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Enderby Wharf Planning Statement

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					Enderby Wharf:
Planning Statement
Mason Developments

October 2010




           www.gvagrimley.co.uk
Mason Developments




CONTENTS

EXECUTIVE SUMMARY                                                          1

1. INTRODUCTION                                                            4
Supporting Information                                                     5
Consultation                                                               6
2. CONTEXT OF THE PROPOSALS                                                8
Location and Land Use Context                                              8
Surrounding Context                                                        10
Planning History                                                           11
3. THE PROPOSED DEVELOPMENT                                                12
Planning Benefits                                                          15
4. PLANNING POLICY FRAMEWORK                                               17
Adopted Planning Policy Framework                                          17
Emerging Planning Policy Framework                                         17
Site Specific Allocations                                                  18
        Greenwich Peninsula and Charlton Riverside West Opportunity Area   19
        Greenwich Peninsula Development Framework                          19
        Local Site Specific Allocations                                    19
5. PLANNING ASSESSMENT                                                     21
Overview of the Principle of Development                                   21
        Site Suitability and Release of Strategic Industrial Land          22
Land Use                                                                   23
        Cruise Liner Terminal                                              23
        Residential                                                        25
        Hotel                                                              27
        Commercial Uses                                                    28
        Skills Academy                                                     30
        Other Supporting Uses: Café, Gymnasium and Crèche                  31
Townscape and Design                                                       32
Heritage and Conservation                                                  35
Landscaping and Public Realm                                               38
Transport and Accessibility                                                39
Parking and Servicing                                                      42
        Car Parking                                                        42




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        Cycle Parking                                       43
        Coach Parking                                       45
        Servicing                                           45
Energy and Sustainability                                   46
Affordable Housing                                          47
Residential Mix and Layout                                  49
Residential Density                                         51
Residential Amenity Space                                   53
        Communal Amenity Space                              53
        Private Amenity Space                               54
        Child Play Space                                    54
Development and Flood Risk                                  57
Archaeology                                                 58
Microclimate                                                59
        Daylight, Sunlight, Overshadowing and Solar Glare   59
        Noise                                               60
        Air Quality                                         61
        Wind                                                62
Ecology (Marine and Terrestrial)                            63
Planning Obligations                                        64
        Draft Heads of Terms                                65
6. CONCLUSIONS                                              67




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        EXECUTIVE SUMMARY
        This Planning Statement has been prepared by GVA Grimley on behalf of Mason
        Developments Ltd (the applicant) in support of an application for Full Planning Permission and
        Listed Building Consent for the redevelopment of Enderby Wharf, Greenwich, SE10 (the site).
        This statement demonstrates the planning case in support of the applicant’s proposals in the
        context of national, regional and local planning policy and other best practice guidance.

        Mason Developments Ltd acquired the application site in 2007 following discussions with the
        former owner, Alcatel. The site was formerly part of a wider estate owned by Alcatel until
        being declared surplus to operational requirements. Alcatel continue to own and occupy the
        balance of the estate and are fully in support of the principle of regenerating Enderby Wharf
        for the proposed mix of uses.

         The applications submitted with this Planning Statement seek approval for the following
         development proposals:

         •     the delivery of a new international cruise liner terminal on the River Thames;

         •     the provision of quality hotel accommodation adjacent to the international cruise liner
               terminal;

         •     the development of private and affordable residential homes set within an extensive array
               of public, semi-public and private landscaped spaces;

         •     the provision of an enterprise and training skills academy;

         •     the delivery of a crèche and gymnasium;

         •     the provision of start-up business accommodation located adjacent to the new hotel and
               cruise terminal;

         •     the refurbishment of the Grade II listed Enderby House as a restaurant / café with
               accompanying exhibition space and tourist and interpretation centre;

         •     the provision of a new public square fronting onto the River Thames which provides a
               new riverside destination alongside the Thames Path incorporating the reinstated
               Enderby House; and

         •     the creation of a new double berth river mooring to be served by the Thames Clipper fast
               passenger service for visitors and residents.




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        The Provision of a Cruise Liner Terminal for Greenwich and London

         In February 2009, the London Waterways Commission commissioned via the London
         Development Agency and the Greater London Authority, with support from the Port of London
         Authority, a report which considered the economic need for a cruise liner terminal to serve
         London, together with an assessment of potential sites.

         The Assessment of Current and Future Cruise Ship Requirements in London, published in
         June 2009, identified London as a ‘marquee’ (must-see) destination, but concluded that the
         lack of a purpose built cruise liner facility represented a significant missed economic
         opportunity.

         The report considered eleven potential sites for a new cruise terminal for London. Having
         considered each site, the report identified Enderby Wharf with a clear advantage due to the
         location of existing and self-scouring deep water outside the wharf, the proximity of the
         Maritime Greenwich World Heritage Site, and the emerging proposals being brought forward
         by Mason Developments Ltd which are now embedded within this application.


        The Proposed Development

         The application for Full Planning Permission seeks approval for the following development
         proposals which are aimed at delivering the comprehensive redevelopment of the Enderby
         Wharf site:

         “Redevelopment of the site comprising the provision of a new jetty in the River Thames to
         provide docking for cruise liners and the Thames Clipper, a cruise liner terminal; a hotel with
         conference, restaurant and ancillary facilities (Use Class C1); skills academy (Use Class D1);
         residential accommodation (Use Class C3); commercial and retail units (Use Classes A1, A2,
         A3, A4, A5 and B1); a crèche (Use Class D1); a gymnasium (Use Class D2); conversion and
         extension of Enderby House to provide tourist, community and retail facilities (Use Classes
         A1, A3, A4, B1, D1 and D2); the provision of vehicular access with associated servicing
         facilities; car, motorcycle and bicycle parking; provision of landscaping and public
         realm (including improvements to the Thames Walk); improvements to the river wall and other
         works within the river including dredging, the provision of tidal gardens, piling, the provision of
         a pontoon and brow, and associated works”.




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         The application for Listed Building Consent seeks permission for the following works to
         Enderby House, such works forming part of the overall redevelopment proposals for the
         Enderby Wharf site:

         “Alterations to Grade II listed Enderby House to include the enlargement of existing windows
         to create door access from the east at lower ground, ground and first floor levels; external
         refurbishment of the west, south and north elevations; removal of the bridge link to existing
         adjacent building; the erection of an extension to the east of the existing building; and internal
         alterations and refurbishment works to the existing building”.


        Consultation

         Extensive discussions and presentations have taken place with a range of statutory and non-
         statutory organisations prior to submission, including:

         •     the Port of London Authority;

         •     the London Development Agency;

         •     Transport for London;

         •     the Environment Agency;

         •     the Homes and Communities Agency;

         •     English Heritage;

         •     the Commission for Architecture in the Built Environment (CABE);

         •     the Greenwich Maritime World Heritage Site Executive;

         •     AEG, managers of the O2;

         •     London and Regional, the owners of the adjacent Lovell’s Wharf regeneration project;

         •     the Greenwich Millennium Village;

         •     the East Greenwich Traders Association;

         •     the Greenwich Management Agency; and

         •     agents for the Trustees of land to the north.

         In addition, detailed discussions have taken place with a range of cruise operators as part of a
         wide ranging consultation exercise.       This process has included in-depth discussions with
         London Central Cruise Moorings, who manage all cruise activities on the River Thames on
         behalf of the Port of London Authority.




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1.       INTRODUCTION
1.1      This Planning Statement has been prepared by GVA Grimley on behalf of Mason
         Developments Ltd (the applicant) in support of an application for Full Planning Permission and
         Listed Building Consent for the redevelopment of Enderby Wharf, Greenwich, SE10 (the site).
         This statement demonstrates the planning case in support of the applicant’s proposals in the
         context of national, regional and local planning policy and other best practice guidance.

1.2      Mason Developments Ltd acquired the application site in 2007 following discussions with the
         former owner, Alcatel. The site was formerly part of a wider estate owned by Alcatel until
         being declared surplus to operational requirements. Alcatel continue to own and occupy the
         balance of the estate and are fully in support of the principle of regenerating Enderby Wharf
         for the proposed mix of uses.

1.3      In February 2009, the London Waterways Commission commissioned via the London
         Development Agency and the Greater London Authority, with support from the Port of London
         Authority, a report which considered the economic need for a cruise liner terminal to serve
         London, together with an assessment of potential sites. The Assessment of Current and
         Future Cruise Ship Requirements in London, published in June 2009, identified London as a
         ‘marquee’ (must-see) destination, but concluded that the lack of a purpose built cruise liner
         facility represented a significant missed economic opportunity.

1.4      Whilst global passenger numbers are expected to increase by 80% up to 2020, and cruise
         traffic at Dover, Harwich, Southampton and Tilbury has risen by 30% between 2006 and 2008,
         cruise passengers visiting Central London are declining.          The report concluded that the
         existing cruise facilities “do not reflect well on London as a global city and international
         tourism destination” and stated that the number of cruise calls could treble from approximately
         22 in 2009 to 70 in the short terms if a new cruise facility was provided.

1.5      The Assessment of Current and Future Cruise Ship Requirements in London (June 2009)
         considered eleven potential sites for a new cruise terminal for London. Having considered
         each site, the report identified Enderby Wharf with a clear advantage due to the location of
         existing and self scouring deep water outside the wharf, the presence of Maritime Greenwich
         represented by the nearby World Heritage Site, and the emerging proposals being brought
         forward by West Properties which form the subject of this application.

1.6      The redevelopment of the site provides a unique opportunity to provide a cruise liner terminal
         for the London Borough of Greenwich and London as a whole, and this key piece of




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         infrastructure generates the additional opportunity to deliver wider regeneration benefits for
         the site and surrounding area.


        Supporting Information

1.7      As agreed with officers at the London Borough of Greenwich, the following information is
         submitted in support of the application for Full Planning Permission:

         •     EW01 - 1APP Planning Application Forms;

         •     EW02 - Existing and Proposed Plans;

         •     EW03 – Planning Statement;

         •     EW04 - Design and Access Statement;

         •     EW05 - Environmental Statement Volume I: Main Report;

         •     EW06 - Environmental Statement Volume II: Townscape and Visual Impact Assessment;

         •     EW07 - Environmental Statement Volume III: Technical Appendices;

         •     EW08 - Environmental Statement Non-Technical Summary;

         •     EW09 - Employment Land Study;

         •     EW10 - Transport Assessment;

         •     EW11 - Framework Travel Plan;

         •     EW12 - Landscape and Public Realm Strategy;

         •     EW13 - Energy Strategy;

         •     EW14 - Sustainability Statement; and

         •     EW15 - Statement of Community Involvement.

1.8      The following information is submitted in support of the Listed Building Consent application:

         •     LB01 - 1APP Application Forms;

         •     LB02 - Existing and Proposed Plans; and

         •     LB03 - Heritage and Urban Design Appraisal.

1.9      The existing and proposed plans, Design and Access Statement (Reference EW04) and
         Statement of Community Involvement (Reference EW15) referenced above should also be
         reviewed as part of the Listed Building Consent application.




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        Consultation

1.10     The development proposals have been the subject of extensive pre-application consultation
         with officers at the London Borough of Greenwich (Steve Pallett, Trevor Dorling, Mark Page,
         Andrew Parker and Louise Thayre), with Kevin Reid, Justin Carr, David Watkinson, Julie
         Fleck and Jonathan Williams at the Greater London Authority and with Patricia Cazes-
         Potgieter at Transport for London.

1.11     Extensive discussions and presentations have also taken place with a range on statutory and
         non-statutory organisations, including:

         •     the Port of London Authority (PLA);

         •     the London Development Agency (LDA);

         •     the Environment Agency;

         •     the Homes and Communities Agency;

         •     the Commission for Architecture in the Built Environment (CABE);

         •     the Greenwich Maritime World Heritage Site Executive;

         •     AEG, the manager of the O2;

         •     Thames Clipper;

         •     London and Regional, the owners of the adjacent Lovell’s Wharf regeneration project;

         •     the Greenwich Society, including the Environmental Society;

         •     the Greenwich Millennium Village;

         •     the East Greenwich Traders Association; and

         •     the Greenwich Management Agency.

1.12     In addition, detailed discussions have taken place with a range of cruise operators as part of a
         wide ranging consultation exercise. This exercise has included in-depth discussions with
         London Central Cruise Moorings, who manage all cruise activities on the River Thames on
         behalf of the Port of London Authority.

1.13     The project team has also engaged extensively with the local community throughout the
         design evolution process, and public exhibitions were held between 28 and 30 July 2010 and
         on 6 and 7 October 2010 at Christ Church on Trafalgar Road, East Greenwich, during which
         local residents, businesses and community associations were invited to comment on the




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         development proposals.      As set out above, a Statement of Community Involvement
         (Reference EW15) has also been prepared by Planning and Regeneration Limited, and is
         submitted as part of this application package. This provides further details of the consultation
         exercises undertaken and how this feedback has shaped the emerging development
         proposals.




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2.       CONTEXT OF THE PROPOSALS

        Location and Land Use Context

2.1      The application site measures approximately 3.6 hectares (ha) and is located within the
         London Borough of Greenwich (LB Greenwich). The site is bounded to the west by the River
         Thames and is located on the western edge of the Greenwich Peninsula, approximately
         equidistant between Maritime Greenwich and the World Heritage Site to the south west
         (approximately 1.4 km from the centre of the site), and the O2 to the north east (approximately
         1.3 km from the centre of the site). A site location plan is located at Figure 1.

        Figure 1: Site Location Plan




2.2      Enderby Wharf was historically used for the manufacture and shipping of submarine
         telecommunication cables but since the rationalisation of the Alcatel operations, is now
         vacant. As set out in Chapter 8: Cultural Heritage of the Environmental Statement Volume I
         (Reference EW05), most of the buildings currently located on the site date from the inter- and




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         post-war period and are of little or no architectural or historic merit. The majority of buildings
         on the site consist of linear ‘industrial sheds’ with pitched roofs. There is also a modern office
         building to the east of the Grade II listed Enderby House, and this occupies a part of the site
         which was cleared when the sheds were reduced in length. Between these sheds and the
         terraced houses to the south on the northern side of Mauritius Road are a number of other
         buildings of a more recent date, and some car parking space currently used by Alcatel.

2.3      The development site currently contains the following buildings and structures:

         •     a two-storey modern gatehouse building (1960s/1970s) at the entrance from Christchurch
               Way;

         •     a three-storey modern ‘L-shaped’ office block (1980s) in the centre the site;

         •     a series of linear two-storey early to mid twentieth century, much-altered, pitched roof
               brick buildings including a chimney on the southern edge of the site (adjacent to the
               Lovell’s Wharf site) by the river;

         •     to the north of these buildings are two early to mid-twentieth century buildings facing the
               river, approximately three storeys in height to the landward side, and two storeys to the
               riverside walkway; they appear to have formed one block and there is visual evidence of
               former construction to the rear of the building next to Enderby House;

         •     beyond these buildings, to the north, is Enderby House;

         •     connected to Enderby House on its northern side, and on the northern edge of the
               development site, is a four-storey modern (1970s) office building;

         •     to the east a number of modern (1960s-1990s) buildings and structures in the location of
               the proposed access road from Blackwall Lane; and

         •     various miscellaneous smaller structures and hard landscaping features.

