “cone” to be shown from avenue’s
intersection and ask that this be expanded to show All
Saints Church from the extent of the view with that
intersection.
Would welcome specific guidance on ceiling height within
cone, equating to between 10-15 stories depending on
base height of floors.
Admiral Estate more commonly referenced as ‘The
Waterside Estate’
Believes the Council is right to hold as last resort exercise
of powers for land assembly
Notes and welcomes Policy SQ4
Suggest the line of the axis might be an advantage to
diagrams shown on p19/34.
11
Believe the Masterplan should make more positive
statement on guidance as to how heights of tall buildings
might be managed to fulfil the guidelines through firmer
specific guidelines or ‘framing’ the Grand Axis ensuring all
development in the frame remain lower so the Axis is
marked by a ‘dip’ in the heights of buildings in the ‘frame’.
Suggested the graphic on p44 might include a narrow cone
of vision representing the view from that point following the
line of trees to either side of view towards General Wolfe
statue – though noted this view is mentioned specifically on
p43 of the document.
Heights assessed in accordance with adopted Local
Plan policy
No action required
Additional diagram has been included in final version
Diagram added
Diagrams in Masterplan are indicative only, so would
not accurately reflect schemes coming forward
No action required
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
Support noted
No action required
Strongly object to prescriptive nature of proposed policy
SQ3 as does not necessarily result in most appropriate
development form for a given site, citing Meridian Gate on
which 70% of site provided as open space achieved
through a design response tailored to individual site.
Requests this section of SPD to be edited to allow for wide
range of development forms to come forward that are most
appropriate for the immediate site context.
Indicative nature of diagrams and text emphasised
for final version
Text amended
Inconsistency in level of detail between car parking and
cycle parking – believes there should be consistent level of
detail.
Parking provision managed through existing Local
Plan policies
No action required
No mention of unloading spaces which slows traffic
considerably around Tesco stores.
This is an enforcement issue
No action required
Would be helpful to show land ownership on cross-sections
on p29/30. Unclear how road could be widened to have
traffic four across.
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Is impossible to identify where Fig 2.6 would be. Crucial as
significant footfall at Discovery Dock as forms key passage
from DLR station to Canary Wharf which will remain a key
thoroughfare.
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Welcomes document relying on Maritime Greenwich World
Heritage Site Management Plan – Third Review – 2014 but
regrets this not being referenced in list of production
information on p5.
Support noted and amendment made to final version
No action required
Would appreciate if the scope of Fig 4.1 could be extended
to include the junction of Blackheath Avenue and Great
Cross Avenue and extend as far south as All Saints Church
Blackheath
Amended for final version
No action required
Should be some corresponding explanation on contour
lines and suggested height of development on Fig. 4.1
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
Would be helpful to include a similar viewing cone as 4.1
from Blackheath/Great Cross Avenue intersection.
Additional diagram has been included in final version
Diagram added
Heights assessed in accordance with adopted Local
Plan policy
No action required
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
Diagrams are indicative only, established/consented
developments are subject to change
No action required
Client is supportive of ambition to activate the external
edges of the site and supports improvement to dockside
walkway and new pedestrian and cycle movement.
Support noted
No action required
Client is not supportive of suggested restrictions on built
form and considers the Masterplan should be amended to
remove proposed restriction on development and ability of
South Quay to respond to government’s growth agenda.
Built form is indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Believes the Masterplan does not meet brief of government
guidance as introduces new policy and site allocations,
duplicates existing policies and is inconsistent with adopted
plans for growth.
No duplications, new policy or site allocations.
Accords with existing adopted Local Plan
No action required
Believes stakeholder engagement process has been flawed
as LA has not had meaningful engagement with landowners
in development of the Masterplan and has therefore ignored
the extensive development experience of those upon whom
the Council relies for delivery, and built little consensus.
The Council is satisfied it has undertaken sufficient
detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Statement for full details of the consultation activities
undertaken.
No action required
Suggest a graphic might be included to illustrate how
Masterplan’s aims with respect to tall buildings might
appear from the viewing points in the WHS.
Would be helpful if a graphic showed montage of all
developments consented and proposed across Isle of Dogs
and this be used to inform building height policy.
MPHL supports SQ2. Care should be taken to ensure
conjoined spaces have a consistent language and palette of
materials.
SQFC1.20
SQFC1.21
SQFC1.22
SQFC1.23
DP9 on behalf
of Meridian
Property
Holdings Ltd.
Local resident
Greenwich
Conservation
Group
GVA on behalf
of client with
interest in
Ensign House
Believes a transverse section running north/south to cover
Masterplan area and key viewing points in WHS would be
useful and would relate to height of development as
suggested in Fig 3.1
Essential that development in South Quay terminates no
higher than 47m AOD for Wolfe statue to be read
unobstructed against an open sky.
Would be useful to information in Fig 3.1 could be
supplemented with an indication of how suggested massing
might be read as seen from south. Would also be
worthwhile including outlines of established developments
in Canary Wharf area and consented/current applications.
12
The Masterplan recognises the unique opportunity to
deliver growth; management relates to securing
benefits for the community through coordinated
development proposals and managing impacts. This
is set out in the document
No action required
It is considered these provide useful context
No action required
Final version has put increased emphasis on
indicative nature of diagrams
No action required
Massing in Masterplan is inconsistent with decisions of
Strategic Development Committee. Suggests Masterplan is
introducing policy ‘through the back door’ by seeking to
constrain landowners ability to adopt a particular urban
design approach that would have been acceptable in the
context of the adopted plan.
Massing is illustrative only
No action required
Building heights are unambitious in the context of adopted
policy and physical setting of the site. Masterplan cannot
introduce significant constraints on development without
proper independent examination.
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
Document seeks to manage rather than facilitate growth.
Placemaking principles are unnecessary as duplicate
adopted policy.
Vision map introduces arbitrary controls on building height
without robust evidential base. These should be on site by
site basis with consideration to particular attributes of given
sites.
SQ2e is unduly prescriptive regarding set-back at dock
edges and should be considered on site by site basis.
Introduce tall building annotations on Ensign House site or
make clear Vision Map V1 is illustrative
Remove references to specific building heights in key to
Vision map
Amend SQ3 guidance to define in the supportive text the
intended meaning of the word ‘reflecting’ to make clear that
a scheme that adopts a different urban approach to that
suggested in the Masterplan but is consistent with the
ambition of the adopted plan, has regard to the broad
principles of the masterplan and better delivers against the
growth agenda, can expect to be supported by officers.
No action required
No action required
No action required
Amended for final draft
No action required
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Content appropriate for SPD though some revision to
text
Text/diagram
amendments
Content appropriate for SPD though some revision to
text
No action required
Relevant for sites in Masterplan area
No action required
Amended in final draft
No action required
Amended in final draft
No action required
Point noted
No action required
Further round of consultation on revised draft Masterplan
should be allowed.
It is not considered that further consultation is
required, as amendments made in response to
formal consultation representations do not materially
alter the document
No action required
CIT are supportive of ambition to activate the external
edges of site, and the improvement of the dockside
walkway and new pedestrian and cycle movement.
Support noted
No action required
Client is not supportive of suggested restrictions on built
form and considers the Masterplan should be amended to
remove proposed restriction on development and ability of
South Quay to respond to government’s growth agenda.
Content appropriate for SPD though some revision to
text
Text/diagram
amendments
Believes the Masterplan does not meet brief of government
guidance as introduces new policy and site allocations,
duplicates existing policies and is inconsistent with adopted
plans for growth.
No duplications, new policy or site allocations.
Accords with existing adopted Local Plan
No action required
Believes stakeholder engagement process has been flawed
as LA has not had meaningful engagement with landowners
in development of the Masterplan and has therefore ignored
the extensive development experience of those upon whom
the Council relies for delivery, and built little consensus.
The Council is satisfied it has undertaken sufficient
detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Statement for full details of the consultation activities
undertaken.
No action required
Prescriptive guidance governing cross section of streets
and composition of hybrid blocks should be removed or
identified as ‘illustrative’.
Detailed guidance to SQ3. 2 and 3 should be removed as
‘hybrid’ block is unlikely to deliver an optimum townscape
response in each case.
SQ4 should not introduce new townscape considerations
when assessing the view from Greenwich as sufficient
guidelines exist in LVM framework.
Inappropriate for Masterplan to seek to introduce distinct
materials palette along Grand Axis when majority are not in
Masterplan area.
Definition of ‘Net Residential Developable Area’ is at odds
with Mayor’s Housing SPG definition of ‘Net Residential
Area’.
References made to discounting site area in the context of
land ownership, overlooking distances, the DLR and the
provision of public open spaces should be removed,
particularly given the significance attached by the Borough
to the value of the spaces beneath the DLR through their
intention to adopt many of these areas within Principal
Public Open Spaces.
Believes the Masterplan should begin by defining the
opportunity for infrastructure delivery and should then
define capacity for growth based on maximum infrastructure
option.
SQFC1.24
No action required
Can be managed on a site by site basis through
Development Management process
Adjust the wording of the ‘guidance notes’ to remove and
reference to ‘requiring’ particular approaches which is
tantamount to introducing new policy.
GVA on behalf
of CIT
Developments
Limited
Will be managed through Development Management
process
Final version has put increased emphasis on
indicative nature of diagrams
Final version has put increased emphasis on
indicative nature of diagrams
13
Document seeks to manage rather than facilitate growth.
The Masterplan recognises the unique opportunity to
deliver growth; management relates to securing
benefits for the community through coordinated
development proposals and managing impacts. This
is set out in the document
No action required
Placemaking principles are unnecessary as duplicate
adopted policy.
It is considered these provide useful context
No action required
Massing in Masterplan is inconsistent with decisions of
Strategic Development Committee. Suggests Masterplan is
introducing policy ‘through the back door’ by seeking to
constrain landowners ability to adopt a particular urban
design approach that would have been acceptable in the
context of the adopted plan.
No new policy introduced and can be managed on a
site by site basis through Development Management
process
No action required
Building heights are unambitious in the context of adopted
policy and physical setting of the site. Masterplan cannot
introduce significant constraints on development without
proper independent examination.
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
SQ2e is unduly prescriptive regarding set-back at dock
edges and should be considered on site by site basis.
Refers to SQ2.1f. Noted; will be managed through
development management process
No action required
Introduce tall building annotations on Quay House site or
make clear Vision Map V1 is illustrative
Final version has put increased emphasis on
indicative nature of diagrams
No action required
Remove references to specific building heights in key to
Vision map
Final version has put increased emphasis on
indicative nature of diagrams
No action required
Amend SQ3 guidance to define in the supportive text the
intended meaning of the word ‘reflecting’ to make clear that
a scheme that adopts a different urban approach to that
suggested in the Masterplan but is consistent with the
ambition of the adopted plan, has regard to the broad
principles of the masterplan and better delivers against the
growth agenda, can expect to be supported by officers.
Managed on site by site basis through Development
Management process
No action required
Adjust the wording of the ‘guidance notes’ to remove and
reference to ‘requiring’ particular approaches which is
tantamount to introducing new policy.
Amended for final draft
Text/diagram
amendments
Prescriptive guidance governing cross section of streets
and composition of hybrid blocks should be removed or
identified as ‘illustrative’.
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Detailed guidance to SQ3. 2 and 3 should be removed as
‘hybrid’ block is unlikely to deliver an optimum townscape
response in each case.
Indicative only and can be managed on a site by site
basis through the development management process
No action required
Provides further clarification
No action required
Relevant for sites in Masterplan area
No action required
Amended in final draft
No action required
Point noted
No action required
Further round of consultation on revised draft Masterplan
should be allowed.
It is not considered that further consultation is
required, as amendments made in response to
formal consultation representations do not materially
alter the document
No action required
No objection to incorporating open space into general area
of client’s sites but requirement to provide suitable vehicular
movement to sites and neighbouring developments needs
to be taken into account through Masterplan policies.
Diagrams are indicative only
No action required
To bring Jemstock 2 back into beneficial use requires a new
access road. Provision of open space further west than
shown on Vision Map on p19 would not be supported.
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Questions why the LUC scoping report was not amended to
provide a more balanced view – 18 criteria to judge
development were considered.
Masterplan was informed by SEA
No action required
The London Plan does not reference that particular
scenario
No action required
Accompanying guidance to SQ5 sets out that Table 1
is illustrative of the amount of infrastructure required
No action required
Concern noted
No action required
Text amended in final version
Actioned
Support noted
No action required
Objection noted
No action required
London Plan states density guidance is not to be
applied 'mechanistically'
No action required
SQ4 should not introduce new townscape considerations
when assessing the view from Greenwich as sufficient
guidelines exist in LVM framework.
Inappropriate for Masterplan to seek to introduce distinct
materials palette along Grand Axis when majority are not in
Masterplan area.
Definition of ‘Net Residential Developable Area’ is at odds
with Mayor’s Housing SPG definition of ‘Net Residential
Area’.
Believes the Masterplan should begin by defining the
opportunity for infrastructure delivery and should then
define capacity for growth based on maximum infrastructure
option.
SQFC1.25
SQFC1.26
CGMS on
behalf of
Jemstock
Properties
Limited and
Fedamore
Limited
Local resident
SQFC1.27
Local resident
SQFC1.28
Local
residents
Wording of advice on density (London Plan) does not seem
to support every building in a neighbourhood exceeding
density levels
Main concern is not enough weight in Masterplan given to
guidance of LUC and two London Mayors. Are we planning
for development to cease when average for neighbourhood
hits 1,100? If not why does Table 1 not include options for
higher levels of density?
Concerned the Masterplan will become defunct before the
approval process is even complete
Comment on lack of ‘local knowledge’ due to comparison
with High Line for space under DLR.
Writes in support of the Masterplan
Object to adoption of the Masterplan without significant
revision and extended consultation.
Proposals breach London Plan density policy.
14
Tenure and bedroom size mix are not consistent with
London or Local Plan policy and guidance.
Managed by Local Plan policy through development
management process
No action required
Unlikely that development will provide significant family
sized housing or meet affordable housing targets given
build form proposed.
Indicative only and can be managed on a site by site
basis through the development management process
No action required
LBTH can meet its ten year target without a new
development on the scale proposed, based on SHLAA
which does not include significant provision within
Masterplan area.
