planning report PDU/0263/01
14 April 2004
Three Quays, Lower Thames Street, EC3
in the City of London
planning application no.03-1181AE
Town & Country Planning Act 1990 (as amended); Greater London
Authority Act 1999; Town & Country Planning (Mayor of London) Order
2000 – strategic planning application stage 1 referral
Demolition of existing building and redevelopment to provide apart-hotel
(77 units) residential (64 units) and retail (Class A1 and/or A3)
accommodation (890 sq. m.) together with ancillary plant, servicing and
1 On 23 June 2003 the Corporation of London consulted the Mayor of London on a
proposal to develop the above site for the above uses. Under the provisions of the Town &
Country Planning (Mayor of London) Order 2000 the Mayor has the same opportunity as other
statutory consultees to comment on the proposal. This report sets out information for the
Mayor’s use in deciding what comments to make.
2 The application is referable under Category 1C of the Schedule of the Order 2000:
“Development which comprises or includes the erection of a building in respect of which one or
more of the following conditions is met –
(a) The building is more than 25 metres high and is adjacent to the River Thames.”
3 If the Corporation of London subsequently decides that it is minded to grant planning
permission, it must first allow the Mayor an opportunity to decide whether to direct the Council
to refuse permission.
4 The Mayor of London’s comments on this case will be made available on the GLA
5 This visually prominent site is located on the north bank of the Thames, immediately
west of the Tower of London. A six storey commercial building known as ‘Three Quays House’ is
built on the approximately 0.4 hectare site. Land uses surrounding the site are predominantly
commercial to the west and north, with the Tower of London to the east. Immediately adjacent
to the Tower of London is the public space of Tower Hill, currently undergoing redevelopment
to improve visitor enjoyment and enhance the character of this important historic site.
Immediately behind the application site on the opposite side of Lower Thames Street lies the
recently completed Tower Place, an office development with A1 and A3 uses at ground level.
The riverside walkway runs along the eastern and southern boundaries.
Details of the proposal
6 Demolition of existing office building (11,883 sq.m.) and redevelopment to provide an
11 storey (including basement) building accommodating an apart-hotel (77 units), residential
(64 units) and retail (Class A1 and/or A3) accommodation (890 sq.m.) together with ancillary
plant, servicing and parking areas. The applicant is the Cheval Group of Serviced Apartments
7 In July 1998 the Corporation of London granted planning permission to develop Three
Quays to provide an eleven storey (including basement) hotel building and Class A1 and A3
facilities. The hotel floor space comprised 17,595 sq.m. and the shop and restaurant 1,005
sq.m. The hotel scheme included 240 bedrooms together with ancillary dining facilities, health
club and meeting rooms. An application, yet to be determined, has been made to the
Corporation of London for an extension of time for the 1998 planning permission.
Strategic planning issues and relevant policies and guidance
8 The relevant issues and corresponding policies are as follows:
• Mix of uses London Plan; London’s Economic Development
Strategy (LDA), PPG1
• Affordable housing London Plan; PPG3
• Impact on the Tower of London London Plan; PPG15
• Urban design London Plan: PPG1
• Access London Plan
• Sustainable development London Plan: PPG3; PPG13
• Views London Plan, Strategic Views in London (LPAC)
• Biodiversity London Plan, the Mayor’s Biodiversity Strategy
• Transport/parking London Plan; the Mayor’s Transport Strategy;
Mix of uses
9 The proposal provides a total of 64 residential units and a further 77 apart-hotel units,
equating to a density of approximately 361 units per hectare. This density falls midway in the
range contained in table 4B.1 of the London Plan and is considered appropriate given the
context of the site and its sensitive historic riverside setting. The development relates well to
the scale, form and massing of surrounding development.
10 The site is located within an area dominated largely by office development. The
proposed development of residential units on site would be consistent with both the London
Plan and national planning policy which seeks to provide additional housing stock to sustain
economic development. The predominance of single-use commercial buildings can detract from
the liveability and vitality of central London. Mixed-use development creates greater use of
areas throughout the day and night and promotes more sustainable forms of development by
reducing the need to travel. It is considered that the mix of residential, commercial (apart-hotel
units) and retail within the proposed development is suitably sustainable and represent a more
appropriate and sustainable mix of land uses than the extant consent for purely hotel
accommodation (and ancillary retail uses) which exists for this site. Generally, the principle of
the development accords with the sustainability criteria set out at policy 2A.1 in the London
Plan in that it is of mixed use, well served by public transport and of relatively high density. In
strategic planning terms, the scheme is welcomed as a positive contribution to the Central
Activities Zone (CAZ).