2.4      The site is not within a conservation area, but Enderby House, a Grade II listed building is
         located to the west of the site. This is understood to have been first built in the early 1840s,
         and refurbished (or possibly rebuilt) after the major fire of 1845. Full details of Enderby House
         and the heritage context of the site is set out in Heritage and Urban Design Appraisal
         (Reference LB03) and Chapter 8: Cultural Heritage of the Environmental Statement Volume I
         (Reference EW05) but by way of a summary, the most important room in the house is the
         ‘octagon room’ in the north west corner of the plan at first floor level. This is where Charles
         Enderby entertained and conducted business. It is richly decorated in comparison to other
         rooms in the building, and has a large bay window looking out onto the River Thames.




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2.5      The site currently has a PTAL (Public Transport Accessibility Level) of 3, which indicates
         moderate accessibility to public transport.      The centre of the Enderby Wharf site is
         approximately 1.3 km south west of North Greenwich Underground Station, which provides
         Jubilee Line services towards Stratford in the east and Central London in the west. The site is
         approximately 1.4 km north of the Cutty Sark DLR Station, which provides services towards
         Lewisham and Stratford or Bank, and is approximately 850 metres north of Maze Hill Rail
         Station, which provides services towards Dartford and London Cannon Street.

2.6      The site is served by a number of bus routes along Blackwall Lane, which provide services
         towards North Greenwich, Greenwich Town Centre (Cutty Sark) and towards destinations
         including Russell Square, Lewisham, Stratford and Bexleyheath. The Thames Clipper has
         stops at both North Greenwich (approximately 1.3 km from the centre of the site) and
         Greenwich Pier (approximately 1.2 km from the centre of the site) and provides River Bus
         services to Woolwich Arsenal and London Bridge / Westminster Piers. Further details of the
         site’s accessibility and other transport considerations are set out in the Transport Assessment
         (Reference EW10) and Chapter 17: Transport of the Environmental Statement Volume I
         (Reference EW05), both prepared by JMP.


        Surrounding Context

2.7      The area to the south east of the site is predominantly residential in character, whilst the area
         to the east and north of the site is in industrial use. The site previously formed part of the
         Alcatel complex, and Alcatel continue to occupy the site to the east.

2.8      The surrounding area on Greenwich Peninsula is in a state of change and has been the
         subject of extensive redevelopment proposals since the opening of the Millennium Dome (now
         the O2) in 1999. There is considerable variety in building heights around the site and an
         emerging context of taller buildings in this area, as demonstrated by the approval of proposals
         for the redevelopment of the Lovell’s Wharf site immediately south of Enderby Wharf, which
         secured Full Planning Permission in February 2007 (Planning Application Reference
         06/1749/F) for the following:

         “Redevelopment for mixed use comprising offices, studio workshops, hotel, 667 residential
        units, retail, restaurant / café / bar, boatclub, ecological centre, medical health centre, health
        club, creche, new open spaces, tidal garden, sports areas, play area, river slipway, parking for
        742 cars, vehicular access arrangements, cycle / pedestrian routes and landscaping”.




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2.9      The Lovell’s Wharf scheme is currently under construction and will be up to 13 storeys in
         height when completed. This provides an emerging context of taller buildings in the vicinity of
         the site.

2.10     To the north of the proposed development site is Tunnel Glucose, a Safeguarded Wharf. The
         site has not been operational as a wharf since 1996 but continues to transport cereals by
         road.       The Greater London Authority’s document, Safeguarded Wharves on the River
         Thames:        Implementation Report (January 2005) recommended that the wharf remain
         safeguarded.

2.11     As set out above, the site is not within a conservation area. The closest conservation area to
         the site is the East Greenwich Conservation Area, approximately 200 metres south and south
         west of the site. There are also a number of other conservation areas in the wider area: the
         West Greenwich Conservation Area (which adjoins the East Greenwich Conservation Area at
         its south west boundary), which includes the Maritime Greenwich World Heritage Site; and
         Island Gardens Conservation Area in the London Borough of Tower Hamlets, approximately
         650 metres to the west of the site across the River Thames.


        Planning History

2.12     Prior to the submission of this application, the following applications have been submitted in
         respect of the sites at Enderby Wharf and Alcatel:

         •     Full Planning Permission was approved in April 2008 for the formation of a new internal
               roadway and car parking and installation of new internal concrete fence (Reference
               08/0447/F);

         •     Full Planning Permission was approved in November 2007 for the erection of two single
               storey outbuildings to house an EDF sub station and factory switch room (Reference
               07/2519/F); and

         •     Full Planning Permission was approved in May 2001 for the erection of a clean room
               facility for light engineering assembly of electronic components (Reference 00/0104).




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3.       THE PROPOSED DEVELOPMENT
3.1      The application for Full Planning Permission seeks approval for the following development
         proposals which are aimed at delivering the comprehensive redevelopment of the Enderby
         Wharf site:

         “Redevelopment of the site comprising the provision of a new jetty in the River Thames to
         provide docking for cruise liners and the Thames Clipper, a cruise liner terminal; a hotel with
         conference, restaurant and ancillary facilities (Use Class C1); skills academy (Use Class D1);
         residential accommodation (Use Class C3); commercial and retail units (Use Classes A1, A2,
         A3, A4, A5 and B1); a crèche (Use Class D1); a gymnasium (Use Class D2); conversion and
         extension of Enderby House to provide tourist, community and retail facilities (Use Classes
         A1, A3, A4, B1, D1 and D2); the provision of vehicular access with associated servicing
         facilities; car, motorcycle and bicycle parking; provision of landscaping and public
         realm (including improvements to the Thames Walk); improvements to the river wall and other
         works within the river including dredging, the provision of tidal gardens, piling, the provision of
         a pontoon and brow, and associated works”.

3.2      The application for Listed Building Consent seeks permission for the following works to
         Enderby House, such works forming part of the overall redevelopment proposals for the
         Enderby Wharf site:

         “Alterations to Grade II listed Enderby House to include the enlargement of existing windows
         to create door access from the east at lower ground, ground and first floor levels; external
         refurbishment of the west, south and north elevations; removal of the bridge link to existing
         adjacent building; the erection of an extension to the east of the existing building; and internal
         alterations and refurbishment works to the existing building”.

3.3      By way of a summary, the applications to which this Planning Statement refers, seek to
         optimise the development potential of the Enderby Wharf site as follows:

         •     the delivery of a new international cruise liner terminal on the River Thames;

         •     the provision of quality hotel accommodation adjacent to the international cruise liner
               terminal;

         •     the development of private and affordable residential homes set within an extensive array
               of public, semi-public and private landscaped spaces;

         •     the provision of an enterprise and training skills academy;




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         •     the delivery of a crèche and gymnasium;

         •     the provision of start-up business accommodation for small and medium sized
               enterprises (SMEs) located adjacent to the new hotel and cruise terminal;

         •     the refurbishment of the Grade II listed Enderby House as a restaurant / café with
               accompanying exhibition space and tourist and interpretation centre;

         •     the provision of a new public square fronting onto the River Thames which provides a
               new riverside destination alongside the Thames Path incorporating the reinstated
               Enderby House; and

         •     the creation of a new double berth river mooring to be served by the Thames Clipper fast
               passenger service for visitors and residents.

3.4      It is proposed that all existing buildings on site, with the exception of Enderby House, are to
         be demolished. The development proposals will replace the existing buildings with a number
         of buildings ranging from 3 to 16 storeys in height. A proposed ground floor block plan is
         provided at Figure 2.

        Figure 2: Proposed Ground Flood Land Use Plan




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3.5      The cruise liner terminal will be located to the north of the site, with a hotel providing 251
         bedrooms adjoining it to the east.         Buildings A to H will primarily provide residential
         accommodation, with a crèche and office / workspace floorspace provided at ground floor
         levels to deliver active frontages throughout the scheme. The scheme will also deliver a skills
         academy which will provide education and training facilities for local people, and a
         gymnasium.

3.6      The cruise liner terminal will operate during the cruise season, which is typically between April
         and October. Outside of this season, it is anticipated that the terminal could be used for
         community meetings and conferences.           This is in accordance with the GLA and LDA
         commissioned report (An Assessment of Current and Future Cruise Ship Requirements in
         London) referenced in this Planning Statement, which cites one of its key conclusions as
         follows: “given the seasonable nature of the industry, a secondary use for a terminal will be
         crucial”.

3.7      Full details of the principal components of the application are set out in the Design and
         Access Statement (Reference EW04) and a summary breakdown of the proposed land uses
         within the scheme is set out in Table 1.

        Table 1: Proposed Land Uses

          Land Use                                          Gross External Floorspace

          Cruise Liner Terminal (Sui Generis)                                       17,312 sqm

          Hotel - including conference, restaurant and             14,474 sqm (251 bedrooms)
          ancillary facilities (C1)

          Residential (C3)                                                             770 units

          Commercial and Retail Units (A1, A2, A3, A4,                                 594 sqm
          A5 and B1)

          Skills Academy (D1)                                                          580 sqm

          Crèche (D1)                                                                  251 sqm

          Gymnasium (D2)                                                               304 sqm

          Enderby House Extension (A1, A3, A4, B1,                                     733 sqm
          D1 and D2)

          Basement                                                                  18,638 sqm

          Total Non-Residential Floorspace                                          52,886 sqm




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3.8      It is anticipated that the double berth river mooring for the Thames Clipper will provide two fast
         passenger services for visitors, existing and future residents per hour towards Woolwich
         Arsenal and London Bridge / Westminster Piers.                This will significantly enhance the
         accessibility of the site and the surrounding area.


        Planning Benefits

3.9      The proposals will provide a wide range of planning benefits for the site and surrounding area,
         as set out below:

         •     provision of an international land-based cruise liner terminal in London;

         •     the redevelopment of the Enderby Wharf site provides the opportunity to enhance and
               diversify the land use mix provided in this location;

         •     redevelopment of a currently under-used brownfield site;

         •     the proposed development will offer extensive site remediation benefits and will bring this
               vacant wharf site back into beneficial use;

         •     enhanced public transport accessibility to the site provided by the provision of a Thames
               Clipper stop;

         •     the development will create a unique landmark cluster of high quality buildings of
               exemplary design;

         •     the scheme will provide a range of residential units to suit the needs of different groups in
               the borough, including a proportion of affordable housing;

         •     the scheme will provide residential accommodation of a high quality standard which will
               comply with the Mayor’s residential unit standards and will provide large and high quality
               amenity spaces and child play spaces;

         •     reinstatement of the Thames Path within the boundary of the site will further enhance the
               accessibility of the site and will provide a pedestrian link for existing and future residents
               of the area, connecting the site to Lovell’s Wharf to the south and the existing path to the
               north;

         •     the provision of a skills academy will deliver high quality, modern education and training
               facilities which will contribute to the identified need for education and training facilities in
               the borough;




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         •     the proposed development will generate 178 jobs throughout the construction phase, and
               a further 365 full time jobs once it is operational, in addition to the 250 jobs which are to
               be retained on the consolidated Alcatel site; and

         •     the proposed development will utilise sustainable and energy efficient building
               techniques and will achieve Code for Sustainable Homes Level 4, and BREEAM Level
               Excellent, along with carbon dioxide emissions reduction of 70%.




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4.       PLANNING POLICY FRAMEWORK
4.1      The proposals for the redevelopment of the Enderby Wharf site must take account of relevant
         national, regional and local planning policy. This section of the Planning Statement sets out
         the relevant national, regional and local policies, and demonstrates the support of the adopted
         and emerging policy framework for the proposals.


        Adopted Planning Policy Framework

4.2      In accordance with Section 38 (6) of the Planning and Compulsory Purchase Act (2004),
         planning applications should be determined in accordance with the development plan unless
         other material considerations indicate otherwise.

4.3      The relevant development plan is the saved policies of the London Borough of Greenwich
         Unitary Development Plan (UDP), adopted July 2006 and the London Plan (consolidated with
         changes since 2004), published February 2008.

4.4      In considering the development proposals, other key documents which will form material
         considerations in the determination of the planning application include national Planning
         Policy Guidance notes (PPGs) and Planning Policy Statements (PPSs), regional planning
         documents including the Greater London Authority’s (GLA) London View Management
         Framework, and local planning policy documents including the Planning Obligations
         Supplementary Planning Document.


        Emerging Planning Policy Framework

4.5      In accordance with the Planning and Compulsory Purchase Act (2004), the UDP is being
         replaced by the Local Development Framework (LDF), a portfolio of documents intended to
         collectively deliver the spatial strategy for each Local Planning Authority’s area.

4.6      The London Borough of Greenwich most recently consulted on its Core Strategy (Issues and
         Options draft) in February 2008. It is understood that the Council is targeting a further round
         of consultation on the Core Strategy, to include Development Management policies, to
         commence in November 2010. Following this, it is expected that the Core Strategy will be
         submitted to the Secretary of State in summer 2011, with adoption targeted for summer 2012.
         Given the early stage of the emerging Core Strategy, this document forms a material
         consideration in the determination of planning applications, albeit with limited weight.




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4.7      Since being elected as the Mayor of London in May 2008, Boris Johnson has published a
         number of documents which will replace the existing London Plan and its supporting
         documents, including the following:

         •     Draft Mayor’s Transport Strategy (consultation October 2009 to January 2010);

         •     Draft Mayor’s Economic Development Strategy (consultation October 2009 to January
               2010);

         •     Draft Climate Change Adaptation Strategy for London (February 2010);

         •     The Mayor’s Vision for London’s Waste (January 2010);

         •     The Mayor’s Draft Climate Change Mitigation and Energy Strategy (consultation with the
               London Assembly and functional bodies, February 2010);

         •     Interim Housing Supplementary Planning Guidance (April 2010);

         •     London Housing Design Guide Interim Edition (August 2010); and

         •     The Mayor’s Draft Air Quality Strategy (consultation March 2010).

4.8      These documents form material considerations in the determination of planning applications
         and so will be considered throughout Section 5 of this Planning Statement, as appropriate.

4.9      The Draft Replacement London Plan, published in October 2009, is currently subject to an
         Examination in Public. Following the conclusion of this, which is scheduled to be in October
         2010, it is expected that the document will be formally published in 2011. At this time, the
         policies contained in the 2008 London Plan will be superseded.


        Site Specific Allocations

4.10     The London Plan identifies Strategic Industrial Locations throughout London and it is stated
         that this framework is intended to reconcile the demand for, and supply of, productive
         industrial land in London. Strategic Industrial Locations include two types of areas, Industrial
         Business Parks (IBP) for businesses requiring a high quality environment, and Preferred
         Industrial Locations (PIL) for businesses with less demanding requirements.         The site at
         Enderby Wharf is located within the Greenwich Peninsula West PIL.