Noted, though the SHLAA is not prescriptive
No action required
Planning consents set precedent for future permissions.
Effectiveness of Masterplan queried as impact on/from
neighbouring areas not evaluated.
SQFC1.29
SQFC1.30
SQFC1.31
Local resident
Local resident
Local resident
Managed through Development Management
process
Masterplan has guidance on impact on setting of
World Heritage Site in Greenwich. Other impacts
such as transport to be managed through GLA's Isle
of Dogs OAPF
No action required
No action required
Masterplan is not fit for purpose as only piecemeal
guidance
Masterplan forms part of a wider development plan
for the area
No action required
Inconsistencies between infrastructure and densities need
to be reviewed.
Addressed by SQ1, SQ5, existing adopted policy with
wider strategic considerations to be addressed by
Isle of Dogs OAPF
No action required
Plan is inadequate and incomplete in many areas of
infrastructure especially transport. Development should be
designed with good public transport, cycleways and
pedestrian routes including new pedestrian bridges
Transport to be addressed by forthcoming Isle of
Dogs OAPF as a wider strategic consideration.
Pedestrian/cycle routes and bridges addressed by
SQ2
No action required
Impact on all services and utilities is not analysed or
articulated.
Where not articulated within Masterplan to be
considered in development of Isle of Dogs OAPF
No action required
Proposal for public open space and recreational areas is
inadequate in the entire area
Masterplan seeks to address this
No action required
Traffic should be reduced across the Blue Bridge with
speed restrictions to protect and enhance historic area and
pedestrian safety.
To be considered in development of Isle of Dogs
OAPF
No action required
Development should be limited to current capacity of Blue
Bridge, which should remain an opening bridge.
To be considered in development of Isle of Dogs
OAPF
No action required
Request positive and affirmative statements to ensure the
whole of the conservation area is preserved and enhanced.
Current proposals are detrimental.
Managed through adopted Local Plan policies
No action required
Found no mention of additional flood risk assessment and
impact of increased load on existing defences.
Managed through adopted Local Plan policies
No action required
Methodology does not pay attention to impact of adoption of
this Masterplan on neighbours or further afield.
Masterplan has guidance on impact on setting of
World Heritage Site in Greenwich. Other impacts
such as transport to be managed through GLA's Isle
of Dogs OAPF
No action required
Requests an extension of two months for consultation due
to complexity.
The Council is satisfied it has undertaken sufficient
detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Statement for full details of the consultation activities
undertaken.
No action required
Believes proposed development of the printworks is a
terrible idea.
Managed through Development Management
process
No action required
Developments outside of Canary Wharf should not be so
high. Ten floors should be maximum for residential
developments.
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
Local infrastructure is already under excessive strain.
Concern noted. This is a driver for development of
the SPD
No action required
Conditions are already placed on development
requiring developers to address water supply
No action required
This is outlined in the Consultation Statement
No action required
By seeking to develop South Quay the Council is badly
failing residents.
Objection noted
No action required
Can we confirm that the Masterplan will cover water in a
substantive way, by specifying usage guidelines or targets?
Worried it will get a superficial mention and no concrete
metrics will mean it is a worthless gesture which will be
ignored.
Conditions are already placed on development
requiring developers to address water supply, but
wider strategic implication of water supply means it is
to be addressed by Isle of Dogs OAPF
No action required
Plan is incomplete as there is no analysis of a density less
than 1,100
This was already considered within adopted Local
Plan
No action required
No examples of primary schools as part of residential
buildings working satisfactorily. Can foresee there will be
problems mixing schools and residents leading to
embarrassment for the Council. Plan is incomplete without
a proper evaluation of this idea.
Concern noted.
No action required
How sensible is it to consider housing densities delivering
all 10,000 new homes for the Isle of Dogs in South Quay?
SQ1 requires robust demonstration of mitigation of
impacts should this scenario occur
No action required
Water pressure is affected when a new development is
constructed. This must be addressed, and new
developments should not be authorised if nothing can be
done.
Hopes Council will be incorporating resident’s views into
decision making process and act upon warnings given.
15
SQFC1.32
Local resident
To what extent should plan be driven by developers and to
what extent by the London Plan and the planning
department/Council?
Developers are one of a number of stakeholders in
the planning process
No action required
Is the council relying on the profile of the current residents
may be only 10% of the potential new inhabitants. Is the
council relying on the current residents to determine the
makeup of the new developments, or is it planning instead?
Development should comply with the adopted Local
Plan policy requesting at least 35% of units to be
affordable homes. How units are purchased or
occupied is outside the remit of the planning system
No action required
There is a mistake under DLR Open Spaces. It compares
the space underneath the DLR with New York’s High Line.
Misleading as the High Line is now a park with no trains.
Amendment made to wording in final version
No action required
Misprint under DLR Open Spaces. Should say “vibrating
stretch”, not “vibrant stretch”.
No misprint, correct wording presented
No action required
Current Masterplan is positive as takes into account areas
raised, but has some concerns.
Support noted
No action required
There would need to be three footbridges over South Dock.
Third should be under current DLR.
Masterplan seeks to secure additional footbridges
No action required
Needs to be a direct pedestrian route not involving roads
going straight from South Quay to new Crossrail station.
To be considered in development of Isle of Dogs
OAPF
No action required
Marsh Wall needs to be redeveloped into a tunnel in the
central South Quay area, or a series of underpasses but the
former would be better for attractive urban landscaping.
Suggestion noted
No action required
With more work on pedestrian movement and capacity the
Masterplan is workable
Please do not allow parameters for building development to
be exceeded for the wellbeing of the future community.
To be further considered in development of Isle of
Dogs OAPF
Managed through Development Management
process
Disappointed to learn that land interest at Cuba Street had
been allocated largely as a ‘Principal Public Open Space’
thus constraining the development potential of the site.
Indicative only, can be managed through
development management process
No action required
There has been an absence of meaningful engagement as
draft Masterplan developed despite requests to engage.
Ballymore would be able to be more supportive of the
Masterplan if the Masterplan is ‘as flexible as senior officers
imply it is intended to be’.
The Council is satisfied it has undertaken sufficient
detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Strategy and Consultation and Engagement Report
for full details of the consultation activities
undertaken.
No action required
Figure V1 suggests a development diagram that is
inconsistent with the consented scheme. On that basis the
Masterplan should not introduce new policy and the
diagram should show the permitted massing at Arrowhead
Quay and make it clear Figure V1 is illustrative in nature.
Fig V1 is indicative and this has been clarified in
revised draft.
Text amended
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Open space referenced in SQ2
No action required
Supplementary text to SQ2 should provide more detail and
clarity on SQ2.2b to clarify how development will be
required to contribute to the delivery of the defined open
spaces and that such contribution may take the form of
payment in lieu. Masterplan should also make clear the
provision of public open space and education infrastructure
are to be prioritised against other infrastructure
requirements for the Masterplan area, with text suggested.
Text amended in final version
Text amended
Questions the ambition of the Council in allocating Cuba St
site for buildings up to a maximum of ten stories as at odds
with mayor’s foreword that South Quay should be an area
of significant housing growth. Taller elements could be
located within Cuba St site and consider Vision 1 diagram
should be amended.
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Ask for the vision for Cuba St to be adjusted to reflect the
emerging diagram subject to pre-application discussions
and note that Figure V1 is labelled as illustrative.
Final version has put increased emphasis on
indicative nature of diagrams
No action required
Text amended in final version
Text amended
Managed on site by site basis through Development
Management process
No action required
Masterplan should make clear vision diagrams are
illustrative and not prescriptive.
Final version has put increased emphasis on
indicative nature of diagrams
No action required
Definition of hybrid urban blocks should be revised, with
suggestion given.
Noted
No action required
Ask that the Masterplan area is treated as one for the
purpose of affordable housing, with amendment to bullet
point 1 of page 11.
Would be in conflict with adopted policy
No action required
The Masterplan in its current form exceeds the legal
limitations of the scope of SPDs by seeking to allocate land
as open space. Also note there appears to be no
supporting analysis for the identification of Cuba Street as
PPOS.
Principal Public Open Space and Local Open Space should
be clearly defined on p48 of the Masterplan.
SQFC1.33
Ballymore
Ask that supporting text is added to follow guidance note
SQ3.1a to make clear what is meant by ‘reflecting’ to
ensure emerging proposals addressing adopted policy
framework and that have broad regard for ambitions of the
Masterplan and support growth targets will be supported.
SQ3 should recognise where there is potential for higher
density development a commensurate uplift in infrastructure
mitigation contributions will be sought, with a new
paragraph suggested.
No action required
No action required
16
Spelling errors on p4 and p48
SQFC1.34
SQFC1.35
SQFC1.36
Canal & River
Trust
Dennis
Defteros on
behalf of
Millennium
Harbour
Residents
Association
John Biggs
AM
Text amended in final version
Actioned
Identified by Millennium Quarter Masterplan and can
be further considered as part of Isle of Dogs OAPF
No action required
Guidance is indicative only
No action required
The Masterplan team is keen to continue to engage
with stakeholders
No action required
Objection noted
No action required
Guidance is indicative only
No action required
Current wording considered appropriate
No action required
Density must be at lower level proposed (650-1100hr) due
to lack of wide roads and state of infrastructure.
London Plan states density guidance is not to be
applied 'mechanistically'
No action required
High density suggested will impact existing utility issues in
area
Concern noted. To be considered in development of
Isle of Dogs OAPF
No action required
Area on consultation impacts the two road access points to
Isle of Dogs.
Noted
No action required
Aim to reduce car ownership greatly overlooks extreme rise
in delivery vehicle traffic and use of taxis/mini cabs
Managed through the development management
process
No action required
Overdevelopment of area will result in reduced quality of life
for existing and new taxpayers.
If Masterplan is approved it must be followed – no point to
process if developers breach the limits set.
Draft Masterplan remains silent on a number of issues
which will have important consequences for future of area;
it is too generalist and does not offer a vision of the area to
which developers can aspire.
Concern noted. This is a driver for development of
the SPD
The Masterplan will be a material consideration in
planning decisions.
Proposal to locate new bridge in location indicated on
Figure 2.1 presents a number of problems to Canal and
River Trust and would impact the usability of the
waterspace that the Trust owns and manages. Strategically
important in London context as one of only four berths
located above Thames Barrier where ships of around 176m
in length can berth and is in use throughout the year. The
location is not acceptable to the Canal & River Trust.
Acknowledge current footbridge is not fit for purpose and
options for upgrade/replacement need to be explored.
Suggest consideration be given to relocating bridge to the
west which would free space for deep water mooring which
in turn would free space for a potential new bridge from
South Quay Plaza.
Request that the Council engage in dialogue regarding
design of bridge across Millwall Cutting and how it could be
operated.
Would oppose any bridge from Wood Wharf to South Quay
as would render dock unusable by large vessels.
It is noted the area of dockspace to the east of Millwall
Cutting must be passed by all vessels entering the dock via
the lock so additional bridges in that location are impractical
due to navigational requirements.
P31 should acknowledge the role South Dock plays as a
berthing area for large vessels and amended wording for
ninth para is supplied.
No action required
No action required
Objection noted
No action required
Repeatedly refers to importance of high quality design but
not what would constitute it.
Already outlined in existing adopted Local Plan policy
No action required
General principles of SQ3 do not provide developers with
sufficient guidance on the type of aesthetics which would be
appropriate; further design guidance would help to string
together the different developments and create a coherent
sense of place.
Managed through existing Local Plan policies
No action required
Masterplan should offer guidance on pavements, circulating
spaces and access agreements.
Managed through the development management
process
No action required
Council may wish to consider a vision document as
produced by GLA and LAs for Old Oak Common
This will be addressed by the forthcoming Isle of
Dogs OAPF
No action required
Masterplan should be clear that potential for tall buildings
on some sites is not carte blanche acceptance of tall
buildings across the whole area
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Guidance exists on trigger points for EIA.
Infrastructure guided by SQ1, SQ5 and existing
adopted policies
No action required
Section 106/CIL receipts are managed according to
adopted procedures
No action required
Support noted
No action required
Not a planning concern
No action required
Concerned siting of blocks envisioned by masterplan in Fig
3.1 does not represent the best possible configuration for
tall buildings, for example clustering taller buildings in the
centre of development and tapering down moving outwards
which has been successful in Vancouver. Would also
prevent tall buildings on edges being cited as precedents
for taller buildings in neighbouring residential areas as
would create a buffer zone making a transition to different
character and context.
Final Masterplan should make clear that all proposals will
be expected to undertake EIA with analyses of supporting
infrastructure and consent only granted where there is
sufficient infrastructure to support the development.
Concerned about potential funding sources for
infrastructure in light of prohibit on pooling of more than five
S106 contributions. Final document must be clearer about
intentions to pool S106 and need for direct developer
provision of certain infrastructure.
Cautiously welcomes proposal to use space under DLR to
create linear stretch of open space but careful thinking
required to make it welcoming. Work needs to be done on
how suggested uses are delivered and managed.
Final Masterplan should make clear the Council expects
new units to be lived in as homes.
17
The Current Context refers to businesses in South
Quay complimenting and supporting Canary Wharf.
Existing adopted policy (site allocations) sets out a
requirement for commercial floorspace and SME
floorspace as part of development. There are
references to commercial/employment space
throughout document
No action required
This would be carried out for a review of the Council's
Local Plan
No action required
Point noted; the promotion of a 'high street' along
Marsh Wall emphasises 'local shops and services'
No action required
Concern noted. This is a driver for development of
the SPD
No action required
Not a planning concern
No action required
Doesn’t assure that each development will have cultural
diversity and without this developments can become
pockets of religious segregation.
Not a planning concern
No action required
Problems of young people sitting in stairwells smoking
marijuana/cocaine and hiding from or joining dangerous
gangs needs to be addressed before considering increasing
density which will magnify the issues.
Not a planning concern
No action required
Concerned draft SPD is silent on role of employment space
which currently contains a number of employment sites.
Unclear what role the new employment space will play.
Risk is that approach is overly permissive of residential to
detriment of other important functions.
Council should conduct an employment capacity study for
area with findings informing the final version of Masterplan
to provide clarity on employment
Marsh Wall retail stretch should support typical high street
functions serving daily needs such as dry cleaners,
supermarkets, affordable retail, leisure and service
functions and should make clear it should serve new
residents as well as existing residents on Isle of Dogs.