11 The proposed development would not provide any on-site affordable housing. Due to
high land values it is difficult to achieve affordable housing on-site within the City. As outlined
within the City of London UDP, the Corporation has for centuries provided public housing on
sites throughout contiguous boroughs and has more recently enabled a number of affordable
housing schemes to be built outside the City using Corporation funds. In return for its financial
support the Corporation receives a number of nomination rights enabling more affordable
housing to be provided due to lower land costs outside the City’s boundaries, ensuring that
people on the City’s housing list are accommodated.
12 An off-site financial contribution of £2,912,800 is proposed to enable the Corporation of
London to utilise the funds within alternative housing schemes on the fringes of the City. The
sum has been calculated on the basis of 33% affordable provision. The London Plan affordable
housing target for all development is 50%. Policy 3A.8 of the London Plan states that such
targets should be applied flexibly and should take account of site specific development costs.
The London Plan also states that in certain exceptional cases a borough and a developer may
consider that the required affordable housing provision should be provided off-site or that a
financial contribution is acceptable.
13 In order for off site provision to be acceptable in this instance, it will be necessary for
details of the off site proposal to be submitted, in terms of the site and the host borough
agreement. Any off site agreement should be on the basis of being equivalent to 50% on site
affordable provision, assuming a mix of 70% social rent/30% intermediate within this in terms of
calculating equivalence to social housing grant contribution. Any variation from this would need
to be justified by a financial appraisal.
Impact on the World Heritage Site (Tower of London)
14 The Tower of London listed Grade I, is located in a Conservation Area, and is designated
as a World Heritage Site and a Draft Management Plan has been prepared. Amongst other
things the plan identifies the “significant local views” which include views from Great Tower
Street and Lower Thames Street, views from the Thames and views from London Bridge and
Tower Bridge. The Draft Management Plan identifies viewing points and suggests that they be
worked up in more detail as per strategic views. The views from the River Thames “emphasise
the intimate relationship between the Tower and the River Thames set against the modern city
skyline”. Whilst the views from the bridges “express the full visual character and distinct identity
of the Tower, and give expression to context and setting, and its relationship with other
monuments, landmarks and city buildings”.
15 This document is advisory, as World Heritage Site Management Plans do not have a
statutory basis. They are designed as guides to the relevant controlling authorities and are a
“key material consideration” in exercising development control functions. They are however
important guidelines and are fully taken into account in the consideration of these proposals.
16 The massing of the scheme responds appropriately to its visually prominent riverside
location and has been designed to respond to adjacent buildings, in particular the Tower of
London. The City of London UDP (policy ENV 24) requires submission of photomontages and
other illustrative material to ensure evaluation of the impact of proposed development located
close to the Tower of London. The applicant has submitted a full visual assessment
demonstrating that the proposed scheme will not result in an unacceptable visual relationship
with the World Heritage Site. In particular, the south-eastern elevation and massing has been
set back and configured to respect views of the Tower of London from London Bridge.
17 The existing Three Quays building is visible from within the Tower. It is not necessarily
the case that any structure visible from the Tower or in the skyline will harm the World Heritage
site. The applicant’s view assessment states that “it is not possible to turn back the clock and
completely isolate the Tower from the outside world. The existence of the City heightens the
contrast and appreciation of the historic fabric and makes the Tower’s existence all the more
special… What is important is whether a visual intrusion damages the ambience of the spaces
within.” The photomontages submitted with the application illustrate that little of the proposed
building will be visible and that these views of the new building will be visible only from a limited
number of viewing points within the Tower. On the basis of this information it is considered
that the proposed development would not unduly interfere with people’s appreciation of the
Tower when viewed from both within and outside the site.
18 The irregular ‘U’ shaped configuration of the building enables the number of units with
river views to be maximised. This goal was clearly the impetus leading to the final form of the
building. The eastern element of the building is the most visually prominent, strongly defining
the building’s location at the edge of the City, and its proximity to the river and the Tower of
London. The building is stepped back on the western facade to retain views and light to the
adjacent building (Sugar Quay). The development is lower on the southern (river side) and taller
to the north. The building height is approximately the same as the existing building and is
slightly lower than the consented scheme (1998). The recessing of upper floors reduces the
visual bulk of the building and the random pattern of fenestration and stone and metal panels
break the horizontality of the neighbouring post-war buildings.