4.11     The site is further designated in the adopted UDP as within a Defined Industrial Area where
         commercial and employment uses (within Use Classes B1, B2 and B8) are “particularly suited
         and safeguarded”.




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         Greenwich Peninsula and Charlton Riverside West Opportunity Area

4.12     The Greenwich Peninsula area is identified as an Opportunity Area within both the 2008 and
         Draft Replacement London Plans. Policy 5D.2 of the 2008 London Plan states that, taking
         account of other policies, developments within the Opportunity Areas will be expected to
         maximise residential and non-residential densities and contain a mix of uses. The Greenwich
         Peninsula and Charlton Riverside West Opportunity Area, which includes the site at Enderby
         Wharf, has an indicative employment capacity of 7,500 additional jobs between 2001 and
         2016, and sets a minimum housing provision over the same period of 15,000.

4.13     The 2008 London Plan and the Draft Replacement London Plan identifies the Opportunity
         Area has having the capacity for substantial development which could contribute to the wider
         regeneration of the Thames Gateway and states that the main focus of development should
         be towards the north of the peninsula, surrounding the O2 and North Greenwich Jubilee Line
         Station.


         Greenwich Peninsula Development Framework

4.14     The London Borough of Greenwich produced a Development Framework for the Greenwich
         Peninsula area in 2002. This sets out the parameters for the future development of the area
         over a fifteen to twenty year period.         It is stated that the purpose of the Development
         Framework is to:

         •     highlight the ‘Strategic Intent’ for the area;

         •     promote investor confidence by giving clear guidance;

         •     allow flexibility for changes over time;

         •     promote environmental sustainability;

         •     address community needs; and

         •     address issues relating to quality of life.

         Local Site Specific Allocations

4.15     The site is also subject to a number of allocations, as set out in the adopted UDP, as follows:

         •     the site is within the Thames Gateway Area, where the Council will seek a high quality of
               design;

         •     the southern boundary of the site is partially within a Local Park Deficiency Area;




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         •     the site is within an area more than 1km from a publicly accessible site of Metropolitan
               Borough Importance for Nature Conservation and is therefore classed as an Area of
               Wildlife Deficiency;

         •     the site is within an area at risk from a 1 in 100 year tidal flooding event, but is protected
               by existing defences against a 1 in 1,000 year event;

         •     the site is within three Local View Zones:

               •   a) – from Shooter’s Hill to Central London;

               •   e) – Eltham Park North to Central London; and

               •   i) – the Docklands Panorama from the Wolfe Memorial.

         •     the proposed Thames Cycle Route runs along the western boundary of the site;

         •     the site is within an Area of Archaeological Potential;

         •     the site is within the designated Waterfront Area; and

         •     the site is south of a Safeguarded Wharf, where the Council will seek to ensure that all
               practicable measures are employed to minimise the potential conflicts between wharf
               operations and adjoining uses.

4.16     Further discussion of these designations will be covered in Section 5 of this Planning
         Statement.




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5.       PLANNING ASSESSMENT
5.1      This Section of the Planning Statement assesses the proposals against the national, regional
         and local planning policy framework as set out above.


        Overview of the Principle of Development

5.2      National government policy encourages developers to optimise the potential of previously
         developed sites in order to achieve the overarching objectives of sustainable development.
         Planning Policy Statement 1 (PPS1): Delivering Sustainable Development (2005) sets out the
         overarching planning policies to be used for the delivery of sustainable development through
         the planning system. PPS1 promotes the more efficient use of land through higher density,
         mixed-use development, and states that planning should actively seek to bring underused
         previously developed land back into beneficial use to help in the achievement of Government
         targets set for development on brownfield sites.

5.3      Planning Policy Statement 3 (PPS3): Housing (2010) also recognises that using land
         efficiently is a key consideration in planning for housing, and encourages an efficient and
         effective use of land, including the re-use of previously developed land, where appropriate.

5.4      The Government’s objective of maximising the opportunities presented by sites is reflected at
         strategic policy level within the Mayor’s London Plan (2008). Objective 1 of the London Plan
         is to accommodate London’s growth within its boundaries without encroaching into open
         spaces, making the most sustainable and efficient use of space in London. Intensification and
         growth is to be encouraged in areas of need and opportunity, whilst promoting a low carbon
         city and seeking to mitigate climate change.

5.5      Planning Policy Statement 4 (PPS4): Planning for Sustainable Economic Growth (2009) sets
         out a number of policies for securing the Government’s overarching objective of sustainable
         economic growth. Policy EC2 of PPS4 seeks to prioritise previously developed land and to
         make the most efficient and effective use of land.

5.6      Planning Policy Guidance Note (PPG13): Transport (2001) reinforces the aim of maximising
         development potential by encouraging planning authorities to plan for increased intensity of
         development at locations which are highly accessible by a number of means of transport or
         where infrastructure improvements are planned.




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5.7      The site is within the South East Sub-Region, as designated in the 2008 London Plan, where
         strategic priorities include the following:

         •     promote the Sub-Region’s contribution to London’s world city role;

         •     optimise the development of Opportunity Areas;

         •     ensure that new housing provision is complemented by adequate social and other
               infrastructure; and

         •     manage the release of surplus industrial land.

5.8      Policies SW1 and SW2 of the adopted LBG UDP support the redevelopment and re-use of
         redundant land and buildings adjacent to the River Thames in bringing about regeneration to
         realise the economic, social, environmental, cultural and recreational potential of the area as a
         whole.


        Site Suitability and Release of Strategic Industrial Land

5.9      As set out above, the site is located within the Greenwich Peninsula West PIL, which is part of
         a Strategic Industrial Location, as designated by the London Plan. Policy 3B.4 of the 2008
         London Plan sets out guidance for the management of Strategic Industrial Locations and
         identifies the potential for surplus industrial land to help in meeting strategic and local
         requirements for a mix of other uses such as housing and social infrastructure.

5.10     The London Borough of Greenwich is identified in the Industrial Capacity SPG (March 2008)
         as a borough where there should be limited transfer of industrial sites. Boroughs are required
         to, taking account of local variations and demand, “manage and where possible, reconfigure
         their portfolios of industrial land, safeguarding the best quality sites and phasing release to
         reduce vacancy rates for land and premises”. The London Borough of Greenwich is identified
         within the South East London Sub-Region, where 29 hectares of land in Greenwich,
         Lewisham and Southwark is to be released between 2011 and 2016 (following 61 hectares to
         be released between 2001 and 2011).

5.11     The 2008 London Plan identifies that the South East London Sub-Region contains more than
         15% of London’s industrial land and eleven of its SILs. It is stated in paragraph 5.127 of the
         London Plan that stock should be “managed to use most effectively and to ensure the release
         of surplus capacity to more productive uses, especially housing”.

5.12     The London Plan, in line with Government guidance set out in the Sustainable Communities
         Plan (2003), prioritises the release of surplus industrial land to meet the increasing need for




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         new homes, where this would not lead to a strategic imbalance between supply and demand
         for industrial use.    Further discussion of the release of industrial land is set out in the
         Employment Land Study (Reference EW09) prepared by GVA Grimley.

5.13     The proposals fully accord with the general principles of national, regional and local planning
         policy. The redevelopment of the Enderby Wharf site represents a highly efficient use of
         brownfield site and the principle of the proposed development has been considered
         acceptable to officers at both the London Borough of Greenwich and the Greater London
         Authority. Set out below is an assessment of the key planning considerations.


        Land Use

        Cruise Liner Terminal

        Policy Context

5.14     The 2008 London Plan does not have any specific policies relating to the provision of a cruise
         liner terminal in London, however, the Draft Replacement London Plan includes commentary
         setting out that “options for a cruise liner terminal in an appropriate location such as
         Greenwich should be explored”. Policy 7.25 further states that the Mayor will seek to increase
         the use of the Blue Ribbon Network for passenger and tourist river services, and the policy
         supports the principle of additional cruise liner facilities on the Thames. This policy supports
         boroughs in identifying locations that are suitable for passenger, tourist, or cruise liner
         facilities.

5.15     As set out above, the Greater London Authority and London Development Agency
         commissioned a research paper into the cruise liner industry in London. This document, An
         Assessment of Current and Future Cruise Ship Requirements in London (June 2009), made a
         number of conclusions, including the following:

         •     demand for cruising continues to be strong and demand for cruise ship visits to London
               are likely to increase if they can be adequately accommodated;

         •     current facilities and conditions are restricting growth and will do so in the future;

         •     there are few potential locations for a new terminal;

         •     a new terminal in central London should include facilities for handling turnaround calls;
               and




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         •     in order to maximise the potential of a new terminal, there needs to be a coordinated and
               committed approach to marketing.

5.16     The report considered eleven potential sites for a new cruise terminal for London. Having
         considered each site, the report identified Enderby Wharf with a clear advantage due to the
         location of existing and self-scouring deep water outside the wharf and the proximity of the
         Maritime Greenwich World Heritage Site.

5.17     As set out above, strategic policy directions for the Greenwich Peninsula Opportunity Area as
         set out in the Draft Replacement London Plan include the principle that “[a]ny release of
         industrial capacity should be managed in the sub-regional context and as part of the planning
         framework, recognising the roles of safeguarded wharves and the potential for a cruise liner
         terminal”.

5.18     Policy W6 of the LB Greenwich UDP states that proposals to moor temporary or permanent
         floating vessels on the Thames must:

         •     sympathetically relate to historic waterfront and riverside areas;

         •     positively contribute to the River’s life and scene;

         •     not compromise existing or potential River transportation, nor adversely effect existing or
               potential wharfage operations, industrial and employment-generating activities;

         •     not unduly impact on the River, its foreshore and environs through ecological disruption,
               pollution, noise and refuse generation; and

         •     not conflict with residential amenity, use of the River for tourism and recreation, nor with
               other policies in the Plan and other Council strategies.

        Planning Assessment

5.19     As set out above, the London Waterways Commission commissioned via the London
         Development Agency and the Greater London Authority, with support from the Port of London
         Authority, a report which considered the economic need for a cruise liner terminal to serve
         London, together with an assessment of potential sites. The Assessment of Current and
         Future Cruise Ship Requirements in London, published in June 2009, identified London as a
         ‘marquee’ (must-see) destination, but concluded that the lack of a purpose built cruise liner
         facility represented a significant missed economic opportunity.

5.20     Whilst global passenger numbers are expected to increase by 80% up to 2020, and cruise
         traffic at Dover, Harwich, Southampton and Tilbury has risen by 30% between 2006 and 2008,




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         cruise passengers visiting Central London are declining.        The report concluded that the
         existing cruise facilities “do not reflect well on London as a global city and international
         tourism destination” and stated that the number of cruise calls could treble from approximately
         22 in 2009 to 70 in the short terms if a new cruise facility was provided.

5.21     The Assessment of Current and Future Cruise Ship Requirements in London (June 2009)
         considered eleven potential sites for a new cruise terminal for London. Having considered
         each site, the report identified Enderby Wharf with a clear advantage due to the location of
         existing and self scouring deep water outside the wharf, the presence of Maritime Greenwich
         represented by the nearby World Heritage Site, and the emerging proposals being brought
         forward by West Properties which form the subject of this application.

5.22     The redevelopment of the site provides a unique opportunity to provide a cruise liner terminal
         for the London Borough of Greenwich and London as a whole, and this key piece of
         infrastructure generates the additional opportunity to deliver wider regeneration benefits for
         the site and surrounding area.

5.23     The proposals for the redevelopment of Enderby Wharf provide a unique opportunity for the
         delivery of a much needed cruise liner terminal for Greenwich and London as a whole, and,
         through the provision of a mix of land uses, will also significantly contribute to the delivery of
         the borough’s housing targets, as well as generating wider regeneration benefits. The release
         of this PIL is fully justified within the Employment Land Study (Reference EW09) submitted in
         support of the application proposals, and has been the subject of extensive discussions with
         the Greater London Authority and London Borough of Greenwich.


        Residential

        Policy Context

5.24     Planning Policy Statement 3 (PPS3): Housing (2010) provides Government guidance on the
         provision of housing and states that housing developments should make efficient use of land.
         Proposed housing developments should be easily accessible and well-connected to public
         transport and community facilities. PPS3 further seeks to create sustainable, inclusive, mixed
         use communities in all areas, and provides a national annual target of at least 60% of new
         housing to be provided on previously developed land, including land and buildings that are
         vacant or derelict, as well as land that is currently in use but which has potential for
         redevelopment.




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5.25     PPS3 sets specific objectives that the planning system should deliver, including the following:

         •     high quality housing that is well-designed and built to a high standard;

         •     a mix of housing, both market and affordable, particularly in terms of tenure and price, to
               support a wide variety of households in all areas;

         •     a sufficient quantity of housing, taking into account need and demand, and seeking to
               improve choice;

         •     housing developments in suitable locations, which offer a good range of community
               facilities and with good access to jobs, key services and infrastructure; and

         •     a flexible, responsive supply of land, managed in a way that makes efficient and effective
               use of land, including the re-use of previously development land where appropriate.

5.26     The requirement for additional homes is a key priority of both the 2008 London Plan and the
         emerging Draft Replacement London Plan. The 2008 London Plan seeks to meet and exceed
         the target for 30,500 additional homes per year in London between 2007 and 2017 and sets
         an annual monitoring target for the London Borough of Greenwich of 2,010.               The Draft
         Replacement London Plan sets out an increased London-wide housing target of 33,400
         additional homes per year, and a revised target for Greenwich of 2,595 houses per year
         (Policy 3.3).

5.27     The Mayor’s Housing SPG (2005) supports the London Plan in seeking to make the best use
         of available sites for the development of housing. The SPG further recognises that many of
         London’s most successful residential neighbourhoods are formed of higher density housing
         stock.

5.28     Adopted Policy H1 of the LB Greenwich UDP states that residential development will be
         acceptable on environmentally suitable sites, and where residential uses on such sites would
         not conflict with other policies and proposals of the Plan. In seeking to deliver sustainable
         development, Policy H1 sets a target of 90% of new dwellings to be provided on previously
         developed land.

5.29     UDP Policy H7 requires new residential development to deliver a high quality of housing
         design and environment and states that in considering proposals, the Council will take into
         account the key relationships between the character of the area, the site location, public
         transport accessibility, car parking and housing densities. Policy H7 sets out a number of
         criteria which will be given particular regard in the consideration of applications for residential




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         accommodation, including landscaping, dwelling mix and privacy.           These, and the other
         relevant considerations, are discussed in more detail further in this Section.


        Planning Assessment

5.30     As set out in Section 3 of this Planning Statement, it is proposed that 770 residential units are
         to be provide as part of the comprehensive redevelopment of the site. This land use will
         complement the other proposed uses and will assist in the creation of sustainable, inclusive
         and mixed communities, as sought by PPS3.

5.31     The proposed residential accommodation will be exemplary in terms of its unit sizes, mix and
         layouts, as set out in further detail later in this Planning Statement.      The proposals are
         therefore fully in accordance with national, regional and local policy, through the provision of
         high density, high quality residential accommodation in a sustainable and accessible location.