Believes the quality of life in the area will deteriorate
because densities are too high creating increased demand
on public services, infrastructure and social cohesion which
are already over-stretched.
Masterplan assumes all tenants will behave in a socially
acceptable manner.
SQFC1.37
Café Forever
Increase in density will be a social catastrophe and will
exacerbate an already tenuous peace.
By persisting in these plans the Council appears to be
encouraging a form of ‘ethnic cleansing’ as residents have
indicated intentions to leave the area.
Tower blocks proposed are too dense and contrary to
London Plan space guidelines and removes access to
sunlight.
SQFC1.38
Local resident
Water, sewerage and road infrastructure is insufficient. No
planning should be given until Environment Agency
approves and has capacity.
Cannot see any coherent link to the existing brick buildings
on Isle of Dogs. In fact brick is being demolished by
approved tower blocks.
Proposed population of 45-65,000 along Marsh Wall is too
high a density
SQFC1.39
Local resident
Masterplan gives licence for density rates that are too high
for the area and could be devastating in long term.
Suggests slower development strategy to see what
population saturation looks like.
Infrastructure for schools, transport, health services,
shopping, roads and parking can’t support the scheme.
10-30 story buildings along Marsh Wall would create a
more sustainable community than 40-60.
Would strongly urge the Council and GLA to progress
quickly with work on OAPF for wider area to ensure a
comprehensive plan for growth.
Consider it would be more appropriate to define Masterplan
boundary based on key physical features/boundaries that
exist such as roads and perimeter blocks to achieve a more
satisfactory and coherent relationship between individual
sites and surrounding area.
SQFC1.40
Quod on
behalf of One
Housing
Group
Concern noted. The Masterplan's objectives include
securing benefits for the community from
development
Concern noted. The Masterplan's objectives include
securing benefits for the community from
development
No action required
No action required
Masterplan gives guidance on development seeking
to exceed London plan density guidelines
No action required
Point noted.
No action required
Masterplan cannot provide guidance on materials
No action required
Development exceeding density guidance is required
ton robustly demonstrate how it mitigates its impacts
No action required
London Plan states density guidance is not to be
applied 'mechanistically'. The Council cannot
prevent proposals coming forward
No action required
Education, health facilities, shopping, roads and
parking addressed by Masterplan and existing
adopted policy. Transport to be addressed by
forthcoming Isle of Dogs OAPF
Assessed in accordance with adopted Local Plan
policy
No action required
No action required
This work is being progressed
No action required
The Council considers the Masterplan boundary to
be reflective of the developable sites in the area.
No action required
Final version has put increased emphasis on
indicative nature of diagrams
No action required
Securing benefits for the wider community is already
referenced
No action required
Point noted, but it is considered that this may detract
from the clarity of the illustrative diagrams
No action required
This is outlined in Placemaking Principles
No action required
SQ1 – May be appropriate to cross-refer to relevant Core
Strategy evidence base documents which set benchmark
for delivery of social infrastructure.
Contextual information amended for final draft
Text amended
SQ2 – Would be useful for Masterplan to demonstrate how
proposals in terms of routes and public realm/public spaces
link into existing and emerging context as a result of already
consented schemes. No detail on responsibility for open
spaces or long term management is provided.
Diagrams are indicative only
Text amended
Development of routes should consider needs of area as a
whole and provide suitable capacity to accommodate
growth in southern part of Isle of Dogs.
To be addressed by Isle of Dogs OAPF
No action required
Use of footbridges by pedestrians and cyclists needs to be
carefully considered particularly access requirements on
and off for different modes.
Bridge design will consider this
No action required
Believes it would improve clarity of the SPD to provide
further information on schemes now consented or resolved
to be approved, as on vision diagram some taller buildings
are only represented as suitable for ten stories.
Consider the Masterplan should recognise opportunity for
positive links with development outside of its boundary.
Would be helpful for the Vision Map to provide some
contextual mapping to show how Masterplan area relates to
area around it.
Absence of reference to delivering high quality, high-rise,
high-density homes is notable.
18
SQ3 – Consider some parts of policy would be better under
different sections such as approach to social infrastructure
within SQ5.
Concerned that SQ3 has potential requires development to
reflect illustrative massing in Fig 3.1 which has potential to
artificially limit the potential to optimise development in the
Opportunity Area and beyond.
More recognition should be given to role of on-street
parking.
SQ4 – Consider the principle reflects the way it is being
implemented in practice.
SQ5 – Believes wording on p18 does not go far enough and
will not help to ensure sites are available for the physical
delivery of the required social infrastructure. Suggests the
wording is altered to specify that ‘contribute’ could be
physically or financially.
Would be helpful if SQ5 provided a separate heading for
Social Infrastructure as likely to generate demand beyond
school facilities. Supporting text to principle needs to
provide commentary covering all the types of infrastructure
required in Table 1.
Masterplan does not specify what varied levels of density
means.
SQFC1.41
SQFC1.42
Cllr Candida
Ronald
DP9 on behalf
of Canary
Wharf Group
plc
Relates to design considerations so considered
appropriate for SQ3
No action required
Greater clarity can be provided through Isle of Dogs
OAPF
No action required
Parking provision managed through existing Local
Plan policies
No action required
Support noted
No action required
Infrastructure is given greater detail in SQ5. It is
considered the brief Placemaking Principles text on
page 18 is sufficient
No action required
Other social infrastructure also discussed in
document such as open space
No action required
Set out in Placemaking Principles
No action required
Does not identify how conflicting designs will be judged.
Managed on site by site basis through Development
Management process
No action required
Masterplan does not define scale in transition in scale from
surrounding areas. Danger of incoherent environment
without a robust design framework.
Hybrid urban blocks address this, and heights guided
in accordance with adopted Local Plan policy
No action required
Masterplan says little on impact of development on SINC.
Managed through adopted Local Plan policies
No action required
Would welcome clarity on how these public spaces will be
realised and how ongoing maintenance will be funded.
Secured/funded through development management
process
No action required
Have infrastructure requirements been costed and what
impact does this have on viability of developments and
ability to provide social housing.
No current plans, but to be addressed by Isle of Dogs
OAPF
Section 106/CIL receipts are managed according to
adopted procedures. Affordable housing is expected
to be delivered in line with policy requirements
Is there a danger that when work is complete we will find
that transport networks cannot be sufficiently upgraded?
To be managed through Development Management
process
No action required
Are we still in position where we are granting planning
permission to developments that may be unsustainable?
The Council has always addressed developments in
line with national, regional and local policy which has
been scrutinised to ensure sustainable development
No action required
Planning guidance brought forward needs to consider
social, economic and environmental impact across the rest
of Isle of Dogs, not just South Quay
This will be addressed by the Isle of Dogs OAPF
No action required
SPD should not be used to set new strategy or DM policies
for the subject area, but the draft Masterplan appears to do
just that. Review of current Local Plan and OAPF is
appropriate forum
No new policy within Masterplan
No action required
Lack of appropriately robust and sound evidence to inform
the Masterplan
Evidence available
No action required
Residential development at South Quay should not place
greater demands on existing and future infrastructure within
Canary Wharf estate and at Wood Wharf, especially
provision of open spaces, health facilities and school places
To be managed through Development Management
process and developmemnt of Isle of Dogs OAPF
No action required
Masterplan often repeats or goes beyond scope of adopted
policies for area set out within London/Local Plan
Masterplan accords with existing adopted
London/Local Plan
No action required
Flawed approach towards provision of education and other
social/community facilities. Lacks a coordinated approach
to identification of specific sites and locations
Concern noted. SPDs cannot allocate uses to
specific sites; diagrams are indicative
No action required
Should make clear CWG’s role in provision of
new/improved bridge connections – as landowner on which
they land, and should not be required to pay for
new/improved connections (Table 1 p47, Table 2 p51)
Not considered necessary to revise document
No action required
CWG would not support any proposal for delivery of an
additional footbridge to Wood Wharf and has concerns as
to feasibility. Provision already made for landing point on
northern promenade between 50 Bank Street and 10 Upper
Bank Street. Note needed to show routes through open
spaces in Canary Wharf are cycle friendly, but not
designated cycle routes.
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Approach to new and existing employment floorspace and
other services in Masterplan area are inappropriate. No
reference is made to role in supporting Canary Wharf
employers/occupiers or existing/future residents of South
Quay/wider Isle of Dogs. Masterplan should mention more
explicitly that a mix of uses needs to be accommodated.
The Current Context refers to businesses in South
Quay complimenting and supporting Canary Wharf.
Existing adopted policy (site allocations) sets out a
requirement for commercial floorspace and SME
floorspace as part of development. There are
references to commercial/employment space
throughout document
No action required
Replacement of Blue Bridge is not mentioned.
No action required
No action required
19
Proposals for new high street do not consider how it would
relate to the existing retail and town centre hierarchy across
the borough. Considers revision needs to be taken as part
of Local Plan review and would require a Retail Impact
Assessment as part of evidence base.
Existing adopted policy guides the nature of retail
provision within Activity Areas and the relationship
with other centres. The promotion of a 'high street'
within the Masterplan emphasises 'local shops and
services' and the aspiration reflects the desire for
active frontages coming forward along Marsh Wall.
No action required
CWG do not consider an SPD the most appropriate
planning policy document to properly plan the area – should
be taken as part of Local Plan review alongside publication
of OAPF for Isle of Dogs
The Masterplan is the first stage in the production of
the Isle of Dogs OAPF
No action required
Evidence available
No action required
No new policy/allocations have been introduced and
diagrams are indicative though this has been clarified
in final version.
No action required
Would welcome opportunity to discuss further with officers
The Masterplan team is keen to continue to engage
with stakeholders
No action required
Encourage the Council to ensure sufficient flexibility is built
into the Masterplan to facilitate rather than constrain the
opportunity to deliver a new future for Thames Quay.
Final version has put increased emphasis on
indicative nature of diagrams/guidance
Text/diagram
amendments
Support noted
No action required
Reference is made to mix of uses in area.
No action required
Should be made clear the Masterplan is illustrative and that
alternative massing diagrams might be more appropriate.
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
It is premature to prescriptively define the form of
development at Masterplan stage and fixed parameters
should be deleted from the document. Amendments should
feed through to the prescriptive 3D diagrams which seek to
precisely define the form of the proposed blocks. Diagrams
should be marked as ‘illustrative’.
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Final version has put increased emphasis on
indicative nature of diagrams
No action required
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Can be managed on a site by site basis through
Development Management process
No action required
Managed through Development Management
process
No action required
Amended for final draft
No action required
Clarified in final draft
Text amended
No new policy/allocations have been introduced and
diagrams are indicative though this has been clarified
in final version.
No action required
It is considered that 'manual' is not inappropriate
No action required
The Masterplan has been formed on robust evidence
base which is available
No action required
It is considered this is already represented within
existing wording
No action required
First paragraph of Current Context cites recent
development with further reference throughout
section
No action required
The draft only referenced schemes determined at the
time of publication though this has been amended for
final draft
Text amended
Amended in final draft
No action required
SPD not founded on robust evidence base
Limitations of SPD mean it cannot deal with matters of
landuse, infrastructure and delivery, so the Council should
cease preparation of the SPD and work instead to address
deficiencies in evidence base to then inform Local
Plan/OAPF
Support objective to ensure alongside housing growth there
is a plan to ensure appropriate infrastructure can be
provided.
South Quay remains home to a number of businesses and
asks that the Masterplan acknowledges the economic
contribution these businesses can bring.
SQFC1.43
Cherryman on
behalf of
Lycatel
A note should be added to the Vision Map that states that
‘This diagram represents one way in which the masterplan
could be delivered’.
The bracketed heights in the key should be deleted or a
note added to state that ‘Heights are not intended to be
prescriptive but will be considered on a site by site basis in
the context of adopted policy and overall planning benefit’
SQ3 be accompanied by a new paragraph in the
accompanying text explaining the term ‘reflecting’ as used
at SQ3 1 a in order to make clear that schemes that ‘reflect’
the masterplan may depart from the illustrative massing
where the principle of enabling growth can be better served
and where a proposed scheme can otherwise be
demonstrated to be appropriate in massing terms.
In the interests of delivering optimum growth, where greater
densities can be enabled, the masterplan should recognise
that a pro rata’d increase in any contribution to
infrastructure delivery will be expected.
Ask that the Council clarify its proposed basis for
calculation of density as this appears to be inconsistent with
the London Plan.
Ask that the masterplan makes clear that the detailed
sections included are illustrative of broad principles and are
not intended to be prescriptive
Concerned the current draft is overly prescriptive in
approach and does not fulfil the framework role a
Masterplan should have
Argue use of the word ‘manual’ on p7 unhelpful and should
revise to “provide framework supplementary planning and
urban design guidance”.
SQFC1.44
JLL and
Pilbrow &
Partners on
behalf of Far
East
Consortium
International
Limited (FEC)
By failing to provide a robust analysis of local context as
well as key plans and diagrams the Masterplan does not
provide the necessary evidence base for proposed policies.
Document fails to acknowledge the correct national and
strategic context within which South Quay should be placed
– one that does not just manage growth (p10) but promotes
and guides it to respond to local needs.
The Masterplan does not recognise the changing context of
South Quay or its existing context, citing existing
consents/resolutions which have an effect on area and way
in which vision is implemented.
P10/15 refer to ‘recent development proposals’ but exclude
a number of schemes. FEC argue these dramatically
change the character and townscape of the area and the
way the Masterplan will be implemented.
Definition of Net Residential Developable Area doesn’t
accord with Mayor’s definition of Net Residential Site Area.
20
No workshops or consultation events organised with
landowners and developers after publication of the
Masterplan – process therefore not undertaken correctly or
in line with principles of NPPF.
The Council is satisfied it has undertaken sufficient
detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Strategy and Consultation and Engagement Report
for full details of the consultation activities
undertaken.
No action required
Masterplan does not reference the Core Strategy
(placemaking) as introduction.