19 In accordance with London Plan policy 4B.1 the proposed scheme would enhance the
public realm as the majority of the southern and eastern elevations would be glazed and would
contain restaurant/retail uses at ground level, giving active frontage to both the riverside
walkway and new public open space adjacent to the Tower of London. The basement houses
most of the mechanical and electrical plant and the back-of-house areas for the building and the
car parking for the residential units. However, the south-western, ground floor corner of the
building (fronting the river) is also shown housing plant/equipment. This presents a blank
façade towards the river and occupies a relatively large area of valuable waterfront space. The
applicant has indicated that the plant has been located here due to servicing arrangements
within the building and that it is not feasible to relocate it. It is considered that further
justification should be provided to demonstrate why the plant is unable to be located within a
less visually prominent area. The proposal incorporates a water feature at first floor level located
on the southern elevation of the building. This element of the proposal is interesting but
additional information on how it would work would be useful.
20 The vitality and vibrancy of the area will also be enhanced by residential balconies at
levels above the ground floor enabling a good level of surveillance over the Riverside Walkway.
The south-facing terrace adjacent to the building would create an attractive and highly usable
amenity area for future residents and public. The landscaping of this area and provision of
seating for members of the public also form part of the benefits package to be secured by way
of condition of consent.
21 The City of London UDP and the London Plan (policy 4C.17) both acknowledge the
importance of providing improved access to the Thames River. The site is located within the
Thames Policy Area and it is proposed to extend the Riverside Walk (which now forms part of
the long distance Thames Path National Trail) between Tower Hill and the existing public
walkway at Sugar Quay. The applicant has indicated that the continuation of the Riverside
Walkway would be formalised through the completion of a Walkways agreement with the
Corporation of London. Accordingly, the proposed development would be consistent with the
London Plan and would provide the additional benefit of increasing the size of the open space
immediately in front of the building enabling members of the public to better appreciate the
views across the river towards the GLA building and to the Tower of London and Tower Bridge
beyond. The applicant has also commissioned a piece of art from William Pye to be publicly
displayed within the development thereby further enhancing the amenity and vitality of the
area. The Corporation of London has indicated that these benefits will be secured by way of
conditions on the planning permission.
22 The applicant has submitted a wind study in support of the application. It concludes
that the wind conditions around the building will be appropriate and will not cause adverse wind
turbulence effects. Overall the design quality is high and the form and massing of the proposed
building respects the local context, particularly the historic value of the Tower of London, and
would not harm the character or setting of the building.
Access and inclusion
23 Policy 4B.5 of the London Plan expects all future development to meet the highest
standards of accessibility and inclusion. An access statement has not been submitted to
demonstrate how principles of inclusive design have been integrated into the proposed
development. The access statement should be treated as more than a commitment to meet the
minimum standards of Part M of the Building Regulations. The access statement should clearly
demonstrate the applicant’s approach to inclusion, and show how all potential users, regardless
of disability, age or gender, can enter the site, move around the site, enter the buildings and use
the facilities. It is recommended that a marked-up plan at an appropriate scale, including
sections showing relevant gradients and any changes in level, be submitted with the written
Access Statement. This plan should illustrate: the main step-free pedestrian routes internally
and externally, showing how people move up and down as well as around the building and the
spaces between the buildings; access to car parking and public transport facilities; staff and
visitor entrances and other relevant facilities and features. Under policy 3A.4 of the London
Plan, all new housing should be built to lifetime homes standards and 10% of units should be
designed to be wheelchair accessible. The applicant should provide further information within
the access statement to demonstrate that these standards have been met.
Sustainable design and energy
24 Policy 4B.6 of the draft London Plan indicates that applications for strategic
development should include a statement showing how sustainability principles will be met in
terms of demolition, construction and long term management. The applicants have provided
limited detail in this regard and accordingly further details should be submitted explaining how
the development will meet the highest standards of sustainable design and construction,
including measures to: -
- Re-use land and buildings
- Conserve energy, materials, water and other resources
- Be bioclimatically designed
- Reduce the impacts of noise, pollution, flooding and micro-climatic effects
- Ensure developments are comfortable and secure for users
- Conserve and enhance the natural environment, particularly in relation to biodiversity.
25 Policy 4A.8 indicates that the Mayor will request an assessment of energy demand for
proposed major developments. This assessment should demonstrate the steps taken to apply
the Mayor's energy hierarchy. The Mayor expects all strategic commercial and residential
schemes to demonstrate that the proposed heating and cooling systems have been selected in
accordance with the following order of preference: passive design; solar water heating;
combined heat and power; for heating and cooling, preferably fuelled by renewables; community
heating for heating and cooling; heat pumps; gas condensing boilers and gas central heating.
No detailed information has been provided in relation to the proposed energy performance of
the development. Policy 4A.9 requires the applicant to demonstrate how a proportion (10% is
specified within the Mayor’s Energy Strategy) of the site’s electricity or heat needs can be
generated from renewables, wherever feasible. This information should be submitted.