        Hotel

        Policy Context

5.32     The Government’s Good Practice Guide on Planning for Tourism (2006) states that, in
         providing tourist accommodation such as hotels and serviced apartments, emphasis should
         be on identifying the most suitable locations.

5.33     Policy 3D.7 of the London Plan outlines the Mayor’s Tourism Vision to achieve 40,000 net
         additional hotel bedrooms by 2026, and to improve the quality, variety and distribution of
         visitor accommodation and facilities.

5.34     Policy 4.5 of the Draft Replacement London Plan states that boroughs should support
         London’s visitor economy by seeking to achieve 40,000 net additional hotel bedrooms by
         2031 in locations with good access to public transport, of which at least 10% should be
         wheelchair accessible.

5.35     UDP Policy ST1 states that the Council supports and promotes tourism, and recognises that it
         has a positive and significant role to play in securing the economic and environmental
         regeneration of the borough, and particularly in the Waterfront areas, which includes the site
         at Enderby Wharf.

5.36     Policy T3 of the UDP states that the Council will seek to diversify the tourism base of the
         borough by encouraging the provision of a range of tourism facilities and ensuring that a
         geographical spread of sites are available for good quality tourism development. Policy T1




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         states that the Council will welcome proposals for major tourism development including hotels
         providing more than 10 ‘bedspaces’ in identified Waterfront locations with good public
         transport access, subject to other provisions of the UDP.

5.37     Policy ST2 further seeks to promote the provision of facilities for tourists in appropriate
         locations subject to the need to:

         •     protect the housing stock, the amenities of the local community and the environment of
               the borough;

         •     ensure that tourism is managed to provide benefits for local communities and businesses;

         •     diversify the tourism base of the borough’s economy by seeking facilities which embrace
               a wide range of arts, culture, sporting and entertainment activities for participation and
               enjoyment by all sections of the community; and

         •     that major tourist facilities are well served by public transport.

        Planning Assessment

5.38     The scheme proposes to provide a 251 bedroom hotel (14,474 sqm) on the northern
         boundary of the site. This will include conference facilities and a restaurant for use by hotel
         guests.

5.39     The hotel will support the function of the proposed cruise liner terminal by providing
         accommodation for visitors using the cruise liner facilities, either before or after their main
         cruise journey. The hotel will also provide accommodation for other visitors to the surrounding
         area, and will contribute to delivering a mix of land uses on the site.

5.40     The delivery of a hotel in this riverside location is in accordance with local policy guidance, will
         assist in the achievement of the Mayor’s Tourism Vision and is fully in accordance with
         national, regional and local policy guidance relating to the provision of hotel accommodation.


        Commercial Uses

        Policy Context

5.41     Planning Policy Statement 4 (PPS4): Planning for Sustainable Economic Growth (2009) sets
         out a number of policies for securing the Government’s overarching objective of sustainable
         economic growth. Policy EC2 of PPS4 seeks to prioritise previously developed land and to
         make the most efficient and effective use of land.           Policy EC10 further states that local
         planning authorities should adopt a positive and constructive approach towards planning




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         applications for economic development and that such applications should be assessed
         against a number of impact considerations, as follows:

         •     carbon dioxide emissions over the lifetime of the development and its overall resilience to
               climate change;

         •     accessibility of the proposal by a choice of means of transport, including walking, cycling,
               public transport and the private car;

         •     high quality and inclusive design;

         •     impact on economic and physical regeneration; and

         •     impact on local employment.

5.42     Policy 3B.1 of the 2008 London Plan seeks to support and develop London’s economy as one
         of three world cities by seeking a range of workspaces of different types, sizes and costs to
         meet the needs of different sectors of the economy. Policy 3B.2 further seeks to increase the
         provision of office floorspace, especially through changes of use and development of vacant
         and brownfield sites. This policy seeks the renovation and renewal of existing office stock to
         increase and enhance the quality and flexibility of London’s office market offer.

5.43     Policy 4.1 of the Draft Replacement London Plan seeks the promotion and continued
         development of a strong and increasingly diverse economy across all parts of London,
         ensuring the availability of sufficient and suitable workspaces in terms of type, size and cost.
         Policy 4.2 further states that boroughs should support the management and mixed use
         development and redevelopment of office provision to improve London’s competitiveness and
         to address the wider objectives of the London Plan, including enhancing its varied attractions
         for businesses of different types and sizes.

5.44     Policy 4.3 of the Draft Replacement London Plan states that mixed use development and
         redevelopment should support consolidation and enhancements to the quality of the
         remaining office stock.     It is stated in Policy 4.4 that boroughs should adopt a rigorous
         approach to industrial land management to ensure a sufficient stock of land and premises to
         meet the future needs of different types of industrial and related uses in different parts of
         London, including for good quality and affordable space.

5.45     The Mayor of London seeks to improve employment opportunities for Londoners and states
         that strategic development proposals should support local employment, skills development
         and training opportunities (Draft Replacement London Plan Policy 4.12).




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5.46     Policy J1 of the LB Greenwich UDP states that Defined Industrial Areas, such as Enderby
         Wharf, are particularly suited and safeguarded for activities within Use Classes B1, B2 and
         B8.   The policy further states that other uses will not be permitted unless they are ‘Sui
         Generis’ uses that are industrial in character, or local service uses to predominantly serve
         businesses within walking distance of the site.

5.47     UDP Policy J7 states that activities within Use Class B1 will normally be permitted in locations
         including Defined Industrial Areas provided that they are of an appropriate scale, deliver
         appropriate environmental and traffic impacts, and that the site is not allocated or safeguarded
         for another use elsewhere in the UDP.


        Planning Assessment

5.48     As set out above, the site is within a Defined Industrial Area, where B1 floorspace is
         considered to be “particularly suitable”. As set out in Section 3 of this Planning Statement,
         the proposed development seeks to include the provision of 594 sqm of ‘start-up’ business
         accommodation. The proposed floorspace will be of a high quality and will provide flexible
         space for small and medium sized enterprises (SMEs). The proposed floorspace will provide
         an increased number of employment opportunities for local people, as detailed in Chapter 6:
         Socio-Economics of the Environmental Statement Volume I (Reference EW05).

5.49     Given the nature of the proposals for the cruise liner terminal, and the other proposed uses
         that will seek to support this, it is considered that the provision of employment floorspace will
         further add to the mix of land uses on site, in accordance with PPS1. The proposals will also
         accord with policy guidance set out in the London Plan, which seeks to increase and enhance
         the quality and flexibility of London’s office market offer.

5.50     The development proposals have developed through consultation with the London Borough of
         Greenwich and it is considered that the provision of office floorspace in this location is fully in
         accordance with national, regional and local planning policy guidance.


        Skills Academy

        Policy Context

5.51     PPS3 recommends that the planning system should deliver housing developments in suitable
         locations, which offer a good range of community facilities.




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5.52     Policy 3A.18 of the London Plan seeks the increased provision of community facilities in
         locations that are within easy reach by walking and public transport for the population that use
         them.

5.53     The Draft Replacement London Plan recommends that development should support the
         provision of additional social infrastructure in light of local and strategic needs assessments
         and reaffirms Policy 3A.18 of the existing London Plan with regard to accessing community
         facilities (Policy 3.17). The Draft Replacement London Plan further advises that multi-use
         community centres that provide flexible and accessible spaces adaptable to communities’
         needs should be encouraged (Paragraph 3.82).

5.54     UDP Policy J14 supports the establishment of training centres, training workshops and other
         training provision to develop the skills of the borough’s workforce. Policy J15 further states
         that in appraising proposals which include employment development schemes, the Council
         will use planning agreements to secure community and workplace benefits as appropriate.


        Planning Assessment

5.55     The provision of a skills academy to deliver education and training facilities as part of the
         Enderby Wharf redevelopment proposals will accord with national, regional and local planning
         policy. The delivery of the skills academy will meet an identified need and will contribute to
         the achievement of Objective 4 of the LB Greenwich UDP which seeks to tackle
         unemployment, concentrated deprivation and homelessness by broadening access to
         education, advice and training services.


        Other Supporting Uses: Café, Gymnasium and Crèche

        Policy Context

5.56     PPS4 seeks to build prosperous communities by improving the economic performance of
         cities, towns, regions, sub-regions and local areas. PPS4 further aims to promote the vitality
         and viability of town centres as important places for communities. The flexibility of mixed use
         development in facilitating a broad range of economic development is acknowledged.

5.57     The 2008 London Plan supports national Government policy in relation to protecting and
         enhancing town centres. The Plan acknowledges that increased housing provision at higher
         densities can enhance the vitality and vibrancy of town centres, levering in resources for
         comprehensive town centre renewal as part of mixed use redevelopment and expansion.
         Policy 3D.3 seeks for provision to be made for retail uses within new residential communities.




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5.58     Policy 4.8 of the Draft Replacement London Plan recommends that local policies should
         support additional retail facilities at an appropriate scale in locations which are under-served
         in local convenience shopping and services provision, and are accessible by walking, cycling
         and public transport.


        Planning Assessment

5.59     The proposed development incorporated a mix of uses in addition to the cruise liner terminal,
         residential accommodation and hotel. This includes a crèche (251 sqm) and gymnasium (304
         sqm) and it is also proposed that as part of the extension and refurbishment proposals for
         Enderby House, a café (773 sqm) will be provided.

5.60     The mix of uses proposed is fully in accordance with national, regional and local policies
         relating to sustainable, large scale residential development. The provision of these uses will
         help to meet the needs created by additional residents and guests of the hotel and cruise
         liners, and will create further activity at ground floor level throughout the scheme.

5.61     The provision of this land use accords with the principles of providing a mixed-use
         development, which is encouraged by national, regional and local planning policy.                Its
         provision will help to meet the needs of both residents and visitors of the site, and will create
         activity at ground floor level, thus contributing further to the regeneration of the public realm at
         the site.


        Townscape and Design

        Policy Context

5.62     PPS1 promotes high quality and inclusive design in the creation of well mixed and integrated
         developments which avoid segregation, and which have well planned public spaces. PPS1
         recognises that good design ensures attractive, usable, durable and adaptable places and is a
         key element in achieving sustainable development.

5.63     CABE’s guidance, By Design (Urban Design in the Planning System: Towards Better
         Practice) (2000) lists seven criteria by which to assess urban design principles, as follows:
         character, continuity and enclosure, quality of the public realm, ease of movement, legibility,
         adaptability and diversity.

5.64     Policy 4B.1 of the 2008 London Plan sets out the design principles for a compact city, stating
         that developments should (amongst other things), maximise the potential of sites, promote




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         high quality inclusive design and create or enhance the public realm, respect local context,
         history, built heritage and communities, be accessible, usable and permeable for all users, be
         sustainable, durable and adaptable in terms of design, construction and use, address security
         issues and provide safe, secure and sustainable environments, be attractive to look at and,
         where appropriate, inspire, excite and delight. Policy 4B.2 further states that the Mayor seeks
         to promote world class design.

5.65     Policy 7.4 of the Draft Replacement London Plan states that developments should have
         regard to the form, function and structure of an area, including the scale, mass and orientation
         of surrounding buildings. The policy further states that buildings should provide contemporary
         architectural responses that:

         •     have regard to the pattern and grain of existing spaces and streets in orientation, scale,
               proportion and mass;

         •     contribute to a positive relationship between the urban structure and local natural
               landscape features;

         •     are human in scale;

         •     allow existing buildings and structures that make a positive contribution to the character
               of a place to influence the existing character of the area; and

         •     are informed by the surrounding historic environment.

5.66     Policy 7.6 of the Draft Replacement London Plan further states that architecture should make
         a positive contribution to a coherent public realm, streetscape and wider cityscape,
         incorporating the highest quality materials and design appropriate to its context.

5.67     UDP Policies SD1 and D1 seek to encourage a high quality of design in all new developments
         and are expected to adhere to the following criteria:

         •     provide a positive relationship between the proposed and existing urban context by taking
               account of:

               •   topography, landscape setting, ridges and natural features;

               •   existing townscape, local landmarks, views, and skylines;

               •   the architecture of surrounding buildings;

               •   the quality and nature of materials, both traditional and modern;

               •   established layout and spatial character;




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               •   the scale, height, bulk and massing of adjacent townscape;

               •   features of architectural, historical, archaeological, biodiversity and their setting;

               •   the effective use of land;

               •   the potential for a mix of uses;

               •   patterns of activity, movement and circulation; and

               •   the cultural diversity of the area.

         •     promote local distinctiveness by providing a site-specific design solution;

         •     demonstrate through proposed land uses, layout and design that the development
               contributes to a safe and secure environment for users and the public. (Policy D7);

         •     achieve accessible and inclusive environments for all, including disabled people;

         •     integrate with existing path and circulation networks and patterns of activity;

         •     create attractive, manageable well-functioning spaces within the site;

         •     maintain adequate daylight and sunlight to adjoining buildings and land;

         •     maximise energy conservation, through effective layout, orientation, use of appropriate
               materials, detailing and landscape design; and

         •     achieve the Building Research Establishment’s BREEAM Excellent rating which
               addresses a wide variety of environmental issues.

5.68     Policy W2 of the LB Greenwich UDP seeks a high quality of design, respecting the special
         character of the River Thames within the Thames Policy Area as defined on the Proposals
         Map. Policy D4 seeks to achieve improvements to both the urban and natural environment.
         In addition, Policy D7 requires all development to be designed to provide and improve
         personal safety and security in the environment.

5.69     Policy D27 of the UDP states that planning permission will be given for developments which
         would not have a seriously adverse effect on the overall perspective and essential quality of
         the Local Views as identified in the UDP.


        Planning Assessment

5.70     The proposed development provides an extremely high quality scheme which will significantly
         enhance the appearance of the Enderby Wharf site and its surrounding area. The proposals
         are in accordance with the design principles set out in national, regional and local policy
         guidance.




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5.71     The site occupies a brownfield site in an accessible location and as such, the redevelopment
         opportunities of the site have been optimised through the proposed development. The high
         quality proposals comprise a unique and innovative design solution which responds effectively
         to the site’s riverside location, its capacity, and the character of both the industrial area and
         the emerging residential proposals to the south at Lovell’s Wharf.

5.72     The proposals have developed through close consultation with officers at the London Borough
         of Greenwich and have been presented to the GLA and CABE throughout the pre-application
         process, where they have secured a high level of support.

5.73     Further discussion of the design evolution process and the final design proposals is presented
         in the Design and Access Statement (Reference EW04), prepared by Ian Simpson Architects,
         and submitted as part of this application.

5.74     The proposals have also been fully assessed as part of the Environmental Impact
         Assessment.       Environmental Statement Volume II:          Townscape and Visual Impact
         Assessment (Reference EW06), prepared by GMJ and Robert Tavernor Consultancy,
         demonstrates through accurate visual representations how the scheme has been designed to
         accord with the principles and objectives of the relevant planning policies of the LB Greenwich
         UDP, the Mayor’s London Plan and national planning policy guidance. This assesses the
         proposed development from a number of viewing points and concludes that it will be a high
         quality development that will relate well to existing and consented buildings, and will
         contribute to the emerging three-dimensional form of the City’s skyline.