Contextual information amended for final draft
Text amended
Amendment made to wording in final version
Text amended
Indicative only and can be managed on a site by site
basis through the development management process
Actioned - text amended
to emphasise indicative
nature of diagrams
Amended for final draft
Text/diagram
amendments
Justification is available
No action required
Appropriate for SPD
No action required
Approach to development is not consistent and purpose
must be clarified and supplement existing development plan
policies.
Approach to detailed policies on design solutions is not
viewed as sound when assessed against Government
policies and is in breach of Tender Brief issued in
November 2013 which referred to semi-flexible design
parameters whereas SQ2 & 3 provide no flexibility for
architectural interpretation.
Policies should be reworded so specific requirements i.e.
urban blocks are either deleted or indicated as possible
design solutions. Figures should be labelled as ‘illustrative’
Height, massing, urban blocks not supported or justified by
urban design study or local context analysis.
Requirements for SQ4 are considered overly prescriptive
and should be removed. LVMF provides necessary
guidance.
Greater flexibility needed for SQ5, which may change as
sites come forward.
Object to adoption of the Masterplan without significant
revision and extended consultation.
Proposals breach London Plan density policy.
Tenure and bedroom size mix are not consistent with
London or Local Plan policy and guidance.
No action required
Guidance supports affordable and family housing in
area
No action required
The SHLAA is not prescriptive
No action required
Planning consents set precedent for future permissions.
Managed through the development management
process
No action required
Effectiveness of Masterplan queried as impact on/from
neighbouring areas not evaluated.
Masterplan has guidance on impact on setting of
World Heritage Site in Greenwich. Other impacts
such as transport to be managed through GLA's Isle
of Dogs OAPF
No action required
Masterplan is not fit for purpose as only piecemeal
guidance
Should be used alongside existing adopted policy
and guidance
No action required
High density will provide unsustainable load on existing and
proposed infrastructure. This is in need of review
Addressed by SQ1
No action required
Plan does not adequately address infrastructure especially
transport through the area or impact on services/utilities.
Transport/utilities to be addressed by forthcoming
Isle of Dogs OAPF
No action required
Concerned at absence of discussion on existing flood
defences.
Managed through adopted Local Plan policies
No action required
Traffic should be reduced across the Blue Bridge with
speed restrictions to protect and enhance historic area and
pedestrian safety.
To be considered in development of Isle of Dogs
OAPF
No action required
Traffic should be reduced across Blue Bridge, with speed
restrictions.
To be considered in development of Isle of Dogs
OAPF
No action required
Ask that Council make clear intention to preserve and
enhance the conservation area.
Managed through adopted Local Plan policies
No action required
Important Masterplan is not overly prescriptive.
Text amended in final version
Text amended
SQ2 – Where active frontages are defined, important to
recognise there will also need to be residential entrances
Diagrams are indicative only and this is being better
reflected in final version
Diagrams are indicative only and this is being better
reflected in final version
Any new footbridge needs to be deliverable
SQFC1.46
No action required
No action required
Local
residents
Signet
Planning on
behalf of
Millharbour
LLP
No action required
Assessed in accordance with adopted Local Plan
policy
Unlikely that development will provide significant family
sized housing or meet affordable housing targets given
build form proposed.
LBTH can meet its ten year target without a new
development on the scale proposed, based on SHLAA
which does not include significant provision within
Masterplan area.
SQFC1.45
SQ5 already states "the most up to date
infrastructure requirements"
The Council is satisfied it has undertaken sufficient
detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Strategy and Consultation and Engagement Report
for full details of the consultation activities
undertaken.
London Plan states density guidance is not to be
applied 'mechanistically'
Clarification is sought as to how delivery of principal and
DLR public open spaces can be done.
SQ3 – Concerned Fig 3.1 does not have regard to preapplication discussions and illustrative massing should be
revised to take that into account.
Consider SQ3.6ii should not necessarily refer to lower
floors.
Opportunities to provide open space/playspace in slightly
different ways than envisaged should not be stifled.
No action required
No action required
To be managed through Development Management
process
No action required
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Can be managed on a site by site basis through
Development Management process
No action required
Already noted within Masterplan
No action required
21
SQ4 – Amendments to policy wording suggested and
provided.
Question whether stepping down would help to mark the
axis where it would be seen against a backdrop of taller
development already consented.
Question how legible ‘uniform palette of materials’ would be
when seen from distance and suggest a palette of sufficient
contrast and boldness to be legible in distant views may
have potentially harmful impacts on coherence of emerging
townscape at local level.
Further definition of what constitutes ‘aesthetically balanced
skyline’ is needed. Suggested wording provided.
Extent of Canary Wharf cluster is not defined
Night time renders of development which is well integrated
into backdrop from distance would be of limited value.
Should be requested only where necessary.
SQFC1.47
SQFC1.48
Rolfe Judd on
behalf of
Nelsons Head
LLP
Local resident
Amendment made to wording in final version
No action required
Assessed in accordance with adopted Local Plan
policy
No action required
Amended for final version
Text removed
Already outlined in guidance text
No action required
Outlined in existing Local Plan policy
No action required
London View Management Framework requests this
No action required
SQ5 – No mention of innovative waste and recycling
storage system/need to connect mentioned in preapplication discussions.
Noted
No action required
Imperative document is treated as guidance and not as
adopted planning policy.
Final version has put increased emphasis on
indicative nature of diagrams
Text amended
Object to inclusion of indicative heights on Fig V1 and 3.1
as plots not reflective of ownership, do not reflect
consented schemes, do not reflect submitted schemes,
cannot be presumed sites are unlikely to come forward.
Final version has put increased emphasis on
indicative nature of diagrams
Text amended
To suggest heights on illustrative plan confuses credibility
of Masterplan.
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Cannot see evidence which confirms the massing/vision
maps have followed the correct approach and followed
adopted design criteria.
Supporting evidence is available
No action required
Clients site should be represented as one in which
redevelopment is likely
Diagrams are indicative only and this is being better
reflected in final version
Support policy SQ1 & 2
SQ3 – Consider Vision Map should be removed and parts 1
and 1a of SQ3 deleted to ensure vision map not used as
definitive guidance.
SQ4 – Supports policy.
SQ5 – Support principle of policy but questionable whether
requirement for development in area to contribute to
delivery of infrastructure breaches CIL regs by seeking to
impose additional costs/requirements without going through
the proper Charging Schedule.
Support noted
GVA on behalf
of Berkeley
Homes Ltd.
Support noted
Greater clarity given in final draft and
acknowledgement of process
No action required
Concerned at huge influx of people to the area
Concern noted. The Masterplan's objectives include
securing benefits for the community from
development
No action required
Understands there is insufficient water and Thames Water
cannot possibly excavate new pipes. Disruption to area if
needed to lay a new network would effectively close of Isle
of Dogs.
Concern noted. To be considered in development of
Isle of Dogs OAPF
No action required
TfL could not cope. Jubilee line runs at full capacity at rush
hour, DLR and bus full at 8 in the morning.
Concern noted. To be considered in development of
Isle of Dogs OAPF
No action required
Please rethink and replan
Suggestion noted
Concern noted. The Masterplan's objectives include
securing benefits for the community from
development
Disruption of massive population increase would be
permanent nightmare
SQFC1.49
Diagrams are indicative only and this is being better
reflected in final version
Actioned - text amended
to emphasise indicative
nature of diagrams
No action required
Actioned - text amended
to emphasise indicative
nature of diagrams
No action required
Have thought, care and respect for residents of the area
who have lived there for many years who do not wish to be
driven from their homes
Believes the Masterplan is unsound due to no supporting
evidence relating to infrastructure needs; duplication of
development plan policies; introduction of new development
management policies and site allocations; is not consistent
with adopted development plan; and the methodology of the
SEA assessment of alternatives is fundamentally flawed but
consider that the in-principle concerns listed could be
addressed if a number of minor modifications are made.
All prescriptive “requirements” to be replaced by guidance
“encouraging” or “supporting” particular development/uses.
This applies in particular in relation to limits on building
heights and allocations of land uses. Implies Council is
seeking to introduce new policy.
All infrastructure “requirements” to be deleted or replaced
by “priorities”.
Additional text to be added clarifying that alternative
approaches and different forms of development may be
permissible, even where they are not consistent with
specific guidance in the Masterplan, where this is justified
on a case by case basis at the development management
level.
No action required
No action required
Securing benefits for the wider community is an
objective of the Masterplan.
No action required
No duplications, new policy or site allocations.
Accords with existing adopted Local Plan
No action required
Text/diagrams amended in final version
Actioned
Amended for final version
No action required
Amended for final draft to clarify Figures/Plans are
indicative
No action required
All Figures/Plans to be clearly marked as illustrative.
Amended for final draft
Text amended
Any prescriptive Figures/Plans to be removed.
Amended for final draft to clarify Figures/Plans are
indicative
No action required
All guidance duplicating existing development plan policies
or supplementary planning documents/guidance to be
deleted.
No duplications of existing policy in Masterplan
No action required
22
All guidance which is inconsistent with existing
development plan policies or supplementary planning
documents/guidance to be deleted.
Masterplan accords with existing adopted Local Plan
No action required
This information is already outlined
No action required
Amended in final draft
No action required
No duplications, accords with existing adopted Local
Plan
No action required
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Final version has greater emphasis on indicative
nature of diagrams
No action required
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Fig 2.3 – Allocations of new principal public open spaces
should be removed
Locations are indicative only
No action required
SQ3.1b should be removed as the Masterplan recognises
an absence of heritage assets.
Some heritage assets are present
No action required
Fig 3.1 should be removed as fails to reflect permitted
schemes
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Supporting evidence is available
No action required
Adds clarity
No action required
SQ3.3c, d and e to be removed as duplicate DM26
Adds clarity
No action required
SQ3.5 to be removed as duplicates DM26
Adds clarity
No action required
SQ3.9a & b should allow for internal child space where
appropriate as currently seeks to introduce policy.
Text amended in final version
Actioned
SQ3.11 should replace ‘required’ with ‘should’
Amended for final draft
Text/diagram
amendments
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Supplements existing policy
No action required
Indicative nature of table and infrastructure guidance
emphasised in final version
Amended text
The Council is satisfied it has undertaken sufficient
detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Strategy and Consultation and Engagement Report
for full details of the consultation activities
undertaken.
No action required
Greater clarity given in final version
No action required
The Masterplan supplements existing Local Plan
policies
No action required
Final draft amended to emphasise indicative nature
of diagrams and remove ‘requirements’ to clarify
Masterplan not seeking to introduce new policy
No action required
No meaningful engagement with landowners set out as
stakeholders on p4
The Council is satisfied it has undertaken sufficient
detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Strategy and Consultation and Engagement Report
for full details of the consultation activities
undertaken.
No action required
Document should make clear that comments received will
be considered and appropriate amendments made before
anything more than limited weight can be attached to
document
Detail on consultation set out on Consultation
Strategy and Consultation Summary reports
No action required
Millennium Quarter Masterplan has a different boundary
and is unclear why sites falling outside of MQMP are to be
included in South Quay Masterplan and what status sites
will have which are within MQMP but outside of South Quay
area.
Explanation of Masterplan boundary set out in
revised draft. Sites outside of Masterplan boundary
to be guided by existing adopted Local Plan policy
Text amended
Historic context is of little relevance to form of new
development today
Important to outline changing nature of area
No action required
Include paragraph on p7 to explain weight of Masterplan in
context of adopted development plan
Review definition of ‘net residential area’ as detailed in
Mayor’s Housing SPG. Masterplan should allow application
of guidance on site-by-site basis
Remove SQ2.1a and b as duplicate adopted policies
SQ2e and Fig 2.4-2.7 should recognise that while step back
from dock edge may be desirable, is not appropriate in
every case. Guidance is unduly prescriptive and without
evidenced foundation
Fig 2.1 should be clear plan is illustrative only; remove
allocations of non-residential uses and make clear these
are promoted.
Fig 2.2 – routes which bisect land holdings should be
reviewed as these should be properly advanced through a
local plan review
SQ3.3a definition of podium and plinth should be removed
and lack of sound evidence prescribing street sections Fig
2.4-2.7
SQ3.4 & 5 repeat principles of good design already
explored in adopted policy.
Massing on p40/41 should be modified to be ‘illustrative’
and hybrid urban blocks should remove reference to limiting
to eight units per floor to account for opportunities where
alternative layouts can be equally good in design terms and
allow for delivery of more homes. Duplicates existing
policy.
SQ4.2 1 and 3 should be removed as seek to introduce
more stringent policy than already provided by DM26 and
LVMF.
Table 1 p47 should be informed by proper assessment of
infrastructure requirements for South Quay area based on
scale of emerging development. Table underestimates
requirements and should not be indicative.
Draft Masterplan is subject of little consensus as no draft
released prior to consultation.
Boundary of Masterplan area not robust and without
rationale
Already adopted plan which makes clear ambition of
foreword, and is being delivered in absence of the
Masterplan
If adopted in current form the Masterplan would be basis
against which stakeholders could set out to manage the
scale of growth in area contrary to ambition of government
guidance
23
Axis of Church of St Anne Poplar and Church of All Saints
Blackheath should be acknowledged
Amended for final version
No action required
No adequate response to comments submitted on Strategic
Environmental Assessment
Response contained within SEA
No action required
Unclear why vision should promote varied densities
This is outlined in Placemaking Principles and SQ3
No action required
Distribution of massing on Vision map is not supported by
evidence base and appears to be seeking to introduce
controls over height that the EiP inspector deleted for MDD.
Final version has put increased emphasis on
indicative nature of diagrams
No action required
Spaces are indicative only, can be managed through
development management process
No action required
Existing determined schemes have been referenced
and evolving landuse mentioned in Context section
No action required
Has relevance to area
No action required
Noted, but not considered necessary to amend within
context of text already supplied
No action required
Clarification of SQ1 – referred as ‘housing design’ on p18
but ‘housing density’ note on p23
Amended for final draft
No action required
SQ1 implies London Housing Design Guide is a policy
requirement, but is not – is guidance
Text amended in final version
Actioned
Not clear how scenarios to inform SQ1 have been
assessed to inform proposals
Evidence base is available
No action required
Additional guidance is presented
No action required
Indicative nature of diagrams has been clarified in
final version
Text amended
Fig 2.2 is indicative
No action required
This is set out in supporting text
No action required
This will be managed on a site by site basis through
the Development Management process
No action required
Can be managed on a site by site basis through the
Development Management process
No action required
Guidance considered appropriate
No action required
It is not considered that there is conflict
No action required
No technical requirement for night-time Verified View
Montages.