        Heritage and Conservation

        Policy Context

5.75     Planning Policy Statement 5 (PPS5): Planning for the Historic Environment (2010) sets out
         the Government’s national policy guidance on the conservation of the historic environment.
         This document sets out the Government’s overarching aim for the historic environment, which
         is that the historic environment and its heritage assets should be conserved and enjoyed for
         the quality of life they bring to this and future generations. Key objectives for planning for the
         historic environment, as set out in PPS5, are as follows:

         •     to deliver sustainable development by ensuring that policies and decisions concerning the
               historic environment:

               •   recognise that heritage assets are a non-renewable resource;




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               •    take account of the wider social, cultural, economic and environmental benefits of
                    heritage conservation; and

               •    recognise that intelligently managed change may sometimes be necessary if heritage
                    assets are to be maintained for the long term.

        •      to conserve England’s heritage assets in a manner appropriate to their significance by
               ensuring that:

               •    decisions are based on the nature, extent and level of that significance, investigated
                    to a degree proportionate to the importance of the heritage asset;

               •    wherever possible, heritage assets are put to an appropriate and viable use that is
                    consistent with their conservation;

               •    the positive contribution of such heritage assets to local character and sense of place
                    is recognised and valued; and

               •    consideration of the historic environment is integrated into planning policies,
                    promoting place-shaping.

        •      to contribute to our knowledge and understanding of our past by ensuring that
               opportunities are taken to capture evidence from the historic environment and to make
               this publicly available, particularly where a heritage asset is to be lost.

5.76     Policy 4B.11 of the London Plan seeks to maintain and increase the contribution of the built
         heritage to London’s environmental quality, the economy, and to the well-being of London’s
         people whilst allowing for London to accommodate growth in a sustainable manner. Policy
         4B.12 seeks to ensure that the protection and enhancement of historic assets in London is
         based on an understanding of their special character and states that this should form part of
         the wider design and urban improvement agenda.

5.77     As set out above, Policy 7.8 of the Draft Replacement London Plan further seeks to identify,
         preserve and restore London’s historic environment (including natural landscapes,
         conservation areas, heritage assets, World Heritage Sites, Scheduled Ancient Monuments
         and memorials) and states that new development in the setting of heritage assets should be
         sympathetic to their form, scale, materials and architectural detail. Policy 7.10 further states
         that new development in the setting of a World Heritage Site should not have a negative
         impact on the Site’s ‘Outstanding Universal Values’.

5.78     Policy 7.9 of the Draft Replacement London Plan states that regeneration schemes should
         make use of heritage assets and reinforce the qualities that make such assets significant. In




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         accordance with this policy, new development should repair, refurbish and re-use heritage
         assets.

5.79     In accordance with Policy D24 of the UDP, proposals which would adversely affect the
         character or appearance of historic landscapes will not be permitted. UDP Policy D18
         identifies a presumption in favour of the preservation of listed building consent and states that
         listed building consent will only be granted for demolition or partial demolition in exceptional
         circumstances, and will be assessed against the following criteria:

         •     the condition of the building and the cost of repairs relative to its importance;

         •     the adequacy of efforts made to return the building to use; and

         •     the merits of alternative proposals for the site.

5.80     Proposals for external or internal alterations or additions to listed buildings are required to
         respect the integrity of the buildings and “harmonise with their special architectural or historic
         character” in accordance with UDP Policy D19. Policy D21 further states that proposals for
         change of use of listed buildings will only be granted planning permission if it is no longer in its
         original or other established historic use, and the new use is beneficial to the building and
         compatible with its character and features of historic interest.


        Planning Assessment

5.81     The development site includes the Grade II listed Enderby House, which is to be retained as
         part of the development proposals. In accordance with Policy HE7 (Policy Principles Guiding
         the Determination of Applications for Consent Relating to All Heritage Assets) of PPS5, local
         planning authorities should take into account the desirability of new development making a
         positive contribution to the character and local distinctiveness of the historic environment. It is
         stated that the consideration of design should include scale, height, massing, alignment,
         materials and use.

5.82     The proposals have been designed to be sympathetic to the setting of the listed building, and,
         in accordance with policies set out in the Draft Replacement London Plan, seeks its
         refurbishment and re-use as part of the wider development proposals. Further discussion of
         the development proposals and how they have been evolved with the regeneration of Enderby
         Wharf as an integral part of the design rationale is set out in the Design and Access
         Statement (Reference EW04) and the Heritage and Urban Design Appraisal (Reference
         LB03) prepared by KM Heritage, which includes a comprehensive PPS5 assessment of the
         proposals.




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5.83     The Townscape and Visual Impact Assessment presented in Volume II of the Environmental
         Statement (Reference EW06), prepared by GMJ and Robert Tavernor Consultancy fully
         supports the design and massing approach to the redevelopment proposals. It concludes that
         the proposed buildings and public realm and urban landscape into which the proposed
         buildings will be set will be of the highest architectural and urban design quality, and will
         integrate successfully with the existing organisation and character of buildings and spaces on
         the site and in the surrounding area.


        Landscaping and Public Realm

        Policy Context

5.84     Planning Policy Guidance Note 17 (PPG17): Open Space, Sport and Recreation (2002)
         recognises that the provision of open space assists in the regeneration and enhancement of
         the physical environment and supports the encouragement of a healthy lifestyle. PPS3 further
         identifies a commitment to high quality design in the provision of new housing developments,
         and outlines the importance of integrating play and informal recreation in planning for mixed
         communities.

5.85     The consultation paper on the new Planning Policy Statement: Planning for a Natural and
         Healthy Environment, which will replace PPG17, sets out national policy on planning for the
         natural environment, green infrastructure, open space, sport, recreation and play. The draft
         Planning Policy Statement recognises that open space can serve as a vital focal point for
         community activities and further advises that planning should deliver safe and attractive
         places to live by ensuring that people have access to high quality open spaces, green
         infrastructure and sports, recreational and play spaces and facilities which are safely and
         easily accessible.

5.86     Through Policy O10 of the LB Greenwich UDP, the Council seeks to secure improvements
         and enhancements of existing parks and public open spaces, and where appropriate, the
         creation of new parks and public open spaces. UDP Policy D3 states that development
         proposals will be expected to take account of ecological factors as well as displaying a high
         standard of landscaping.

5.87     Policy O15 states that existing footpaths will be safeguarded, and new footpaths created to
         and through open spaces and places of interest, where they do not adversely affect nature
         conservation. Policy O16 of the UDP further states that the existing riverside footpath will be
         safeguarded and improved so that a continuous signposted walk from Deptford to
         Thamesmead is created. This policy states that development proposals for riverside sites will




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         be required to incorporate provision for a riverside walkway along the river frontage or
         contribute to improvements where the existing footpath needs it. In addition to this, Policy
         O17 states that the Council will use its planning and other powers to secure the provision of
         cycleways along the riverside.


        Planning Assessment

5.88     The proposed development includes a number of landscaping proposals and extensive
         improvements to the public realm throughout the site, and surrounding Enderby House. Full
         details of these proposals are set out in the Landscape and Public Realm Strategy (Reference
         EW12), prepared by Townshend Landscape Architects.

5.89     The proposals include the provision of an ‘arrival square’ adjacent to the cruise liner terminal
         and Enderby House, designed to be a hub of activity on days of embarkment and
         disembarkment. The improved riverside walk will also deliver a key pedestrian route that runs
         alongside the River Thames at the western boundary of the site.

5.90     The proposed development also includes the provision of Tidal Gardens, which will provide
         the following ecological benefits:

         •     mitigate the impact of the proposed jetty structures;

         •     enhance natural habitats and ecology;

         •     create suitable breeding areas for Flat Fish; and

         •     provide an opportunity for improved public access and educational potential.

5.91     The proposals are in accordance with national, regional and local policy, as they will assist in
         enhancing the public realm and will serve to improve the environment surrounding the site
         and along the riverside walk.


        Transport and Accessibility

        Policy Context

5.92     PPG13 directs new development to locations that are highly accessible by public transport,
         walking and cycling, recognising that an integrated transport system is necessary to support a
         strong and prosperous economy. PPG13 states that the consideration of the location, scale,
         density, design and mix of land uses can help to reduce the need to travel, reduce the length
         of journeys, and make it safer and easier for people to access jobs, shopping, leisure facilities
         and services by public transport, walking and cycling.           PPS3 further states that a




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         consideration of housing density should be the location and level of public transport
         accessibility of the site.

5.93     Policy 3C.1 of the 2008 London Plan seeks to ensure the integration of transport and
         development by encouraging patterns and forms of development that reduce the need to
         travel by car, and to locate high trip generating development in locations with high levels of
         transport accessibility and capacity. The Mayor’s Accessible London: Achieving an Inclusive
         Environment (2004) SPG provides detailed advice and guidance on the policies contained in
         the London Plan which promote an inclusive environment in London.

5.94     Policy 7.2 of the Draft Replacement London Plan states that development proposals should
         meet the highest design standards of accessible and inclusive design so that they:

         •     can be used safely, easily and with dignity by all, regardless of disability, age, gender,
               ethnicity or economic circumstances;

         •     are convenient and welcoming with no disabling barriers;

         •     are flexible and responsive; and

         •     are realistic, offering more than one solution.

5.95     The Mayor’s Draft Transport Strategy (October 2009) reiterates the guidance set out in the
         Draft Replacement London Plan in that it seeks to improve transport opportunities for all
         Londoners and reduce transport’s contribution to climate change. The Draft Replacement
         London Plan reiterates Policy 3C.1 of the existing London Plan by seeking to reduce travel.

5.96     UDP Policy SM2 identifies pedestrians, people with disabilities, cyclists and public transport
         users as the first priority in seeking equitable levels of mobility and accessibility for all groups
         of people. Policy M1 states that transport planning for large development sites should have
         regard to the following:

         •     designing for the needs of pedestrians, people with disabilities, cyclists and public
               transport users first;

         •     arranging highways networks after these priorities;

         •     building into highways networks traffic calming and design criteria for speeds no greater
               than 20 mph and the creation of home zones;

         •     locating major activities such as schools and shops at public transport, cycling and
               pedestrian nodes;




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         •     as relevant, building into development costings provision for segregated roadways for
               Waterfront Transit as well as more conventional highways, cycle networks and pedestrian
               networks; and

         •     existing and proposed utilisation of public transport and impact upon capacity of
               networks. Close liaison with Transport for London (TfL) and the relevant railway
               undertakers will be necessary.

5.97     Policy M6 states that when considering developments that generate and / or attract significant
         public transport need and demand, the Council will take into consideration the accessibility of
         the site to and from public transport.      Policy M11 of the UDP further states that good
         interchanges between public and private modes of transport will be sought as opportunities
         arise, and that developments which improve such facilities will be sympathetically considered
         by the Council.

5.98     UDP Policy M19 requires new roads within housing developments which are to be adopted to
         have appropriate traffic calming measures incorporated into them before any dwelling is
         occupied. Policy M33 further promotes high standards of pedestrian safety, accessibility and
         convenience.


        Planning Assessment

5.99     As set out above, the Enderby Wharf site currently has a PTAL rating of 3, which indicates
         moderate accessibility to public transport. The proposed development supports the use of
         sustainable modes of travel and the proposals will optimise the use of this accessible
         brownfield location in accordance with planning policy guidance.

5.100    As part of the provision of the cruise liner docking station, the scheme also proposes to
         provide a double berth river mooring for the Thames Clipper.        This will provide two fast
         passenger services for visitors, existing and future residents per hour towards Woolwich
         Arsenal and London Bridge / Westminster Piers.           This will significantly enhance the
         accessibility of the site and the surrounding area.

5.101    A Transport Assessment (Reference EW10) and Framework Travel Plan (Reference EW11)
         have been prepared by JMP and are submitted as part of this planning application package.
         The assessment concludes that the development has been designed to maximise
         accessibility by non-car modes, and that the development would minimise any impacts on the
         surrounding roads.




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5.102    The Transport Assessment (Reference EW10) reviews the emerging transport proposals for
         the site and surrounding area and concludes that if the Greenwich Waterfront Transit, a new
         local bus route calling close to the site, and river bus services were to be introduced, the site
         would have an improved PTAL of 4/5, indicating good to very good accessibility to public
         transport.

5.103    The operation of the proposed development at Enderby Wharf is demonstrated to be wholly
         acceptable, and are therefore in accordance with national, regional and local planning policy
         guidance.


        Parking and Servicing

        Policy Context and Planning Assessment

5.104    PPG13 encourages the use of parking policies alongside other planning and transport
         measures to promote sustainable transport choices and reduce reliance on the car for work
         and other journeys.


        Car Parking

5.105    Policy 3C.23 of the 2008 London Plan seeks to ensure that on-site car parking at new
         developments is the minimum necessary and that there is no over-provision that could
         undermine the use of more sustainable non-car modes. The only exception to this approach
         will be to ensure that developments are accessible for disabled people.

5.106    The 2008 London Plan states in Annex 4 that it is not possible to prescribe parking standards
         for mixed and multi-use developments, as these differ widely. However, the London Plan
         does set maximum car parking standards for residential and non-residential developments.
         Policy M23 of the adopted UDP states that the standards for car parking for new
         developments in the London Plan should be applied.

5.107    The London Plan outlines car parking standards for non-residential developments and sets
         out a maximum provision of 1 car parking space per 600 – 1,000 sqm B1 floorspace in inner
         London (which includes development sites in the London Borough of Greenwich). Maximum
         car parking standards for residential developments are prescribed as follows: a maximum
         provision for one to two bedroom units of 1 to less than 1 space per unit; for three bedroom
         units; a provision of 1.5 to 1 space per unit; and for four bedroom plus units, 2 to 1.5 spaces
         per unit to be provided.




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5.108    Policy M27 of the LB Greenwich UDP states that in all cases, decisions on parking provision
         should incorporate a consideration of the following principles:

         •     provision for people with disabilities (‘Reducing Mobility Handicaps’ by the Institute of
               Highways and Transportation is a relevant guide);

         •     agreement with the developer that pricing and management structures should be subject
               to Council approval, particularly in the case of large shopping and mixed use
               developments;

         •     that spaces provided in a scheme are generally available and not use specific;

         •     monitoring and reviews of usage over time so that as public transport improves and car
               usage declines, spaces that are under-utilised can be released and re-used for other
               purposes e.g. landscaping, other development, public spaces etc; and

         •     in areas of high public transport accessibility standards should be even lower i.e. even
               less parking provision than might otherwise be considered acceptable or appropriate. In
               lieu, developers would be expected to contribute to public transport, cycle and pedestrian
               provision through Section 106 agreements. In some such circumstances (almost) zero
               provision of car parking would be appropriate.

5.109    The proposed development will provide 726 car parking spaces, which is within the car
         parking standards set by the London Plan and London Borough of Greenwich. Further details
         of the proposed parking provision are outlined in the Transport Assessment (Reference
         EW10), prepared by JMP.


        Cycle Parking

5.110    Cycle parking standards are taken from Transport for London’s (TfL) Cycle Parking Standards
         Proposed Guidelines document, which sets out the minimum number of spaces to be
         provided according to land use. A summary is provided in Table 2 below.

5.111    UDP Policy M32 promotes cycling in the borough and states that the needs of cyclists will be
         particularly pursued in all new developments through the following measures:

         •     freeing cyclists from the restrictions of existing and proposed traffic management
               schemes, as appropriate;

         •     providing cycle routes in accordance with the London Cycle Network, Thames Cycle
               Route and evolving local network. Where possible these will be physically segregated
               from other road users. The use of footpaths in general, the riverside walk and the Green




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               Chain will be examined in this context, as will their provision in association with new
               development and road schemes. Other physical provision, such as improved junction
               design will also be implemented where possible and required. In particular, safe cycle
               routes to schools will also be implemented;

         •     providing cycle parking facilities, particularly in conjunction with major traffic
               attractors/generators and new developments. These should be sufficient in number, safe
               and in well-lit areas; and

         •     the provision for secure cycle parking and other cyclists needs will be a condition on
               planning permissions for major new developments, and developer contributions to cycle
               provision / networks will also be sought as appropriate in line with Policy SC2.

        Table 2: TfL Cycle Parking Standards Summary Table

                   Land Use                           Cycle Parking Standards

                   Cruise Liner Terminal (Sui         No guidance - cycle parking to
                   Generis)                           provided on its own merit.
                   Hotel (C1)                         1 space per 10 staff

                   Residential (C3)                   •   1 space per residential unit for
                                                          flats
                                                      •   1 space per residential unit for
                                                          1 or 2 bed dwellinghouses
                                                      •   2 spaces per 3 bed
                                                          dwellinghouse
                   Commercial and Retail (A1, A2,     •   1 space per 500 sqm for A1
                   A3, A4, A5 and B1)                 •   1 space per 125 sqm for A2
                                                      •   1 space per 20 staff plus 1
                                                          space per 20 seats for visitors
                                                          for A3
                                                      •   1 space per 250 sqm for B1
                   Skills Academy (D1)                1 space per 8 staff or students

                   Crèche (D1)                        No guidance.




5.112    The redevelopment proposals aim to provide 823 cycle parking spaces throughout the
         scheme.      This provision is in accordance with the provision required by relevant policy
         guidance and so will assist in achieving the objectives of PPG13 by promoting more




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         sustainable modes of transport. Further details of the provision are set out in the Transport
         Assessment (Reference EW10).


        Coach Parking

5.113    The 2008 London Plan requires all large developments to provide appropriate taxi ranks and
         coach / bus parking and stands.

5.114    Further to the London Plan guidance, UDP Policy M40 states that developments generating /
         attracting coach traffic will need to make provision for dropping off and picking up, coach
         manoeuvring and parking on site.

5.115    Due to the delivery of a cruise liner terminal and hotel, the development proposals seek to
         provide 5 coach parking spaces in the development and will provide coach drop-off and pick-
         up at two locations within the application site. The management of cruise passengers is a
         highly controlled process and the design of this system of coach drop-off and pick-up has
         been prepared following detailed discussions with London Central Cruise Moorings who
         manage all cruise operations of the River Thames on behalf of the Port of London Authority.


        Servicing

5.116    UDP Policy M29 further states that new developments will be expected to provide adequate
         service areas so that vehicles can leave the site in forwards gear.

5.117    At local policy level, UDP Policy D5 states that the design and layout of access road, cycle
         paths, footpaths, parking and service areas should be attractive, safe, convenient and
         appropriate to the type and scale of the development. It is stated that parking and servicing
         arrangements should work effectively and be designed to minimise their visual impact.

5.118    As set out in the Transport Assessment (Reference EW10), servicing of the cruise ships is
         expected to take place after the majority of passengers have left and before the majority
         arrive, usually between 10:00 am and 2:00 pm. As with coach drop-off and pick-up, this
         process is highly managed, with servicing requirements identified well in advance, and
         suppliers notified of an appropriate visiting time.

5.119    Servicing for the non-cruise ship uses will be in accordance with those of typical urban areas,
         such as refuse pick up once a week, linen pick up for the hotel on alternate days etc.




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        Energy and Sustainability

        Policy Context

5.120    Planning Policy Statement 22 (PPS22): Renewable Energy (2004) seeks to incorporate
         renewable energy in developments where the technology is viable, economical, and the social
         impacts can be addressed satisfactorily. PPS22 identifies that increased development of
         renewable energy resources is vital to facilitating the delivery of the Government’s
         commitments on both climate change and renewable energy.

5.121    Planning and Climate Change, a supplement to PPS1 encourages development proposals to
         incorporate renewable energies and promote energy efficiency. According to the supplement,
         urban growth should secure sustainable transport modes and enable communities to
         contribute effectively to climate change.

5.122    The 2008 London Plan seeks to ensure that future developments meet the highest standards
         of sustainable design and construction (Policy 4A.3). Policy 4A.4 states that the Mayor will,
         and boroughs should, support the Mayor’s Energy Strategy (2004). A key objective of the
         Energy Strategy is to reduce London’s contribution to climate change through energy
         efficiency, combined heat and power (CHP), renewable energy and hydrogen.                 An
         assessment of the energy demand will be requested by the Mayor and boroughs for proposed
         major developments, which should meet the Mayor’s energy hierarchy as stated in the Energy
         Strategy of:

         •     using less energy (be lean);

         •     using renewable energy (be green); and

         •     supplying energy efficiently (be clean).

5.123    Policy 4A.4 of the 2008 London Plan further requires major developments to show how the
         development would generate a proportion of the site’s electricity or heat needs from
         renewables, wherever feasible. The London Plan sets a target for new development of a 20%
         reduction in carbon dioxide emissions (Policy 4A.7).

5.124    The Draft Replacement London Plan seeks to achieve an overall reduction in London’s
         carbon dioxide emissions of 60% by 2025 (Policy 5.1). Policy 5.2 indicates that development
         proposals should make the fullest contribution to minimising carbon dioxide emissions. Policy
         5.3 further states that development should achieve the highest standards of sustainable
         design and construction.




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5.125    UDP Policy E9 states that the Council will expect all new developments seeking to provide in
         excess of 1,000 sqm of floorspace or more than 10 residential units, to incorporate renewable
         energy production equipment to provide at least 10% of the predicted energy requirements of
         the scheme, where there is no conflict with other policies in the Plan.


        Planning Assessment

5.126    The total carbon emissions of the proposed development will be reduced by 70% compared to
         Part L from the use of a number of measures including a Combined Heat and Power (CHP)
         scheme and photovoltaics. Further sustainability measures will be included throughout the
         detailed design and construction of the proposed development to ensure that the scheme
         meets BREEAM ‘Excellent’ and Code for Sustainable Homes Level 4. This exceeds the
         requirements of London Plan policy and so the proposals are fully in accordance with the
         objectives of national, regional and local planning policy.

5.127    Further details are set out in the Energy Strategy (Reference EW13) and Sustainability
         Statement (Reference EW14), prepared by Cundall Genesys Environmental, and Chapters 16
         and 15 of the Environmental Statement Volume I (Reference EW05) respectively.


        Affordable Housing

        Policy Context

5.128    PPS3 states that the Government is committed to providing high quality affordable housing for
         people who are unable to access or afford market housing, and sets out that local planning
         authorities should balance the need for affordable housing against the viability of sites in their
         areas. This involves having regard to the implications of competing land uses and making
         informed assumptions about the levels of finance available for affordable housing.

5.129    Affordable housing targets set out in the 2008 London Plan seek a London-wide provision of
         50% affordable housing with a tenure split of 70% social rented and 30% intermediate
         accommodation on developments providing 10 or more dwellings (Policy 3A.9). In negotiating
         the provision of affordable housing, Policy 3A.10 states that boroughs should seek the
         “maximum reasonable amount of affordable housing”, whilst having regard to the need to
         encourage rather than restrain residential development and to take into account the individual
         circumstances of the site.

5.130    Policy 3.8 of the Draft Replacement London Plan states that Londoners should have a
         genuine choice of homes that they can afford and which meet their requirements for different




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         sizes and types of dwellings in the highest quality environments. The Draft Replacement
         London Plan seeks to maximise affordable housing provision across the boroughs and seeks
         an average of at least 13,200 more affordable homes per year in London up to 2021. The
         Draft Replacement London Plan does not set a London-wide strategic target for securing
         affordable housing, but instead advises that this should be set by boroughs at the local level
         within LDF documents (Policy 3.12). The Draft Replacement London Plan sets an amended
         tenure split of 60% social rented accommodation and 40% intermediate accommodation.

5.131    Policy 3.13 of the Draft Replacement London Plan, like Policy 3.10 of the 2008 London Plan
         seeks the “maximum reasonable amount of affordable housing”, having regard to:

         •     current and future requirements for affordable housing at local and regional levels
               identified in line with Policies 3.8 and 3.11 and 3.12;

         •     affordable housing targets adopted in line with Policy 3.12;

         •     the need to encourage rather than restrain residential development (Policy 3.3);

         •     the need to promote mixed and balanced communities (Policy 3.10);

         •     the size and type of affordable housing needed in particular locations; and

         •     the specific circumstances of individual sites.

5.132    The policy further states that “negotiations on sites should take account of their individual
         circumstances including development viability, the availability of public subsidy, the
         implications of phased development including ‘overage’ provisions and other scheme
         requirements”.

5.133    The GLA published its Interim Housing Supplementary Planning Guidance (SPG) in April
         2010. This document provides interim guidance going forward until the Draft Replacement
         London Plan is formally published. The Interim Housing SPG provides guidance to local
         authorities in the implementation of London Plan policies and states that local affordable
         housing targets should be based on an assessment of all needs and a realistic assessment of
         supply. It is set out in the Interim Housing SPG that the strategic London Plan target of 50%
         of housing provision to be affordable is not a local target, and is only one of several factors to
         be taken into account when setting a local target.

5.134    The Interim Housing SPG further sets out strategic factors which should be taken into account
         in the delivery of affordable housing:

         •     the need to encourage rather than restrain housing development;




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         •     individual circumstances of the site; and

         •     applying the targets flexibility, taking account of individual site costs, the availability of
               public subsidy and other requirements.

5.135    Policy SH5 of the LB Greenwich UDP states that the Council will seek to ensure that 35% of
         the dwellings provided over the Plan period (between 1997 and 2016) are affordable to those
         on low and lower incomes. Policy H14 further states that developments seeking to provide 15
         or more units on site (or sites of more than 0.5 hectares in size) will be expected to provide a
         significant element of affordable dwellings on site.       This policy goes on to state that the
         precise percentage, distribution and type of affordable housing will be determined by the
         particular circumstances and characteristics of the site and the development, the economics
         of housing provision, other planning objectives and the scale of need for affordable housing as
         set out in Policy SH5.


        Scheme Provision and Planning Assessment

5.136    The applicant is currently undertaking detailed viability assessments of the proposed
         development to establish the quantum of affordable housing that can be viably delivered on
         the site. The affordable housing offer of the proposed development will then be subject to
         discussions with the London Borough of Greenwich throughout the application’s determination
         period.


        Residential Mix and Layout

        Policy Context

5.137    National policy guidance encourages local planning authorities to take account of local
         housing need in determining the type and size of additional housing provision, and promotes
         sufficient quantity of housing taking into account need and demand (PPS3).

5.138    Policy 3A.5 of the 2008 London Plan states that boroughs should seek to ensure that new
         developments offer a range of housing choices in terms of the mix of housing sizes and types,
         taking account of the housing requirements of different groups. The policy also requires that
         all new housing is built to ‘Lifetime Homes’ standards and that 10% of new housing is
         designed to be wheelchair accessible or easily adaptable for wheelchair users.

5.139    As set out above, the Draft Replacement London Plan states that “Londoners should have a
         genuine choice of homes that they can afford and which meets their requirements for different
         sizes and types of dwellings in the highest quality environments”. This is further reiterated in




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         the Mayor’s Interim London Housing Design Guide (August 2010), which requires
         development proposals to demonstrate how the proposed accommodation mix reflects the
         needs and aspirations of the local community, and how the tenure mix reflects the needs of
         the local community and local borough targets. This document has been published to shape
         the design of London Development Agency (LDA) supported developments, but also seeks to
         encourage the wider use of the design guidelines.

5.140    The Interim London Housing Design Guide further sets out minimum space standards for new
         residential developments. Table 3 provides a summary of the relevant standards using Gross
         Internal Areas (GIA).

        Table 3: Interim London Housing Design Guide Internal Space Standards

                                   Dwelling Type               Minimum Floorspace
               Single Storey       1 bedroom / 2 person                 50 sqm
               Dwellings           2 bedroom / 3 person                 61 sqm
                                   2 bedroom / 4 person                 70 sqm
                                   3 bedroom / 4 person                 74 sqm
                                   3 bedroom / 5 person                 86 sqm
                                   3 bedroom / 6 person                 95 sqm
                                   4 bedroom / 5 person                 90 sqm
                                   4 bedroom / 6 person                 99 sqm
               Two Storey          2 bedroom / 4 person                 83 sqm
               Dwellings           3 bedroom / 4 person                 87 sqm
                                   3 bedroom / 5 person                 96 sqm
                                   4 bedroom / 5 person                 100 sqm
                                   4 bedroom / 6 person                 107 sqm
               Three Storey        3 bedroom / 5 person                 102 sqm
               Dwellings           4 bedroom / 5 person                 106 sqm
                                   4 bedroom / 6 person                 113 sqm



5.141    UDP Policy H15 states that a mix of housing types and sizes will be expected in all
         developments, and particularly in those providing more than 25 dwellings. The mix sought on
         each site will vary according to the location of the development and the character of the
         surrounding area. The policy states that both large and small units should be included, and
         dwellings for families should be provided with direct access to a garden.




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5.142    UDP Policy H17 requires all new housing to be built to Lifetime Homes standards and H19
         states that residential developments providing more than 25 units should provide 10% built to
         full wheelchair accessible standards. The policy states that in the case of private housing, the
         requirement may be provided as units capable for adaptation to full wheelchair standard, if
         this can be carried out without further structural alterations.


        Planning Assessment

5.143    The proposed residential accommodation will be of the highest design quality. The scheme
         has been designed in accordance with the emerging unit size standards set by the GLA in the
         Interim London Housing Design Guide as far as possible. The proposed development has
         been designed to minimise the number of single aspect north-facing units, and all larger family
         sized units have direct access to private gardens. The development is in accordance with the
         requirements of the Lifetime Homes Standards and the Wheelchair Housing Standards,
         further details of which are set out in the Design and Access Statement (Reference EW04),
         prepared by Ian Simpson Architects and David Bonnett Associates.

5.144    As set out above, the affordable housing provision of the proposed development remains the
         subject of viability assessments and will be the subject of discussions with the London
         Borough of Greenwich throughout the application’s determination period.