Further detail added to supplementary text to justify
inclusion
Amended text
Masterplan is ambiguous in definition of ‘necessary
infrastructure’. Plan should have been based on
assessment of infrastructure opportunities to seek to unlock
optimum capacity in the area for development.
SQ5 states "the most up to date infrastructure
requirements" as flexibility required
No action required
IDEA Store to be delivered at Wood Wharf is not a matter
for the Masterplan.
Consider guidance could be strengthened in terms of
developers being required to cooperate in creating
seamless or rationally varied design of good quality finishes
for the surface finishes of public spaces as well as coordinating ‘stand-up’ elements such as street furniture
Give a more active encouragement of free-enterprise nonresidential uses fronting onto and using the linking spaces;
Give a more active emphasis on the need for developers
and their street-front tenants to be involved in helping
ensure the maintenance and quality of those spaces
Masterplan should reference the Vienna Memorandum on
‘World Heritage and Contemporary Architecture –
Managing the Historic Urban Landscape’ and ‘Guidance on
Heritage Impact Assessment for Cultural World Heritage
Properties’, a publication of the International Council on
Monuments and Sites January 2011
These are directed to designated town centres which
would preclude delivery in South Quay
No action required
Already covered by adopted Local Plan policy and
can be managed through Development Management
process
No action required
Indicative active frontages might involve a variety of
uses/occupiers
No action required
Already covered by adopted Local Plan policy
No action required
Amended for final draft
No action required
Contradictory statements of p14 and p2 para 1.15 regarding
SINC
SINCs and Natura 2000 sites referenced in SEA are
different, therefore no contradiction
No action required
Proposed revision of Section 6 p18 provided
SQ2f – stepping back from dock edges. Developments
which respect building zone footprints but overhang several
stories from floor levels should be considered in terms of
compromising the public realm and dock side walkways in
terms of light and appreciation of open sky.
Current wording considered appropriate
No action required
This is why the Masterplan cites stepping back from
dock edges
No action required
Principal open spaces allocated around Marsh Wall are
likely to be dominated by traffic. Unlikely to be high quality,
well used spaces.
Masterplan has failed to acknowledge the emerging context
of the South Quay area through the Council’s own
permitted schemes and those with significant developer
interest
Creation of RP panel is noted but not a matter for the
Masterplan
While right to acknowledge CADAP, should make clear
applicants can choose to engage with CABE or other
qualified organisation.
SQ2 should be deleted as introduces no principals not clear
in adopted development plan.
Benefits of schemes such as South Quay Plaza would not
be delivered if schemes were to be designed in strict
accordance with Masterplan.
Some routes in Fig 2.2 bisect land holdings. These should
be advanced through Local Plan review to allow meaningful
consultation with respective landowners.
No evidence presented as to why existing footbridge is
required to be replaced. Masterplan should make clear
existing footbridge is to be retained.
Masterplan should make clear that on-site contributions in
lieu will be acceptable to meet any deficiency in on-site
communal or play requirements where Council prioritise
public open space delivery over residential amenity
contributions.
SQ3.6b could helpfully acknowledge that where capacity of
lower rise elements has been fully utilised for larger units, a
smaller unit mix will be encouraged at height even where
Council’s preferred unit mix is not met given unique
characteristics of this urban neighbourhood.
External playspace not always optimum solution (SQ3.9a
and b)
Conflict between SQ3.10c and d. Also no evidence as to
prescription.
SQFC1.50
Maritime
Greenwich
24
SQFC1.51
SQFC1.52
Committee of
the Isle of
Dogs
Neighbourhoo
d Planning
Forum
Rolfe Judd on
behalf of
Daejan (FHNV
1998) Limited
SQ4.1 text could be more specific – alternative supplied
Existing text considered appropriate
No action required
Suggested amendment to General Wolfe statue (SQ4.3a)
Existing text considered appropriate
No action required
Amendment to Skyline (p45 para 2) suggested and
provided
Existing text considered appropriate
No action required
Typos on p45 para 3 and 4
Amended for final version
No action required
P45 para 9 text appears to lack coherence and replacement
suggested
Amended for final version
No action required
Delivery p51 should refer to Maritime Greenwich World
Heritage Site Executive Group
Amended for final version
No action required
P45 para 5.82 should refer to Maritime Greenwich World
Heritage Site Management Plan (Third Review) 2014
Amended for final version
No action required
P45 5.83, 5.84 and 5.85 correction provided
Amended for final version
No action required
Would welcome opportunity to engage further
The Masterplan team is keen to continue to engage
with stakeholders
No action required
Amended for final draft
No action required
The Masterplan will be the first stage of the OAPF
No action required
Conditions have been placed on consents requiring
these considerations to be addressed before
construction proceeds
No action required
Masterplan guidance informed by SEA
No action required
SPD must conform with adopted policies
No action required
London Plan states density guidance is not to be
applied 'mechanistically'. Table 1 is indicative of
infrastructure required
No action required
Masterplan does not take account of all the developments
already approved in the area, those in pre-planning and
those we expect to be approved before the Masterplan is
complete. Concerned Masterplan will be defunct before
approval process is even complete.
Concern noted. Already consented applications at
the time of publication were outlined; this has been
updated for the final version. Suggestion noted
Amended text
Worry about a lack of local knowledge for example
comparison with New York’s High Line with space under
DLR. Space could be made prettier, but is not a
recreational location.
Wording amended for final version
Text amended
A number of residents have expressed their intentions to
leave the area. Sustainable development is meant to
protect the rights of current and future residents and not
drive them from the area. This cannot be good for
community cohesion and it certainly isn’t logical.
Concern noted. The Masterplan's objectives include
securing benefits for the community from
development
No action required
Wish is that the investment, goodwill and effort that has
gone into drafting the Masterplan leaves us with a policy
statement that both makes sense and has some effect.
Please include a robust policy statement limiting density to
level recommended by the London Plan.
This is not possible as it would be in conflict with
existing adopted policy
No action required
Imperative document is treated as guidance and not as
adopted planning policy.
Text has been enhanced for final version
Text amended
Opportunity to engage in drafting process did not provide
insight to client on direction and content of Masterplan.
First opportunity to understand and comment on Masterplan
was this consultation. Contrary to requirements of part 14
(ii) of Local Plan Regulations the LA has not provided a
summary of the main issues raised during that consultation
exercise.
The Council is satisfied it has undertaken sufficient
detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Strategy and Consultation and Engagement Report
for full details of the consultation activities
undertaken.
No action required
It is not considered that further consultation is
required, as amendments made in response to
formal consultation representations do not materially
alter the document
No action required
Amended in final draft
No action required
Support noted
No action required
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
To be managed through Development Management
process
No action required
Helpful for providing overall vision for area
No action required
Fig 3.1 is illustrative
No action required
Document would benefit from closer proof-reading.
Standard terminology should be adopted i.e. WHS and
World Heritage Site, Masterplan and masterplan.
Alarming that Masterplan is being written before OAPF has
been undertaken. The two processes must surely be
synchronised.
What happens if Strategic Development Committee
conforming to Masterplan grants consent that are later
found to be incapable of being supported by local power,
water or transport infrastructure?
18 criteria in LUC scoping report seem to represent a
balanced view on development. If not, why was LUC report
not amended earlier to reflect a more balanced view?
Not putting enough weight in Masterplan to importance of
guidelines issued by LUC, GLA and two London Mayors.
Why does Table 1 not include options for higher levels of
density? The only sensible answer is of course to limit
density as we go, and the Masterplan must surely be the
place to do it.
Is appropriate to provide landowners with a further
opportunity to review the Masterplan document once all
representations have been received. This could take the
form of another public consultation period or direct liaison
with individual landowners.
Approach to net Residential Developable Area differs from
that set by Housing SPG. Request amendment to clarify
proposed open spaces can be included in calculation.
Support principle of SQ1
Requested flexibility is applied to SQ2 when assessing
schemes that propose landuses inconsistent with the nonresidential frontages shown on Fig 2.1/open spaces on Fig
2.3
Not clear what might be required of applicants to
demonstrate compliance with SQ2 where site constraints
may present issues on individual sites.
Not clear why illustrative map for massing is required as
DM26 provides clear and rational criteria for assessment of
tall buildings.
Fig 3.1 contradicts Fig 3.10 which suggests different
variations of podium/plinth/taller element could be used on
development sites.
25
Indicative only and this is being better reflected in
final version
In current form maps are overly prescriptive.
Final draft to clarify Figures/Plans are indicative
Removal of Fig 3.1 and V1 requested so tall buildings can
be assessed against DM26
Indicative only and this is being better reflected in
final version
Appears urban design approach is to be universally
enforced across all development sites in South Quay area
which goes beyond remit of SPD document.
Indicative only and this is being better reflected in
final version
Ability to continue to provide features such as open spaces
and routes through developments would be constrained by
the inflexible approach to application of hybrid block
approach across all sites and client would question the
deliverability
Hybrid block approach considered appropriate, and
can be managed on a site by site basis
No action required
Request removal of section relating to hybrid urban blocks
or commentary inserted allowing for other approaches
where sites are identified for alternative approaches
Hybrid block approach considered appropriate, and
can be managed on a site by site basis
No action required
Fig 3.1 should be used as diagrammatic guide rather than
strict guidance on appropriate building height.
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
P40 justification text is overly prescriptive and is
inconsistent with DM26
Adds clarity, accords with DM26
No action required
Greater clarity given in final draft and
acknowledgement of process
No action required
Applications will continue to be assessed in
accordance with adopted policies
No action required
Text has been enhanced for final version
Text amended
Opportunity to engage in drafting process did not provide
insight to client on direction and content of Masterplan.
First opportunity to understand and comment on Masterplan
was this consultation. Contrary to requirements of part 14
(ii) of Local Plan Regulations the LA has not provided a
summary of the main issues raised during that consultation
exercise.
The Council is satisfied it has undertaken sufficient
detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Strategy and Consultation and Engagement Report
for full details of the consultation activities
undertaken.
No action required
Is appropriate to provide landowners with a further
opportunity to review the Masterplan document once all
representations have been received. This could take the
form of another public consultation period or direct liaison
with individual landowners.
It is not considered that further consultation is
required, as amendments made in response to
formal consultation representations do not materially
alter the document
No action required
Approach to net Residential Developable Area differs from
that set by Housing SPG. Request amendment to clarify
proposed open spaces can be included in calculation.
Amended in final draft
No action required
Support noted
No action required
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
To be managed through Development Management
process
No action required
Helpful for providing overall vision for area
No action required
Fig 3.1 is illustrative
No action required
Fig 3.1 is illustrative
No action required
Final draft to clarify Figures/Plans are indicative
No action required
Removal of Fig 3.1 and V1 requested so tall buildings can
be assessed against DM26
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Believe perimeter block arrangement generated by hybrid
urban block approach will only serve to internalise private
residential developments within the area thereby limiting the
potential for increased legibility and permeability in the
area.
Can be managed on a site-by-site basis
No action required
Request removal of section relating to hybrid urban blocks
or commentary inserted allowing for other approaches
where sites are identified for alternative approaches
Hybrid block approach considered appropriate, and
can be managed on a site by site basis
No action required
Fig 3.1 is illustrative
No action required
Adds clarity, accords with DM26
No action required
Questionable whether the requirement for development in
the area to contribute to the delivery of infrastructure
breaches the CIL Regulations by seeking to impose
additional costs/requirements without going through the
proper Charging Schedule process.
Consideration should be given to incentivising developers
to provide infrastructure within new schemes by for
example reducing affordable housing provision to offset
some costs.
Imperative document is treated as guidance and not as
adopted planning policy.
SQFC1.53
Rolfe Judd on
behalf of The
Komoto Group
Limited
Actioned - text amended
to emphasise indicative
nature of diagrams
No action required
Actioned - text amended
to emphasise indicative
nature of diagrams
Actioned - text amended
to emphasise indicative
nature of diagrams
Fig 3.1 does not appear reflective of land ownership and
not consistent with consented schemes.
Support principle of SQ1
Requested flexibility is applied to SQ2 when assessing
schemes that propose landuses inconsistent with the nonresidential frontages shown on Fig 2.1/open spaces on Fig
2.3
Not clear what might be required of applicants to
demonstrate compliance with SQ2 where site constraints
may present issues on individual sites.
Not clear why illustrative map for massing is required as
DM26 provides clear and rational criteria for assessment of
tall buildings.
Fig 3.1 contradicts Fig 3.10 which suggests different
variations of podium/plinth/taller element could be used on
development sites.
Fig 3.1 does not appear reflective of land ownership and
not consistent with consented schemes.
In current form maps are overly prescriptive and have
potential to be misused or misinterpreted.
Fig 3.1 should be used as diagrammatic guide rather than
strict guidance on appropriate building height.
P40 justification text is overly prescriptive and is
inconsistent with DM26
26
SQFC1.54
DP9 on behalf
of MW30 Ltd
Questionable whether the requirement for development in
the area to contribute to the delivery of infrastructure
breaches the CIL Regulations by seeking to impose
additional costs/requirements without going through the
proper Charging Schedule process.
Greater clarity given in final draft and
acknowledgement of process
No action required
Consideration should be given to incentivising developers
to provide infrastructure within new schemes by for
example reducing affordable housing provision to offset
some costs.
To be managed through Development Management
process
No action required
No new policy/allocations have been introduced
though indicative nature of diagrams/text has been
emphasised for final version.
No action required
Objection noted
No action required
Evidence available
No action required
Supplements existing guidance without repetition
No action required
Particular requirements can be managed on a site by
site basis
No action required
Evidence available
No action required
Main concern in Masterplan is SPD not appropriate
document to set new planning policies for the area as do
not have same status within development plan.
Believe the Masterplan should follow the publication of the
Isle of Dogs OAPF as these focus on implementation and
the identification of challenges and opportunities that need
resolving such as infrastructure, access, energy, phasing
and development capacity. Context and strategic principles
of the wider Isle of Dogs area should be considered first
followed by further level of detail within the Masterplan
document
Concerned document was not informed by a robust
evidence base. Nothing available to review which shows
how relevant requirements have been calculated, especially
infrastructure requirements.