5.145    For the purposes of the application submission, an indicative mix is presented on the planning
         application drawings (Reference EW02).         However, this is likely to be subject to review
         following the conclusion of discussions with the Council.


        Residential Density

        Policy Context

5.146    PPS3 states that urban land can often be significantly underused and that local planning
         authorities should analyse the capacity of the land in their borough in order to ensure the
         maximisation of the reuse of previously developed land.

5.147    Density ranges for new residential developments are set out in the 2008 and Draft
         Replacement London Plans, and relate to the accessibility of sites. As set out above, the site
         at Enderby Wharf currently has a PTAL of 3, indicating moderate accessibility to public
         transport. However, it is anticipated that following a number of transport initiatives, the site
         could have a PTAL of 4/5. In accordance with this, and its definition as an urban area, the
         guidance set out in both the 2008 and Draft Replacement London Plan seeks to provide




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         residential densities of between 650 and 1,100 habitable rooms per hectare on the site. The
         Draft Replacement London Plan seeks to optimise housing potential through the achievement
         of such densities, and states that development proposals which compromise this policy should
         be resisted (Policy 3.4).

5.148    The Mayor’s Interim Housing Design Guide states that development proposals must
         demonstrate how densities of residential accommodation reflect a sound understanding of
         PTAL, accessibility to local amenities and services, and appropriateness to physical context.

5.149    The Mayor’s Housing SPG (2005) supports the London Plan in seeking to make the best use
         of available sites for the development of housing. The SPG further makes recognition of
         many of London’s most successful residential neighbourhoods being comprised of higher
         density housing stock.

5.150    The GLA’s Interim Housing SPG sets out further guidance relating to density, which reinforces
         that set out in the Draft Replacement London Plan. The guidance set out in the Interim
         Housing SPG states that the form of developments should reflect the objectives of the
         development plan, including identified housing requirements.

5.151    At the local level, UDP Policy H8 states that in considering residential development proposals,
         the Council will give priority to securing a high quality environment for residents and making
         the best suitable use of land, having regard to the location of the site and its individual
         characteristics. Appropriate densities are set out in UDP Policy H9, as follows:

         •     150 – 250 habitable rooms per hectare for family dwellings;

         •     170 – 300 habitable rooms per hectare for non-family dwellings;

         •     200 – 400 habitable rooms per hectare for non-family dwellings in Major District Centres
               or sites with immediate access to a network of good public transport facilities;

         •     over 450 habitable rooms per hectare for non-family dwellings will be accepted in
               exceptional circumstances, on sites of high public transport accessibility, where it can be
               demonstrated that the design is of exceptional quality.

        Planning Assessment

5.152    As set out above, the Enderby Wharf development proposals seek to provide 770 residential
         units on a site measuring approximately 3.6 hectares. The scheme proposes a residential
         density of circa 623 habitable rooms per hectare (based on 2,243 habitable rooms in the
         proposed scheme), which, in conjunction with the other proposed uses, optimises the use of




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         the site in accordance with national, regional and local policy guidance, whilst creating a high
         quality, sustainable mixed-use development. The proposed development seeks to provide a
         high density scheme in an accessible location that responds to its setting.

5.153    The scheme has been rigorously tested to ensure that it does not result in any significantly
         adverse impacts with regards to townscape, environmental or infrastructure capacities. The
         full results of this testing are set out within the Environmental Statement (References EW05,
         EW06 and EW07), prepared by Planning and Regeneration Ltd. Following the Environmental
         Impact Assessment that has been undertaken, it is considered that the proposed residential
         density of the scheme is wholly suitable in this urban location.


        Residential Amenity Space

        Policy Context

        Communal Amenity Space

5.154    Through Policy 3D.8 of the 2008 London Plan, the Mayor will work with strategic partners to
         protect, promote and improve access to London’s network of open spaces, to realise the
         current and potential value of open space to communities, and to protect the many benefits of
         open space. Policy 3D.8 further states that developments will be expected to incorporate
         elements of open space that make a positive contribution to, and are integrated with, the
         wider network.

5.155    Policy 7.5 of the Draft Replacement London Plan states that new developments should make
         the public realm comprehensible and that landscape treatments (including furniture etc)
         should be of the highest quality.

5.156    The Mayor’s Interim London Housing Design Guide sets a requirement for development
         proposals to demonstrate how they comply with the borough’s open space strategies,
         ensuring that a review of surrounding open space is undertaken and that opportunities to
         address a deficiency in provision are taken forward in the design process.

5.157    Policy H11 of the LB Greenwich UDP states that new residential developments will be
         expected to provide sufficient amenity space to meet the needs of residents. The policy
         further states that family housing should normally have direct access to a private garden, and
         that flats should be provided with a terrace, balcony or enclosed communal gardens that are
         not accessible to the general public.




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        Private Amenity Space

5.158    The Interim London Housing Design Guide recommends that a minimum of 5 sqm of private
         outdoor space should be provided for 1-2 person dwellings and an extra 1 sqm should be
         provided for each additional occupant.

5.159    As set out above, Policy H11 of the UDP requires family sized accommodation to provide
         direct access to private gardens, and flats should be provided with a terrace, balcony or
         enclosed communal gardens that are not accessible to the general public.


        Child Play Space

5.160    The 2008 London Plan seeks to ensure that all children have safe access to good quality,
         well-designed, secure and stimulating play and informal recreation provision and Policy 3D.13
         states that developments that include housing should make provision for play and informal
         recreation, based on the expected child population generated by the scheme and an
         assessment of future needs.

5.161    Policy 3.5 of the Draft Replacement London Plan seeks to enhance the quality of local places
         by ensuring that new housing developments take into account the provision of public,
         communal and open spaces. The Draft Replacement London Plan reaffirms Policy 3D.13 of
         the existing London Plan regarding the provision of children’s play space, and encourages the
         incorporation of trees and greenery into proposals.

5.162    The Mayor’s Providing for Children and Young People’s Play and Informal Recreation SPG
         (March 2008), which is referred to in both the current and Draft Replacement London Plans,
         states that children’s play space should be provided in new developments with a standard
         target of 10 sqm per child.       The SPG further recommends the following accessibility
         requirements for children’s play space:

         •     100 metres maximum walking distance from a residential unit for under 5s;

         •     400 metres maximum walking distance from a residential unit for 5-11 year olds; and

         •     800 metres maximum walking distance from a residential unit for 12+ year olds.

5.163    UDP Policy H12 states that residential development seeking to deliver more than 50 units of
         family housing should provide suitably equipped and well designed children’s play areas.




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        Scheme Provision and Planning Assessment

5.164    The amenity space provision of the proposed development is summarised in the diagram
         presented at Figure 3.

         Figure 3: Proposed Amenity Space Provision




5.165    In addition to the landscaping and public realm proposals detailed earlier in Section 5 this
         Planning Statement, the scheme also proposes to provide 6,700 sqm of communal amenity
         space for use by its residents. The landscape design at Enderby Wharf will provide a variety
         of spaces for use by both residents and visitors.

5.166    All ground floor residential units will have access to private amenity space with an average of
         20 sqm per unit.

5.167    It is expected that the proposed development will generate the following child yield, as set out
         in Table 4.




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        Table 4: Expected Child Yield

                 Age                       Expected Child Yield       Playspace Provision
                                                                      Requirement
                 0-4 years                           133                       1,330
                 5-11                                120                       1,200
                 12-17                               127                       1,270
                 Total                               380                       3,800



5.168    In accordance with the standards prescribed by the GLA, the scheme therefore has a
         requirement to provide 1,330 sqm of playspace for children up to the age of 5, 1,200 sqm for
         children aged between 5 and 11, and 1,270 sqm of space for children aged between 12 and
         17. The scheme proposes to provide this as follows:

         •     children aged between 0 and 5:        approximately 1,558 sqm of small age-appropriate
               equipped play areas with opportunities for informal play are to be located within 15
               metres of residential or retail units, or adjacent to a main route throughout the site;

         •     children aged between 5 and 11: approximately 1,813 sqm of equipped age-appropriate
               play areas with opportunities for informal play, ‘kickabout’ areas or adventure playground
               equipment are to be located within 30 metres of residential or retail units, or adjacent to a
               main route; and

         •     children aged between 12 and 17: approximately 1,282 sqm of playable space required
               for children aged from 12 to 17 is to be split into a number of smaller scale spaces across
               the development. These spaces will be informal meeting and gathering areas for children
               to use and enjoy throughout the year.

5.169    As much of the public realm and residential courtyard spaces as possible will be delivered as
         ‘playable space’, where children’s play is a legitimate use of the space without compromising
         other users of the space. As set out in more detail in the Landscape and Public Realm
         Strategy (Reference EW12), the aim is to create spaces that are genuinely child-friendly and
         inclusive to all, in line with the aspirations set out in the 2008 London Plan: to “ensure that all
         children have safe access to good quality, well-designed, secure and stimulating play and
         informal recreation provision” (Policy 3D.13).       The play facilities provided in the Enderby
         Wharf development will not be segregated and fenced-off, but instead playful offers will be
         threaded throughout the scheme.




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5.170    The scheme will exceed the Mayor of London’s target of 10 sqm per child, and will provide an
         exemplar scheme in this regard.


        Development and Flood Risk

        Policy Context

5.171    Planning Policy Statement 25 (PPS25): Development and Flood Risk (2010) aims to ensure
         that flood risk is taken into account at all stages in the planning process to avoid inappropriate
         development in areas at risk of flooding and to direct development away from areas at highest
         risk.     Where new development is necessary in such areas, PPS25 aims to make it safe
         without increasing flood risk elsewhere and where possible, reducing flood risk overall.

5.172    Policy 4A.13 of the 2008 London Plan states that where development in areas at risk from
         flooding is permitted (taking into account the provisions of PPS25), the Mayor will, and
         boroughs and other agencies should, manage the existing and future increased risk and
         consequences of flooding as a result of climate change by:

         •       protecting the integrity of existing flood defences;

         •       setting permanent built development back from existing flood defences to allow for the
                 management, maintenance and upgrading of those defences to be undertaken in a
                 sustainable and cost effective way;

         •       incorporating flood resilient design; and

         •       establishing flood warning and emergency procedures.

5.173    Policy 5.12 of the Draft Replacement London Plan accords with national policy and the
         existing London Plan by stating that development proposals must comply with the flood risk
         assessment and management requirements set out in PPS25 over the lifetime of the
         development. Policy 5.13 also indicates that development should utilise sustainable urban
         drainage systems (SUDS) unless there are practical reasons for not doing so.

5.174    Policy E17 of the LB Greenwich UDP requires all development to be controlled so as not to
         give rise to flooding or surface, groundwater or aquifer pollution. Policy E18 further requires
         all planning applications for development in areas within Flood Zones 2 and 3, and more than
         1 hectare in size, to be accompanied by a Flood Risk Assessment appropriate to the scale
         and nature of the development, the level of flood risk, and the protection afforded by the
         existing defences.




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5.175    In consultation with the Environment Agency, Policy E19 of the UDP states that the Council
         will ensure that new developments safeguard existing tidal and fluvial flood defences. Where
         works are carried out in proximity to a tidal or fluvial flood defence, the Council will seek to
         safeguard and where possible extend public access to the waterfront and protect and
         enhance existing ecological features. The policy states that generally consideration will be
         given to maintaining and / or improving the existing ecological features, the existing flood
         defences, and access to flood defence facilities for operational and maintenance purposes.


        Planning Assessment

5.176    In accordance with national, regional and local planning policy guidance, a full Flood Risk
         Assessment has been undertaken by Water Environment Ltd part of this application
         submission. Further details are set out in Chapter 11: Water Resources and Flood Risk of
         Environmental Statement Volume I (Reference EW05), and within the full Flood Risk
         Assessment, provided as a technical appendix in Environmental Statement Volume III
         (Reference EW07). The Flood Risk Assessment concludes that the proposed development
         will have no impact on the frequency, extent, rate and duration of flooding from the River
         Thames.


        Archaeology

        Policy Context

5.177    Planning Policy Statement 5 (PPS5): Planning for the Historic Environment (2010) sets out
         guidance on how archaeological remains should be preserved or recorded, and includes
         direction on the weight to be given to them in planning decisions. PPS5 seeks to protect
         heritage assets, which include those parts of the historic environment that have significance
         because of their historic, archaeological, architectural or artistic interest.

5.178    Policy 4B.15 of the 2008 London Plan supports the identification, protection, interpretation and
         presentation of London’s archaeological resources.

5.179    Policy 7.8 of the Draft Replacement London Plan states that London’s historic environment
         should be identified, preserved and restored. The policy further states that new development
         should make provision for the protection of archaeological resources.

5.180    In accordance with Policy D30 of the LB Greenwich UDP, the Council expects applicants to
         properly assess and plan for the impact of proposed developments on archaeological remains
         where sites are located within Areas of Archaeological Potential. Policy D31 further states




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         that the Council will seek to preserve remains in situ, but where this is not feasible, the
         remains should either be investigated, excavated and removed from the site, or investigated,
         excavated and recorded before destruction.


        Planning Assessment

5.181    As set out above, the site is located within an Area of Archaeological Priority. As required by
         national, regional and local planning policy, an archaeological assessment has therefore been
         undertaken by Wessex Archaeology Ltd. The results of this are presented within Chapter 7:
         Archaeology of the Environmental Statement Volume I (Reference EW05). In summary, it is
         proposed that all relevant archaeological features directly affected by the proposed
         development will be subject to archaeological mitigation. The proposed mitigation strategy set
         out in the Archaeology Chapter will ensure, where practicable and appropriate, full
         Preservation by Record of all sites, features and deposits identified.


        Microclimate

        Daylight, Sunlight, Overshadowing and Solar Glare

        Policy Context

5.182    Guidelines relating to daylight and sunlight are contained within the Building Research
         Establishment (BRE) Handbook – Site Layout Planning for Daylight and Sunlight (1991). This
         guidance includes discussion on how to protect the daylighting and sunlighting of existing
         buildings when new developments are proposed. Details are also included on rights to light
         and indicators to calculate access to skylight, sunlight and solar radiation.

5.183    Policy 4B.10 of the 2008 London Plan refers to the design and impact of large scale buildings
         and includes the requirements that in residential environments, particular attention should be
         paid to privacy, amenity and overshadowing.

5.184    Policy 7.6 of the Draft Replacement London Plan requires new buildings and structures to
         ensure that they do not cause unacceptable harm to the amenity of surrounding land and
         buildings in relation to a number of factors, including overshadowing.          The policy makes
         reference to this being particularly important for tall and residential buildings.     Policy 7.7
         further states that tall buildings should not adversely affect their surroundings in terms of
         overshadowing and reflected glare.




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        Planning Assessment

5.185    A full assessment of the daylight, sunlight, overshadowing and solar glare impacts of the
         proposed development has been undertaken by BLDA and is set out in Chapter 10: Daylight,
         Sunlight, Overshadowing and Solar Glare of Environmental Statement Volume I (Reference
         EW05). This concludes that following appropriate mitigation measures, the daylight, sunlight,
         overshadowing and solar glare impacts of the proposed development are considered
         acceptable in accordance with the relevant BRE guidance.