SQ1 repeats guidance of London Plan policy 3.4 and SP02
and do not believe this needs to reaffirmed in the
Masterplan
SQ2 – aspirations for active spaces need to be realistic and
an appropriate balance found where developments can
provide active spaces but also provide for physical
unavoidable requirements, like cycle storage, back of house
and plant.
SQ3 – Consider inappropriate to refer to massing diagram
(3.1) as no evidence to support the indicative massing and
approach would reduce development capacity and housing
delivery. No justification for heights contained on 3.1
Need to contribute towards infrastructure does not need to
be repeated in Masterplan as outlined in development plan.
No robust evidence behind findings of infrastructure Table 1
Needs to be explained why the replacement of the western
South Dock footbridge should be provided after the eastern
South Dock footbridge
Insufficient time for full participative discussion involving
local people
Whole Isle of Dogs area needs a comprehensive plan and
strategy at least broadly agreed by those that live there.
Masterplan should be set aside and reconsidered as part of
a wider Isle of Dogs Masterplan
Millennium Quarter Masterplan should not be deleted as
covers a different and larger area. Principle of height
scaling down from Canary Wharf tower down to two story
terraced houses in Mellish St should stand.
No action required
No action required
This is not stated within the document
No action required
The formal consultation exceeded the legal minimum
of four weeks
No action required
This will be addressed by the Isle of Dogs OAPF
No action required
Height principles are established in existing Local
Plan policy which remains
No action required
Marsh Wall as a ‘local high street’ might work, position is
relevant to the Isle of Dogs but suffers the displacement
and breaks caused by the DLR structures and water
passage to Millwall inner dock
Comment noted
No action required
Does not believe space under DLR would be good for a
conventional garden or park space, but a carefully thought
out and looked after garden using shade-loving plants and
‘lower canopy’ forest plants might work, but it may not be
very robust
Concern noted
No action required
Space under DLR could be used for
-free access dance floor
SQFC1.55
Further guidance in Masterplan compared to Local
Plan
Evidence available
Local resident
-performance space/mini amphitheatre
-spaces for street musicians
-skate boarding park
-exercise equipment for adults and children
-seating, benches, places for people to gather and talk
-market stalls
-car parking
Costs of activities under DLR could be from CIL
Does not like podium/plinth/tower proposals as does not
make best use of space available. Suggests alternative of
entire block between north side of Marsh Wall and South
Dock to be built to cover entire footprint of each lot of land
but to a uniform height of 10 stories and the entire roof to
be one continuous public space roof garden. Where there
are gaps between buildings these could be connected by
high level footbridges. Some parts could be
greenhouses/playing fields.
Can be considered in line with the principles for DLR
public open spaces
Different uses might be accommodated throughout
Masterplan area
Different uses might be accommodated throughout
Masterplan area
Different uses might be accommodated throughout
Masterplan area
Different uses might be accommodated throughout
Masterplan area
Different uses might be accommodated throughout
Masterplan area
Different uses might be accommodated throughout
Masterplan area
Different uses might be accommodated throughout
Masterplan area
Different uses might be accommodated throughout
Masterplan area
Suggestion noted
Suggestion noted, but would impact on quality of
public realm
No action required
No action required
No action required
No action required
No action required
No action required
No action required
No action required
No action required
No action required
No action required
27
Should be able to restrict the total density or square footage
of floorspace allowable.
Huge blocks could allow for
-car parking or noisy youth clubs/nightclubs in basement
-shopping malls at street level/ground floor
SQFC1.56
Environment
Agency
Masterplan cannot dictate density as would conflict
with adopted policy
Different uses might be accommodated across the
area without single large blocks
Different uses might be accommodated throughout
Masterplan area
Different uses might be accommodated throughout
Masterplan area
No action required
No action required
No action required
No action required
-offices on 1st/2nd floor
Different uses might be accommodated throughout
Masterplan area
No action required
-residential and compatible uses i.e. schools on 3rd floor
and above
Noted, different uses might be accommodated
throughout Masterplan area
No action required
If there are buildings on north side of Marsh Wall exceeding
height of the roof garden, should still be a continuation of
the roof garden walkway
Suggestion noted
No action required
Buildings on south side of Marsh Wall should be compatible
with the general plan, area, objectives and not exceed the
height of the roof garden block on north side.
Building heights are assessed in accordance with the
Local Plan policies through development
management process
No action required
Consider moving walkways or free bus circulating the Isle of
Dogs.
Marsh Wall should not end up being an obstacle to people
wishing to walk/cycle across it.
Support that the guidance seeks to shape South Quay to
ensure buildings step down from the north to the south and
step back from docklands.
Support that the principle that the design of public open
spaces should include elements to support and improve
biodiversity
This is the only place where the designation of Flood Zone
3a is referenced. It is disappointing to see that apart from
the reference to 'housing (subject to flood risk)' on page 40
that the requirements of developments due to the increased
nature of flood risk in this area has not been referred to in
this document. It missed to include design guidance to
reduce and mitigate flood risk as well as include references
to Sustainable Drainage Systems (SUDS), Green Roofs
and to include key messages from the Thames Estuary
2100 plan relevant to Tower Hamlets and in particular
dockside development.
Small sections of the masterplan area (in the West and
East) are at risk of flooding if there was a breach in the
defences or if the defences were overtopped. In these
areas, a Flood Risk Assessment would need to assess in
detail the risk of flooding to the sites and demonstrated that
occupants would be protected from flooding in the event of
a breach of the tidal flood defences. Residential uses
(except basement dwellings and other highly vulnerable
uses) are acceptable in principle, subject to the
implementation of suitable mitigation and protection
measures.
The flood risk mitigation measures should be included in
this masterplan guidance, under Development Management
or under the Placemaking principle Housing Design and
include examples such as raising floor levels above the
predicted depth of flooding; ensuring that residential uses
will be above the predicted level of flooding; ensuring that
occupants will have safe refuge above the predicted depth
of flooding; or implementing a suitable emergency plan. The
Council's emergency planning team should be satisfied with
any mitigation measures proposed such as safe refuge
during a flood.
The Sequential Test should be undertaken for any of the
developments to be considered appropriate in the
masterplan area.
Outside of the area that may be affected if there was a
breach in the tidal defences, a Flood Risk Assessment will
be required to assess in detail the risk of flooding to the
site.
Principle 1 - it is disappointing to see that SuDS are not
referenced here as a mechanism to achieve this or referred
to in the masterplan document at all. It is suggested the
inclusion of 'through the use of Sustainable Drainage
Systems following the drainage hierarchy where
appropriate' under Development Management or Housing
Design.
All new development will be required to manage surface
water runoff rates and volumes in accordance with the
London Plan (July 2011) which sets higher standards than
the NPPF.
Principle 3 - SuDS could be designed and implemented in
ways that deliver other objectives of the masterplan
including water use efficiency and quality, biodiversity and
recreation. In addition, where Private Amenity Space with
Roof Terraces and Community Amenity Space are
considered, Green Roofs which are at the top of the
hierarchy could be included.
To be considered in development of Isle of Dogs
OAPF
Improved connectivity is an aspiration of the
Masterplan
No action required
No action required
Support noted
No action required
Support noted
No action required
Covered by existing adopted Local Plan policy, but
reference added to Development Management
section in final document
No action required
Managed through adopted Local Plan policies
No action required
Managed through adopted Local Plan policies
No action required
This would be managed through the Development
Management process
No action required
This would be managed through the Development
Management process
No action required
Covered by adopted Local Plan policy
No action required
Managed through adopted Local Plan policies
No action required
Covered by adopted Local Plan policy
No action required
28
SQFC1.57
SQFC1.58
SQFC1.59
SQFC1.60
Thames Water
Royal Borough
of Greenwich
Local resident
TfL
Special requirements for sites that border the docks as they
are 'floodwater storage). Development should not encroach
into the docks without appropriate flood storage
compensation and be set back where possible. Refer to the
Thames Estuary 2100 Plan - Dockside requirements.
Actions may include - A flood control gate may also be
needed on the entrance to the West India and Millwall
Docks.
Omission of a 'Infrastructure and Utilities' Policy - it is the
local authority's responsibility to ensure infrastructure is
provided ahead of occupation, either through phasing or the
use of planning conditions. This is especially relevant to
wastewater infrastructure where powers to control
connection through the Water Industry Act are limited to the
quality of construction of the connection to the sewer, rather
than the suitability of the point of connection.
There is no specific policy dedicated to water and
wastewater infrastructure in either the Borough's Core
Strategy or Managing Development Document. It is
considered essential that reference is made to it within the
SQ Masterplan. See proposed following wording:
"Developers need to consider the net increase in water and
waste water demand to serve their developments and also
any impact the development may have off site further down
the network, if no/low water pressure and internal/external
sewage flooding or property is to be avoided. Developers
will be required to demonstrate that there is adequate
wastewater and water supply capacity both on and off site
to serve the development and that it would not lead to
problems for existing or new users. In some circumstances
it may be necessary for developers to fund studies to
ascertain whether the proposed development will lead to
overloading of existing wastewater and water infrastructure.
We would therefore recommend that developers engage
with Thames Water at the earliest opportunity to establish
the following: 1) The developments demand d for water
supply and network infrastructure both on and off site and
can it be met; 2) The developments demand for sewage
treatment and sewerage network infrastructure both on and
off site and can it be met; 3) The surface water drainage
requirements and flood risk of the area and downstream
and can it be met"
Thames Water must also be consulted regarding proposals
involving building over or close to a public sewer.
The desktop assessments indicate that local network
upgrades will be required in the area. However, these
upgrades are likely to be developed on a case by case
basis as development becomes more certain through the
planning process and the detailed impact studies are
completed. Thames Water would expect the developer to
pay a fair and reasonable contribution towards the local
network upgrade.
This would be managed through the Development
Management process
No action required
Managed through Development Management
process
No action required
More relevant to review of Local Plan and
development of Isle of Dogs OAPF. Can also be
managed through Development Management
process
No action required
Thames Water were consulted and a response to this
formal consultation was submitted
No action required
Requires discussion between applicants and Thames
Water during application stage
No action required
Concerned about how future unsympathetic development in
the South Quay Masterplan area will affect views from
locations in Greenwich
Managed in accordance with Local Plan policies and
development management process
No action required
No mention made in Masterplan of developments already
approved or in pipeline, or those outside of area across Isle
of Dogs. Supports suggestion that a graphic montage of all
such developments on views from General Wolfe statue
and grounds of Old Royal Naval College be included in
Masterplan and these being used to inform the high building
policy.
Already consented applications at the time of
publication were outlined; this has been updated for
the final version. Suggestion noted
No action required
Feels Masterplan is a triumph of optimism over reality.
Comment noted
No action required
Will be too late when buildings are completed to find the
necessary utilities are not in place.
Concern noted. Managed through development
management process. Also to be considered in
development of Isle of Dogs OAPF.
No action required
NHS planning to cut the hours of doctor’s surgeries on Isle
of Dogs so despite increasing number of residents there will
be fewer doctor hours available. Obviously there has been
no discussion with NHS on this issue
Health provision is outlined in SQ5
No action required
London Plan states density guidance is not to be
applied 'mechanistically'
No action required
Concern noted. The Masterplan's objectives
include securing benefits for the community from
development
No action required
Found whole consultative process a sham and fears for
future of Isle of Dogs
Noted. The Council is satisfied it has undertaken
sufficient detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Strategy and Consultation and Engagement Report
for full details of the consultation activities
undertaken.
No action required
Public Transport and Connectivity - The masterplan
identifies the extent of public transport that serves the area
which indicates correctly that the area has predominately
good access to public transport services. However, it
Noted, contextual information amended for final draft
No action required
Planning team is in breach of consultative document it
commissioned regarding population/density figures. Why
does Tower Hamlets break the recommendations of the
report it commissioned?
The team don’t live in the Isle of Dogs, don’t fight, don’t
implement their own commissioner’s recommendations,
allow developers to renege on promises, don’t have the
infrastructure in place before building begins and potentially
could break legally enshrined rights.
29
should be noted that South Quay footbridge, Docklands
Light Railway (DLR), cycle hire capacity and local bus
services are currently experiencing peak time congestion
which can restrict local accessibility. This should be
reflected in the current context.
TfL would also request that this section encourages early
engagement with TfL given the constrained public transport.
Supported by the TfL, but greater emphasis could be
included demonstrating the need for significant new
infrastructure to deliver the new/improved walking &cycling
routes over the docks. This could be achieved by
referencing ' possible bridge locations' where the new
routes cross over the docks.
It would be beneficial if the existing and proposed bridges
were labelled appropriately to differentiate the two.
The description of the various footbridges referenced within
the document is not consistent.
The strategy for replacing the existing footbridge is not
clear.
The new footbridge is referred to as 'between the South
Bank Plaza and Upper Bank Street'
The new footbridge is referred to as 'Eastern South Dock
foot bridge'
A new footbridge is proposed adjacent to the DLR bridge to
replace the existing footbridge will be 'improved or replaced'
(page 25) and 'replaced or refurbished'. Greater
consistency will provide a clarified policy position. TfL
requests that the document reflects that the relocation of
the existing bridge is the priority over the refurbishment of
the existing bridge. The relocation of the existing bridge in
line with the DLR Viaduct, utilising the public undercroft of
Heron Quays DLR and the proposed public square in South
Quay, would expand the catchment of Heron Quays DLR to
the south west. This has the potential to increase PTALs in
the area (e.g. from level 2/3 to 4)
It is requested that it is amended to show a public access
along the alignment with active frontages facing onto the
new route
TfL considers that the bridge to be necessary mitigation and
are preparing an invitation to tender to obtain designs and
indicative costing of the three new bridges proposed. It is
requested that TfL are included as a delivery organisation
for the feasibility, design and delivery study for foot bridges.
The GLA and TFL intend to meet with the Council early
march to discuss a public realm strategy for the South Quay
area and it would be beneficial for this document to reflect
any outcome of discussions
TfL has no objections in principle to SQ2 proposal
regarding how to use of spaces adjacent or under the DLR.