        Noise

        Policy Context

5.186    Planning Policy Guidance Note 24 (PPG24): Planning and Noise (1994) seeks to minimise the
         adverse impact of noise without placing unreasonable restrictions on development.         It is
         recognised that noise can have a significant effect on the environment and on the quality of
         life enjoyed by individuals and communities. PPG24 identifies that the impact of noise can be
         a material consideration in the determination of planning applications.

5.187    Through Policy 4A.20, the 2008 London Plan seeks to reduce noise by minimising the existing
         and potential adverse impacts of noise, from, within, or in the vicinity of development
         proposals. It also states that new noise sensitive developments should be separated from
         major noise sources wherever practicable.

5.188    Policy E3 of the LB Greenwich UDP states that housing or other sensitive uses will not
         normally be permitted on sites adjacent to existing problem uses, unless ameliorating
         measures can reasonably be taken and which can be sought through the imposition of
         conditions. Policy E4 further sets out measures to reduce nuisance caused by existing uses
         from the emission of noise, fumes, light, dust, grit, smells or vibration by:

         •     negotiating reduction of activity or installation of ameliorating measures;

         •     encouraging relocation where appropriate;

         •     refusing planning permission for consolidation or expansion of problem uses, or imposing
               conditions on planning permissions; and

         •     taking enforcement action where appropriate.




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        Planning Assessment

5.189    A full noise and vibration assessment has been undertaken by Sandy Brown Associates as
         part of this application, and this is presented in Chapter 19: Noise and Vibration of
         Environmental Statement Volume I (Reference EW05). Based on the 3D acoustic modelling
         that has been undertaken, it is concluded that, based on the highest recorded noise levels for
         a cruise liner, the façades of the proposed buildings at Enderby Wharf will be required to
         provide a minimum sound insulation performance of Rw + Ctr 28-33 dB.              This can be
         successfully provided by installing double glazing. It is also concluded that when cruise ships
         are docked at Enderby Wharf, the resultant daytime noise will be comparable to the existing
         levels currently generated by river traffic.


        Air Quality

        Policy Context

5.190    Planning Policy Statement 23 (PPS23): Planning and Pollution Control (2004) sets out
         potential impacts on air quality arising from development, possibly leading to impacts on
         health is capable of being a material planning consideration. Paragraph 10 states that whilst
         planning and pollution controls are separate, they are complementary. Considering planning
         and pollution together ensures that air quality meets the standards that guard against impacts
         to the environment and human health. The planning system controls the development and
         use of land in the public interest and plays an important role in determining the location of
         development which may give rise to pollution.

5.191    The 2008 London Plan and the Mayor’s Air Quality Strategy (2002) seek to minimise the
         emissions of key pollutants and to reduce concentrations to levels at which no, or minimal
         effects on human health are likely to occur. Policy 4A.19 of the 2008 London Plan seeks to
         achieve this by:

         •     improving the integration of land use and transport policy and reducing the need to travel
               especially by car;

         •     promoting sustainable design and construction;

         •     identifying environmental constraints on polluting activities;

         •     seeking to reduce the environmental impacts of transport activities; and




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         •     working in partnership with relevant organisations, taking appropriate steps to achieve an
               integrated approach to air quality management and to achieve emissions reductions
               through improved energy efficiency and energy use.

5.192    At the local level, Policy E1 of the LB Greenwich UDP states that planning permission would
         not normally be granted where a proposed development would have a significant adverse
         effect on the amenities of adjacent occupiers or uses, especially where proposals would be
         likely to result in the unacceptable emission of odours, fumes, dust, water and soil pollutants
         or grit.

5.193    UDP Policy E6 states that development proposals with the potential to result in a significant
         deterioration in air quality will be resisted unless measures to minimise this impact are
         included.


        Planning Assessment

5.194    A full assessment of the air quality impacts of the proposed development has been
         undertaken by JMP and is set out in Chapter 18: Air Quality of Environmental Statement
         Volume I (Reference EW05). This concludes that the proposed development will, at worst,
         provide a slight adverse impact at one receptor point in the site, whereas will provide
         negligible impacts at the other tested locations.


        Wind

        Policy Context

5.195    There are no national codes of practice or legislative policies relating to the assessment of
         environmental wind flows in the built environment. The impact of environmental wind on
         pedestrian spaces and the subsequent suitability of these spaces for planned usage are
         described by and compared against the industry standard Lawson criteria, which are
         recognised by local authorities as a suitable benchmark for wind assessments.

5.196    Policy 4B.10 of the 2008 London Plan sets out that the design and impact of tall buildings
         should be sensitive to their impact on micro-climates in terms of wind, sun, reflection and
         overshadowing.

5.197    The GLA Sustainable Design and Construction SPG (2006) provides a description of wind
         microclimatic issues, particularly in relation to public realm and accessible landscaped areas.
         Reference is made to the use and application of wind tunnel testing. Measures for avoiding
         potential adverse pedestrian wind effects are also suggested




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        Planning Assessment

5.198    The impacts of the proposed development on the wind microclimate have been assessed by
         RWDI Anemos and are presented in Chapter 9: Wind of the Environmental Statement Volume
         I (Reference EW05). This concludes that the Enderby Wharf site is open to prevailing winds
         and is therefore uncharacteristic of many other development sites in London. Wind tunnel
         modelling with no landscaping identified in localised areas where additional shelter would be
         beneficial but the majority of the site had a wind environment that was suitable for the
         intended pedestrian use on the site. Further tests were conducted to illustrate the benefits of
         localised mitigation concepts, and the overall impact of the scheme on wind microclimate was
         consequently measured to be negligible.


        Ecology (Marine and Terrestrial)

        Policy Context

5.199    Planning Policy Statement 9 (PPS9): Biodiversity and Geological Conservation (2005) sets
         out national planning policies on conserving and enhancing biodiversity. It includes the broad
         aim that planning, construction, development and regeneration should have minimal impacts
         on biodiversity and enhance it wherever possible.

5.200    Policy 3D.14 of the 2008 London Plan refers to biodiversity and nature conservation and
         states that the planning of a new development should have regard to nature conservation and
         biodiversity, and opportunities should be taken to achieve positive gains for conservation
         through the form and design of development.

5.201    Policy 7.19 of the Draft Replacement London Plan states that the Mayor will work with all
         relevant partners to ensure a proactive approach to the protection, promotion and
         management of biodiversity in support of the Mayor’s Biodiversity Strategy.          Policy 7.19
         further states that development should, wherever possible, make a positive contribution to the
         protection, promotion and management of biodiversity.

5.202    Policy D3 of the LB Greenwich UDP requires development proposals to take account of
         ecological factors, including protected species and natural river features. Policy O21 further
         states that the ecological and wildlife value of the borough’s rivers, canals and lakes are to be
         protected and enhanced.

5.203    UDP Policy O23 states that in Areas of Wildlife Deficiency (such as Enderby Wharf), the
         Council will take opportunities to secure the provision of areas to be managed as wildlife




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         habitats, and will seek to maximise opportunities for access to suitable sites within areas of
         wildlife deficiency.

5.204    With regards to trees, UDP Policy D8 states that the Council will encourage planting in
         appropriate places, and that the planting of trees as part of new developments is encouraged.


        Planning Assessment

5.205    Full assessments of the marine and terrestrial ecology on the site, and the impacts of the
         proposed development on such flora and fauna have been carried out by Thomson Ecology
         Ltd and Biodiversity by Design Ltd and these assessments are presented in Chapters 14:
         Marine Ecology and 13: Ecology and Biodiversity of the Environmental Statement Volume I
         (Reference EW05) respectively.

5.206    By way of a summary, it is considered that following the implementation of ecological and
         mitigation measures as detailed in the Environmental Statement, there would be no significant
         adverse ecological effects of the proposed development on the ecology of the site.


        Planning Obligations

5.207    Paragraph B5 of Circular 05/2005: Planning Obligations states that in order to be sought, a
         planning obligation must be:

         i.    relevant to planning;

         ii.   necessary to make the proposed development acceptable in planning terms;

         iii. directly related to the proposed development;

         iv. fairly and reasonably related in scale and kind to the proposed development; and

         v.    reasonable in all other aspects.

5.208    The policy tests set out in Circular 05/2005 have recently been put on a statutory footing by
         the Community Infrastructure Levy Regulations (SI 2010/948). In particular, Regulation 122
         (2) of the Regulations states that:

        “A planning obligation may only constitute a reason for granting planning permission for the
        development if the obligation is –

        a) necessary to make the development acceptable in planning terms;

        b) directly related to the development; and




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        c) fairly and reasonably related in scale and kind to the development,”

5.209    The above statutory tests are based on three of the policy tests contained in paragraph B5 of
         Circular 05/2005 (tests (i), (iii) and (iv)). The two main remaining tests (i.e. tests (ii) and (v))
         were omitted from Regulation 122, as they were considered unnecessary and repetitive of
         matters covered by the other policy tests.

5.210    In March 2010 the Department for Communities and Local Government (DCLG) launched a
         New Policy Document for Planning Obligations consultation, the closing date for which was 21
         June 2010. The consultation document sought the views of consultees on the Government’s
         proposals for a new policy document on planning obligations. The policy annex appended to
         the consultation document indicates the Government’s intention to bring the policy tests
         contained in Circular 05/2005 into line with the legal tests set out in Regulation 122. In
         particular, paragraph PO2.1 of the policy annex requires that, in order for a planning obligation
         to be sought to constitute a reason for granting planning permission, it must be:

         a. necessary to make the development acceptable in planning terms;

         b. directly related to the development; and

         c.    fairly and reasonably related in scale and in kind to the development.

5.211    Once finalised, the New Policy Document for Planning Obligations will replace Circular
         05/2005.


        Draft Heads of Terms

5.212    The applicant has engaged in preliminary discussions with the Council regarding the planning
         obligations which may be required in the event that the Council is minded to grant planning
         permission for the redevelopment of Enderby Wharf. Discussions to date have been focused
         around the Council's Supplementary Planning Document: "Planning Obligations" (February
         2008) and the broad categories of planning obligation referred to, therein including:

         •     Affordable Housing;

         •     Transport;

         •     Education and Employment Training;

         •     Health and Social Services;

         •     Local Community Facilities;

         •     Open Space, Children's Play Areas, Public Realm and Public Art;




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         •     Public Safety and Emergency Services;

         •     Cultural Strategy and Sports Leisure Facilities;

         •     Environmental Health and Waste Management; and

         •     Monitoring, Review, Legal and Professional Fees.

5.213    Following submission of the full planning application for the redevelopment of Enderby Wharf,
         the applicant shall continue to engage with the Council in this regard and, at the appropriate
         time, shall enter into negotiations with the Council concerning the set of planning obligations
         which will be required, in this case having regard to the particular characteristics of the
         development proposals, the statutory tests for planning obligations contained in Regulation
         122 of the Community Infrastructure Levy Regulations 2010, any relevant Circular guidance
         on the need for planning obligations, and the overall viability of the Enderby Wharf scheme.




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6.       CONCLUSIONS
6.1      This Planning Statement has been prepared by GVA Grimley on behalf of Mason
         Developments Ltd (the applicant) in support of an application for Full Planning Permission and
         Listed Building Consent for the redevelopment of Enderby Wharf, Greenwich, SE10 (the site).
         This statement demonstrates the planning case in support of the applicant’s proposals in the
         context of national, regional and local planning policy and other best practice guidance.

6.2      The applications submitted with this Planning Statement seek approval for the following
         development proposals:

         •     the delivery of a new international cruise liner terminal on the River Thames;

         •     the provision of quality hotel accommodation adjacent to the international cruise liner
               terminal;

         •     the development of private and affordable residential homes set within an extensive array
               of public, semi-public and private landscaped spaces;

         •     the provision of an enterprise and training skills academy;

         •     the delivery of a crèche and gymnasium;

         •     the provision of start-up business accommodation located adjacent to the new hotel and
               cruise terminal;

         •     the refurbishment of the Grade II listed Enderby House as a restaurant / café with
               accompanying exhibition space and tourist and interpretation centre;

         •     the provision of a new public square fronting onto the River Thames which provides a
               new riverside destination alongside the Thames Path incorporating the reinstated
               Enderby House; and

         •     the creation of a new double berth river mooring to be served by the Thames Clipper fast
               passenger service for visitors and residents.

6.3      The proposals for the redevelopment of Enderby Wharf are fully in accordance with the overall
         objectives of national, regional and local policy guidance. The proposed development seeks
         to optimise the potential of this under-utilised brownfield site by delivering a high quality
         scheme on previously developed land and provides a unique opportunity to provide a cruise
         liner terminal for the London Borough of Greenwich and London as a whole. The delivery of
         this key piece of infrastructure generates the additional opportunity to deliver wider
         regeneration benefits for the site and surrounding area.




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6.4      The proposals have benefited from extensive and ongoing pre-application consultation with
         officers at the London Borough of Greenwich, the Greater London Authority and Transport for
         London, as well as with a number of other key stakeholders and the local community, as set
         out earlier in this Planning Statement, and have generated a significant level of pre-application
         support.

6.5      The proposed development would provide a number of benefits for the site and surrounding
         area (as set out in Section 3 of this Planning Statement) including the following:

         •     provision of an international land-based cruise liner terminal in London;

         •     the redevelopment of the Enderby Wharf site provides the opportunity to enhance and
               diversify the land use mix provided in this location;

         •     redevelopment of a currently under-used brownfield site;

         •     the proposed development will offer extensive site remediation benefits and will bring this
               vacant wharf site back into beneficial use;

         •     enhanced public transport accessibility to the site provided by the provision of a Thames
               Clipper stop;

         •     the development will create a unique landmark cluster of high quality buildings of
               exemplary design;

         •     the scheme will provide a range of residential units to suit the needs of different groups in
               the borough, including a proportion of affordable housing;

         •     the scheme will provide residential accommodation of a high quality standard which will
               comply with the Mayor’s residential unit standards and will provide large and high quality
               amenity spaces and child play spaces;

         •     reinstatement of the Thames Path within the boundary of the site will further enhance the
               accessibility of the site and will provide a pedestrian link for existing and future residents
               of the area, connecting the site to Lovell’s Wharf to the south and the existing path to the
               north;

         •     the provision of a skills academy will deliver high quality, modern education and training
               facilities which will contribute to the identified need for education and training facilities in
               the borough;

         •     the proposed development will generate 178 jobs throughout the construction phase, and
               a further 365 full time jobs once it is operational, in addition to the 250 jobs which are to
               be retained on the consolidated Alcatel site; and




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         •     the proposed development will utilise sustainable and energy efficient building techniques
               and will achieve Code for Sustainable Homes Level 4, and BREEAM Level Excellent,
               along with carbon dioxide emissions reduction of 70%.

6.6      The Enderby Wharf proposals represent a truly integrated mixed use opportunity to
         regenerate a vacant wharf on the River Thames whilst celebrating its maritime history.




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