However, it is concerned that any proposals that would
impede DLR's ability to access, maintain and operate DLR
infrastructure. A document outlining the restrictions on uses
or structures permitted under the DLR is being created. It is
nevertheless welcomed that you expect development
proposals adjacent to the DLR to engage with TfL early
within the planning process.
The document refers to the DLR operating in a similar
fashion to New York's High line however it is requested that
this is either removed or clarified as the two operate very
differently. The High line is anon operational viaduct with a
park on top similar to the Greenway which links Hackney to
Barking.
A significant proportion of growth is expected to occur away
from dock edge; for example within the area south east of
South Quay DLR station. This is contrary to what the figure
shows which directs development to concentrate alongside
the docks.
The document states that walking and cycling connectivity
is poor in the area due to a poorly defined public realm. On
that basis, it is requested that there is a greater emphasis
on improving north to south links to Marsh Wall within
Figure 2.1.
TfL expects the number of buses running per hour along
West ferry Rd and Eastferry rod to increase in the future.
Consequently, these roads should be considered
destinations and will continue to be a high attractor for
walking trips. On that basis, it is requests that this figures to
conclude east to west routes that could be improved to
deliver greater accessibility to these two roads.
The figure includes a 3.3m pavement, however TfL
recommends that the considering the expected level of
footfall in the area that the payment to the northern edge of
Marsh Wall is extended to a minimum of 5m wherever
possible. Bus services operate along both Millharbour and
Limeharbour however no bus stops are indicated. On that
basis, it is requested that the document considers how a
bus stop, with sufficient alighting space, could be
incorporated within the street type.
Amended in final draft
No action required
Amendment made to wording in final version
No action required
Diagrams amended for final version
Text amended
Text amended in final version
Actioned
Work being taken forward by TfL in advance of Isle of
Dogs OAPF
No action required
Amendment made to wording in final version
No action required
Amendment made to wording in final version
No action required
Diagram is indicative only
No action required
Indicative diagram already shows this
No action required
Text amended for final version
Text amended
Can support guidance outlined in Masterplan
No action required
Support noted
No action required
Amendment made to wording in final version
No action required
Already shown within the document
No action required
Indicative diagram amended for final draft
highlighting improved north-south connections
No action required
Diagrams have been amended for final version
enhancing indicative routes.
Diagrams amended
The indicative diagrams have been reviewed for the
final draft
No action required
30
It is recommended that any unnecessary street clutter
including guard railing is removed within the area and it is
requested that this is included as an additional principle
with the policy.
Supports the provision of improved cycling routes however
it is requested that greater emphasis is included on those
areas sought of Marsh Wall.
The Council should use the published London Cycling
Design Standards when planning the street environment or
during the engineering of cycle-specific infrastructure and
reference to the document would be welcomed within the
masterplan.
Cycle parking has not been referenced within the document
even though its implementation can constrain the space
available to deliver public realm improvements. This has
become more relevant following the adopted of the FALP
which has increase the cycle parking requirements for
many land uses. Should a site not be able to accommodate
the full provision of cycle parking then it may be necessary
to provide provision on street. TfL therefore requests that
the document reflects the Council's approach to how cycle
parking will be provided within the public realm. The London
Cycling Design Standards does provide advice on this
matter.
There is currently only one docking station for the TfL Cycle
Hire Scheme within the masterplan area - 57 space docking
station on Lighterman's Rd. It should be noted there are
other docking stations accessible within 200m of the
masterplan area; notably the south and east and to the
north within the Canary Wharf estate. Notwithstanding this,
TfL has identified that an additional five cycle hire docking
stations will be required within the masterplan area, the
location of which have been appended to this letter. This
could equate to approximately 150 dock points with a
delivery cost of approx. £1.25 million. This is not funded
within the TfL's business plan and therefore would need to
be delivered through external funding either by CIL or s 106
agreement.
The document does not refer to bus infrastructure. TfL
therefore requests that detail is included requiring bus stops
to be provided in convenient locations for passengers; an
accessible for those with mobility impairments and are
located amidst high quality urban realm so that passengers
feel secure.
In order to increase in bus trips in the South Quay area TfL
will be seeking funding towards the provision of additional
bus services. Bus stands outside the masterplan area are
needed to service local bus routes and therefore existing
bus stands will need to be protected and additional stand
space sought. The absence of suitable facilities will
constrain TfL's ability to provide sufficient bus capacity
within the masterplan area. For the masterplan area the bus
stands located at Crossharbour are of particular
importance.
The DLR will continue to experience capacity constraints in
the future at this location and therefore it is welcomed that
the document makes the link between the provision of
additional dock crossing points and relieving pressure on
the DLR network. It is also welcomed that the document
states that the Council will work with TfL to ensure that site
specific impacts (such as those above are addressed
through the development management process.
The London Plan Housing SPG recommends that each
wheelchair accessible unit is allocated a dedicated Blue
Badge bay. For high density development with a low car
parking provision this could require a quantum of spaces in
excess of what could be economically achieved on site. On
that basis, TfL requests that the document reflects that local
streets maybe need to provide on street Blue Badge
parking to meet a local shortfall in supply. It queries why the
document refers to considering the availability of visitor
parking spaces. The masterplan area benefits from a
reasonably good PTAL level and therefore TfL would not
support the provision of visitor car parking that could
undermine the use of more sustainable modes of transport.
It is nevertheless welcomed that the provision of car clubs
or car-pooling schemes are encouraged as this will assist in
reducing car ownership in the area.
Amendment made to wording in final version
No action required
Indicative diagram amended for final draft
highlighting improved north-south connections
Actioned
Text amended for final version
Actioned
Design Standards referenced
No action required
To be considered as part of Development
Management process
No action required
To be considered in development of Isle of Dogs
OAPF
No action required
To be considered in development of Isle of Dogs
OAPF
No action required
Support noted
No action required
Support noted
No action required
31
SQFC1.61
SQFC1.62
James
Etherington
Rolfe Judd on
behalf of HPB
Pension Trust
and LCN
Properties
It is agreed that the work on the Isle of Dogs Opportunity
Area Planning Framework (commencing in summer 2015)
will provide the appropriate mechanism for delivering further
improvements to the public transport network beyond the
South Quay area. Notwithstanding that it is requested that
the list of strategic infrastructure on page 47 is expanded to
include additional cycle hire capacity. Bus services, by
definition within the CIL regulations, are not infrastructure
and therefore TfL would negotiate bus mitigation on a site
by site basis through the s 106 agreement processes. The
document has stated within this list that DLR is a delivery
partner for delivery the principal public open space. Be
aware that this would only be the case where DLR is the
land owner. It is welcomed that development should
connect to demonstrate a potential connection to a
masterplan wide waste storage and collection system as
this will assist in reducing to amount of freight movement
within the masterplan area.
Would encourage greater scrutiny of the high density of
many new proposed developments. Needs to be greater
pushback by LBTH rather than accepting influx of new
accommodation and people in such a constrained area.
Answers given in public consultation meeting and on what
difference the Masterplan would make in practice were
inadequate.
Should be greater accountability of spending of S106 and
proper follow through on commitments to local service
provision being made by LBTH in approving these
developments, for example working with all providers of
schools and create an enabling environment for them to
develop new school places and sites.
Imperative document is treated as guidance and not as
adopted planning policy.
Indicative nature of table and infrastructure guidance
emphasised in final version with amendments
No action required
Proposals are assessed in accordance with adopted
policies and guidance
No action required
Feedback from consultation events has been
recorded to inform future events.
No action required
Section 106/CIL receipts/spending are managed
according to adopted procedures with details
published by the Council
No action required
Indicative nature of diagrams and text emphasised
for final version
Text amended
Key objection is inclusion of indicative heights on vision
drawing V1 and Fig 3.1
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Plots on illustrative figures not reflective of actual plots/land
ownership. Heights do not represent consented or
submitted schemes. Cannot be presumed sites are unlikely
to come forward.
Final draft to clarify Figures/Plans are indicative
No action required
To include suggested heights on an illustrative plan
confuses credibility of Masterplan
Heights are illustrative only and this has been better
reflected in final version
Text amended to
emphasise indicative
nature of diagrams
Cannot see evidence which confirms massing/vision maps
have followed correct approach. Developments should
continue to be assessed against DM26
Support principle of SQ1 and criteria are acceptable
Support SQ2
SQ3 presents most concern as visual maps are misleading.
Consider Vision map should be removed and SQ3.1 and
part a should be deleted to ensure developers do not use
as definitive guidance.
Support the principle of SQ4
Building heights are assessed in accordance with the
Local Plan policies through development
management process. Evidence available
Support noted
Support noted
No action required
No action required
No action required
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Support noted
No action required
Supports the principle of SQ5
Support noted
No action required
Consider Masterplan should be a supplementary guidance
document illustrating level of development in area and not
restricting future developments in certain plots.
Masterplan is indicative and does not therefore
restrict development in certain plots
No action required
Noted. The Council is satisfied it has undertaken
sufficient detailed public consultation on the SPD in
accordance with statutory regulations and as set out
in the Councils Statement of Community
Involvement (SCI). See accompanying Consultation
Statement for full details of the consultation activities
undertaken.
No action required
It is not considered that further consultation is
required, as amendments made in response to
formal consultation representations do not materially
alter the document
No action required
Amended in final draft
No action required
Support noted
No action required
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Can be managed site by site through the
Development Management process
No action required
Demonstrates changing nature of area
No action required
Fig 3.1 is illustrative
No action required
Fig 3.1 is illustrative
No action required
Final draft to clarify Figures/Plans are indicative
No action required
Opportunity to engage in drafting process did not provide
insight to client on direction and content of Masterplan.
First opportunity to understand and comment on Masterplan
was this consultation. Contrary to requirements of part 14
(ii) of Local Plan Regulations the LA has not provided a
summary of the main issues raised during that consultation
exercise.
Is appropriate to provide landowners with a further
opportunity to review the Masterplan document once all
representations have been received. This could take the
form of another public consultation period or direct liaison
with individual landowners.
Approach to net Residential Developable Area differs from
that set by Housing SPG. Request amendment to clarify
proposed open spaces can be included in calculation.
Support principle of SQ1
Requested flexibility is applied to SQ2 when assessing
schemes that propose landuses inconsistent with the nonresidential frontages shown on Fig 2.1/open spaces on Fig
2.3
Not clear what might be required of applicants to
demonstrate compliance with SQ2 where site constraints
may present issues on individual sites.
Not clear why illustrative map for massing is required as
DM26 provides clear and rational criteria for assessment of
tall buildings.
Fig 3.1 contradicts Fig 3.10 which suggests different
variations of podium/plinth/taller element could be used on
development sites.
Fig 3.1 does not appear reflective of land ownership and
not consistent with consented schemes.
In current form maps are overly prescriptive and have
potential to be misused or misinterpreted.
32
Removal of Fig 3.1 and V1 requested so tall buildings can
be assessed against DM26
Believe perimeter block arrangement generated by hybrid
urban block approach will only serve to internalise private
residential developments within the area thereby limiting the
potential for increased legibility and permeability in the
area.
Request removal of section relating to hybrid urban blocks
or commentary inserted allowing for other approaches
where sites are identified for alternative approaches
Fig 3.1 should be used as diagrammatic guide rather than
strict guidance on appropriate building height.
SQFC1.63
Cllr Cregan,
Cllr Wood, Cllr
Ronald, Cllr
Chesterton
P40 justification text is overly prescriptive and is
inconsistent with DM26
Questionable whether the requirement for development in
the area to contribute to the delivery of infrastructure
breaches the CIL Regulations by seeking to impose
additional costs/requirements without going through the
proper Charging Schedule process.
Consideration should be given to incentivising developers
to provide infrastructure within new schemes by for
example reducing affordable housing provision to offset
some costs.
Found it useful and its recommendations should form the
core part of the SQMP especially when judging whether
future planning applications are sustainable or not.
There is an inherent contradiction between buildings
approved, in the pipeline and the infrastructure plans for the
area. The infrastructure planning is based on the London
Plan targets as per Table 1, the Council has approved
planning application which substantially exceed the
recommended density i.e. Galliard 2 Millharbour (3,000+).
Is the Council saying all these new development is
exemplary in design?
The Council will treat density as only one of a range of
factors but the LUC scoping report clearly looks at a wide
range of issues, including transportation, schools,
connectivity, infrastructure, anti-social behaviour, car
parking etc.
High density, tall development works less well for families
based on a lot of evidence, therefore the less likely that
mixed communities will work. The risk is that people will be
moved to social housing properties that are best designed
for the private rented market and not for long term, family
occupation.
The masterplan assumes the same density targets for the
whole area but the actual PTAL levels in the SQMP area
range from 5 down to 2. Densities in the plan should reflect
the different PTAL levels in the SQMP area as per the
London Plan
Section 2 - The word resident does not appear in the list of
groups to be consulted. The Council's list of tenants and
residents associations is out of date, misses many
residents associations and some of them either chooses
not to get involved in planning or are defunct. Most
residents also do not belong to residents associations. How
would you propose to reach them?
East End Life, THC website and writing to local
associations will not generate public involvement. Social
media, leaflets and emails via the Island Planning Forum
was able to generate much higher numbers of attendees. It
is suggested the Council to allow more time for preparation,
better locations, a better time of the year and assistance
with advertising e.g. goggle search. This should be
considered before the next major consultation on the
OAPF.
What is the actual split of development across the twenty
wards?
Forcing car parking levels to below 10% in most of these
new developments is forcing residents to lie about their use
of cars, creates parking stresses on nearby roads and
creates more parking fine revenue for the Council. It does
nothing to help residents especially those in social housing.
With self-driving cars now being tested in Greenwich, Tesla
electrical car charging points in Canary Wharf and
numerous electric cars on the road some of the reasons for
trying to reduce car use are changing.
By the time the Masterplan is approved in May (?) it will be
redundant as a large number of developments will have
been approved which clearly do not match the
recommendations in the SQMP. How the 2nd South Quay
Plaza Tower seems to occupy the space reserved for a
mini-park. Perhaps it would be cheaper and less misleading not to do any more masterplans?
The OAPF should have been done before the SQMP or run
in parallel with it not after it. How can you do a Masterplan
proposing up to 64,000 people in it (Option 5 in the LUC
report) with no TfL input? That seems to contradict the
notion of a Masterplan.
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Can be managed on a site-by-site basis
No action required
Can be managed on a site by site basis through
Development Management process
No action required
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
Adds clarity
No action required
Greater clarity given in final draft and
acknowledgement of process
No action required
To be managed through Development Management
process
No action required
Support noted
No action required
Table provides guidance; site by site mitigation can
be secured through the Development Management
process
No action required
Point noted. Considerations such as transport will be
addressed by forthcoming Isle of Dogs OAPF
No action required
Concern noted. Registered providers were engaged
during development of the Masterplan
No action required
Noted, but guidance is indicative and PTAL levels
could increase with greater connectivity
No action required
Noted. Contact lists and the Council's database of
interested persons have been amended following
formal consultation as new persons are added or
details are identified as defunct or requiring updates.
The Council cannot dictate that organisations or
individuals involve themselves in planning.
No action required
It is not considered that the time of year was a poor
choice. The benefits of the alternative promotional
methods mentioned are acknowledged, but the
Council does not have the resources to manage such
activity.
No action required
This information is outlined in the Council's annual
Monitoring Report
No action required
Parking provision managed through existing Local
Plan policies; parking elsewhere is potentially an
enforcement issue.
No action required
Indicative only and this is being better reflected in
final version
Actioned - text amended
to emphasise indicative
nature of diagrams
The Masterplan will be the first stage of the Isle of
Dogs OAPF
No action required
33
Who will fund the capital requirements in the area as S106
and CIL might not be able to provide all of the funds
required? Concerned that the public investment will not be
available to match the huge increase in population and that
CIL will not cover the gap. What is the budget for all of the
infrastructure requirements in the area?
The Council will use these powers again as developers will
see the Council using its powers as a cheaper option then
paying appropriate contributions to affected residents. The
Council will improve developer's profits at the expense of
resident's property values. It is interesting that the SQMP
makes no mention of this issue.
Most of the existing new development are anti-septic and
unchild friendly, besides Phoenix Heights. The word
Nursery does not appear in the main document yet the
demographics suggest it is one of the most important types
of education in the area (as many parents move away as
their children age).
What are the public health implications of such high levels
of density? Has the Council's Public Health Team been
consulted on the SQMP? The research we have read is
negative on the health implications of high-density
developments.
The term "ASBO" does not get mentioned in either the main
report or in the LUC scoping document. Why not? There
are young people hanging out inside the secure areas of
those developments without concierges (mainly social
housing), in waterside areas away from the roads and out
of view of parents where they can smoke cannabis and
drink alcohol. Smart design could help with ASBO but
recent developments have made it worse. Where will young
people wish to hang out in the SQMP area? How will this
problem be fixed?
Will those new towers get demolished in 30 years time?
With construction likely to proceed for the next 10-15 years
we need to find a better way to protect existing residents
from the noise and disruption of construction. It is
suggested at a minimum, new rules on pile driving and a
9am Sat start versus 8 am with no weekend working
allowed on Bank holiday weekends
There is a complete disconnect between the Council
'Planning for school places 2012 - 2022'(Sep 2012) and the
detail contained in the masterplan. No detail on school
capacity (as compared to the GP analysis). Why? LUC
report says that the IOD has the fewest options for school
expansion and potential new schools and therefore the
capacity for financial contributions to offset adverse effects
within the immediate locality is limited. It also says the
masterplan is unable to allocate sites for a primary school.
If so, how was the Westferry print works site reserved for a
secondary school?
There is none in the SQMP. This is an issue we will wish to
discuss with the Council in more detail in the future
The combination of planned works and emergency works is
toxic in a geographically constrained area with only two exit
routes. More planning is required, for example, to only
allow one major road obstruction on the two main access
routes and that all construction related traffic is co-ordinated
across all developments in the same way that the London
2012 Olympics co-ordinated traffic across London. In
addition, given the expected increase in traffic will the Blue
bridge be replaced, if so when, who will manage the
process and pay for it? The SQMP is silent on this issue.
These big tall towers in SQ may not be economically
sustainable over the next 10 -15 years when the market
cools. They are not sold to meet the real housing needs but
to overseas investors. However, if smaller less dense
development was encouraged then the upfront costs would
be lower, developers would be more likely to build as they
had lower risk, the impact on local infrastructure would be
less requiring less public investment and therefore less
s106/CIL. That would help to reduce the price per unit and
make units more affordable making them accessible to a
wider range of people.
The list of utility issues - water, sewage, mobile phone
capacity, internet, busses etc. How will all of these issues
get dealt with?
The masterplan does need to include guidance on social
housing related issues. These may not be enforceable but
that does not mean that you cannot recommend them to
developers. The issues are: durability of internal fittings;
child play space internal and external; entrances
The dock areas are designated as site of importance for
nature conservation. The SQMP has little to say on how the
adverse effects on the historic and natural environment will
be mitigated, both during construction and with the
subsequent population increase e.g. construction noise on
the swans that normally reside in Middle Dock
Infrastructure needs and funding are managed
through Council's prioritisation matrix
No action required
Managed through Development Management
process
No action required
Nursery provision can be offered as part of
community facility provision
No action required
Public Health have been consulted, and evidence
has been considered as part of Local Plan
No action required
Behaviour of individuals is not a matter for the
Masterplan
No action required
Not a planning concern
No action required
Can be managed through the Development
Management process
No action required
Education addressed by SQ1, SQ5 and existing
adopted policy. Westferry was allocated through the
development plan process involving rigorous public
examination by an Inspector. Such provision is not
possible for SPDs, which cannot set new policy or
allocate sites.
No action required
Request to meet acknowledged
No action required
The Blue Bridge is a matter for the Isle of Dogs
OAPF to consider; works are a matter for the
Transport team
No action required
Concern noted. Heights and densities are managed
through the development management process. The
planning system cannot control how units are
marketed and sold.
No action required
Some issues mentioned are not matters for planning,
others are wider issues that can be dealt with through
the Isle of Dogs OAPF
No action required
Individual designs managed through Development
Management process
No action required
Managed through adopted Local Plan policies
No action required
34
Unlike Whitechapel, it feels that the Council has no vision
for the area beyond the delivery of the London Plan housing
target and the 4,000 social housing that the Mayor has
promised as a manifesto commitment. Individual
developers have a vision for their little patch but there is no
collective vision.
The vision of a 'thriving dockside neighbourhood' is
set out on page 17
No action required
35
Table 3: Key amendments to the supplementary policy guidance within the South Quay Masterplan SPD
The table below outlines the key amendments to the supplementary policy guidance within the adopted South Quay Masterplan SPD (October
2015) compared to the previous consultation version (November 2014).
The changes listed in the table below focus on additions and deletions to the text of the supplementary policy guidance as a result of
consideration of the representations received (set out in Table 2 of this Consultation Statement) during the formal public consultation period (5th
January – 16th February 2015). Additions are underlined and deletions are struck through. Also included for ease of use and transparency is a
summary of the reason for the change and consideration of its affect. It should be noted that a number of other amendments have also been
made to the document, but these are corrections related to grammar, presentation and other such minor clarifications.
Supplementary policy guidance
Change
Reason
SQ1 Housing density
Development seeking to exceed London Plan housing
densities should will be required to
Representations raised concerns that the supplementary policy
guidance was going beyond its legislative remit by including
requirements. It was considered that this was something that
should be covered by a Local Plan policy. The SPD has been fully
prepared in accordance with the requirements of the NPPF and the
Town and Country Planning (Local Planning) (England)
Regulations 2012 and the supplementary policy guidance acts
within their remit by supplementing the adopted Local Plan.
However, the Council acknowledges this perceived concern and
has replaced the phrases ‘required/need to/must’ with ‘should’ has.
This has been done for consistency and clarity.
C) provide the required infrastructure in accordance with the
Local Plan and the London Plan.
SQ2.1. Connections & public realm
Development should will be required to deliver legible and
well-defined networks of routes and spaces by
SQ2.2 New public open space
Development should will be required to:
SQ2.3. Principal and DLR public open
space
Development adjacent to the Principal and DLR public open
spaces should will be required to
SQ3.1 Massing
SQ3.3 Podiums and plinths massing
Development should will be required to define and enclose
the network of connections and spaces set out in SQ2 by
Hybrid urban blocks should are required to consist of three
core components
Podiums and plinths massing
SQ3.4 Podium and plinth design
Podium and plinth massing should are required to
This should will be required to:
SQ3.2Hybrid urban blocks
SQ3.5 Taller elements massing and
design
SQ3.6 Housing typologies
The additional text has been added to criterion for clarity in
response to representation. This to make it clear that it is the
infrastructure requirements of the Local Plan and London Plan that
will need to be met.
Representations raised concerns that the supplementary policy
guidance was going beyond its legislative remit by including
requirements. It was considered that this was something that
should be covered by a Local Plan policy. The SPD has been fully
prepared in accordance with the requirements of the NPPF and the
Town and Country Planning (Local Planning) (England)
Regulations 2012 and the supplementary policy guidance acts
within its remit by supplementing the adopted Local Plan. However,
the Council acknowledges this perceived concern and has replaced
the phrases required/need to/must with ‘should’ has. This has been
done for consistency and clarity.
SQ3.5 Taller elements massing and design
Taller element massing and design should will be required
to:
Development should deliver a range of housing typologies
and their design should aim to including:
a. directing wheelchair accessible housing to:
i. the ground floor where non-residential uses are
not suitable; or
ii. lower floors served by at least two lifts with easy
access to street level and communal amenity
space.
b. directing family housing to:
i. on the ground floor where non-residential uses
are not suitable, in the plinth element and in the
lower levels of the taller element;
ii. have easy access to child play space, communal
amenity space and service cores; and
iii. enable passive surveillance over child play space
and communal amenity
space with elements of play.
c. accommodate in the hybrid urban blocks to:
i. provide a range of residential types including town
houses, flats, maisonettes,
and duplexes;
ii. maximise the proportion of dual-aspect units;
iii. limit units on each floor to eight per floor; and
iv. maximise floor to ceiling heights, particularly at
lower levels
SQ3.8 Communal amenity space
SQ3.9 Child play space
d. maximise daylight and prevent overheating of singleaspect units by considering the depths of the unit
This should
SQ3.9 10 Private amenity space
SQ3.10 Private amenity space
SQ3.10 9 Child play space
SQ3.11 Car parking & servicing
Where parking is proposed, it should will be required to
deliver:
This additional text has been included in response to
representations for clarity.
Directing has been edited so it reads correctly and improves
grammar for parts a. and b.
The background text to supplementary policy guidance SQ3.6
included a number of points that were drafted as supplementary
policy guidance and mistakenly excluded in error. These have been
reinstated and now make up two new criteria in c) and d).
Text introduced to improve how the guidance is read.
Numbering rearranged to improve how the supplementary policy
guidance is read.
Numbering rearranged to improve how the supplementary policy
guidance is read.
Representations raised concerns that the supplementary policy
guidance was going beyond its legislative remit by including
requirements. It was considered that this was something that
should be covered by a Local Plan policy. The SPD has been fully
prepared in accordance with the requirements of the NPPF and the
Town and Country Planning (Local Planning) (England)
36
Supplementary policy guidance
SQ3.12 Developments with car parking
and servicing shared access
SQ3.13. Mechanical parking systems
SQ3.14 Car parking for disabled
people
Change
SQ3.12 Developments with car parking and servicing shared
access
Mechanical parking systems
This should reflect:
a. demand for parking access;
Mechanical parking systems should reflect:
a. demand for parking access
Car parking for disabled people
Reason
Regulations 2012 and the supplementary policy guidance acts
within its remit by supplementing the adopted Local Plan. However,
the Council acknowledges this perceived concern and has replaced
the phrases required/need to/must with ‘should’ has. This has been
done for consistency and clarity.
Text amended to improve how the supplementary policy guidance
is read.
Text amended to improve how the supplementary policy guidance
is read.
Text amended to improve how the supplementary policy guidance
is read.
This should be provided within or below
SQ3.15 Integrating social infrastructure
& primary schools
Car parking for disabled people should be provided within or
below
Amend the title from “Integrating social infrastructure &
primary schools” to “Integration of social infrastructure &
primary schools”
Text amended to improve grammar.
Text amended to read correctly
SQ4.1 The Skyline
ii. on podiums for play decks and MUGAs.
play decks, MUGAs and on podiums
Was 3.16 but amended as incorrectly numbered
Development located on the Grand Axis should: will be
required to:
SQ4.2 Layering and clustering
Development should: will be required to:
SQ4.3 Views
Development should will need to
Give full name of “the Grand Axis” - “the Maritime
Greenwich Grand Axis”
SQ4 supporting text
SQ5
The masterplan requires is a uniform palette of
material for the sites along the Grand Axis. Over
time this has a way of standing out amongst the
cluster of buildings unified by their colour and
materiality visible in the distant view.
Now just a waste section rather than infrastructure more
generally
Representations raised concerns that the supplementary policy
guidance was going beyond its legislative remit by including
requirements. It was considered that this was something that
should be covered by a Local Plan policy. The SPD has been fully
prepared in accordance with the requirements of the NPPF and the
Town and Country Planning (Local Planning) (England)
Regulations 2012 and the supplementary policy guidance acts
within its remit by supplementing the adopted Local Plan. However,
the Council acknowledges this perceived concern and has replaced
the phrases required/need to/must with ‘should’ has. This has been
done for consistency and clarity.
Text removed as could be read as introducing new policy which is
beyond the remit of an SPD, and was not the intention.
Infrastructure requirements covered by existing Local Plan. Only
waste offers any further detail – schools captured in SQ3.
Text amended to improve clarity.
Change the title from “Infrastructure” to “Waste
Management”
Cumulative changes to supplementary
policy guidance
The document’s supplementary policy guidance has been
amended in places to ensure the meaning is clear, and that
the policies supplement existing Local Plan policies as a
material consideration, rather than appearing to set new
policy requirements which is beyond the remit of an SPD.
The main change to policy is in the additions to
supplementary policy guidance SQ3.2, where three new
criterions have been added. This detail was in the supporting
background text, and was clearly written to guide future
development. Therefore it should be clearly included in the
body of the supplementary policy guidance rather than the
supporting text.
Primarily the changes are a result of request for clarity in the
document received during the public consultation.
37
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