26 The London Plan (policy 4B.15) has designated a number of strategically important river
prospect views, including the view from Tower Bridge. In addition this policy also designates a
number of strategically important townscape views including the view from City Hall across to
the Tower of London. As discussed under the Urban Design section of this report, the proposed
building has been designed and articulated in such a way that it will not harm these views.
27 The application site is adjacent to the River Thames, a site of Metropolitan Importance
for Nature Conservation. The GLA’s Principal Policy Adviser (Biodiversity) states that it “is
highly unlikely that the proposed development would have any significant adverse impact on the
ecology of the river as this is already a very disturbed stretch so birds occurring here are
generally those species less sensitive to disturbance. Shading is not an issue as the application
site is on the north bank of the river.” The opportunity for providing additional biodiversity
habitat alongside the River Thames (as encouraged by the Biodiversity Strategy and the Blue
Ribbon Network, London Plan policies) has not been taken. It is acknowledged that a softer
approach to the landscaping of the public areas may not be appropriate in the context of the
28 The site is located in an area of excellent Public Transport Accessibility. It is within
walking catchment of Fenchurch Street national rail station and Tower Hill and Monument
Underground stations. The site is located immediately adjacent to Tower Millennium Pier from
which London River Services (LRS) operate. Tower Hill Road and Tower Bridge Road also offer
access to 5 different bus services.
29 There was no Transport Assessment submitted with the application so TfL has been
unable to accurately predict the number of additional people who will be using the public
transport infrastructure. However, due to the scale of the building and the numerous transport
modes available, TfL considers that the development will not have a significant impact on the
public transport network.
30 TfL is concerned about access to Tower Millennium Pier. Adequate signage needs to be
provided as well as provisions for deliveries to the pier. Noise pollution due to passengers
disembarking at unsociable hours also needs to be considered. TfL will also seek a construction
statement in order to minimise the negative impact construction will have on the pier. TfL
London River Services is happy to meet and discuss these issues.
31 TfL welcomes the proposal of only 26 car-parking spaces. However, it seems no
provisions have been made to provide any cycle parking. The London Cycle Network (LCN)
Design Manual states that at least 64 secure cycle parking units should be provided for the
residential units as well as a reasonable amount for the retail and aparthotel uses. Several of the
cycle parking units should be located near the entrance in a secure location for visitors to use.
Comments from LDA
32 In principal the Agency supports the proposals for the mixed-use redevelopment of this
prominent riverside site, which has been vacant and subject to redevelopment proposals for
some years. Provided the Tower of London World Heritage site and strategic views issues are
satisfactorily addressed it will complement the Tower Environs Scheme which is making major
improvements to the visitor facilities and environment of the Tower of London, one of London's
most visited tourist attractions. The Agency is a significant funder through SRB of the last phase
of this scheme and also contributed to previous phases.
33 It is important that the scheme does allow for a high quality and attractive riverside walk
way with active frontages and surveillance such that the riverside route that has been created on
the north bank of the Thames can properly continue through this site. This is another project in
which the Agency has been involved through SRB.
Comments from other agencies
34 The Commission for Architecture and the Built Environment has expressed “broad
support for the project and would be happy to see the scheme approved and built, subject to the
conclusion of negotiations between the applicant and the planning authority.”
35 Under the terms of the Water Resources Act 1991 and the Land Drainage Byelaws 1981,
the prior written consent of the Environment Agency is required for any proposed works or
structures either affecting or within 16 metres of the tidal flood defence structure. The
Environment Agency has objected to the proposal on the basis that a Flood Risk Assessment is
required. The applicant has commissioned a report from a structural engineering company who
have confirmed the longevity of the river wall and its functionality as a flood protection device,
but the Environment Agency do not consider that this information adequately addresses their
36 English Heritage considers that the scale and form of the proposed building “would
create an unduly assertive relationship with the River, the World Heritage site and the setting of
the listed Pump House.” It is of the opinion that “the proposed design of the replacement
building would benefit from taking greater account of the positive aspects of the existing
building, such as its quiet and understated presence and careful massing in relation to the River
and the Tower.” English Heritage welcomes the efforts made to integrate the proposed
development with the Tower Environs scheme and the Riverside Walkway.
Historic Royal Palaces
37 The applicant has been involved in on-going discussion with Historic Royal Palaces
(HRP) throughout the course of the application, but has not been able to address its concerns.
HRP is concerned with the cumulative impact of incremental growth in the scale and visual
dominance of new development surrounding the Tower of London. In particular, HRP considers
that the proposed development would continue the detrimental visual impact of the Tower Place
scheme, when the proposed scheme is viewed from within the Tower grounds. HRP considers
that the only way to avoid the adverse visual impact would be the reduction in height (by at
least 2 storeys) of the eastern elevation of the building. HRP also have concerns regarding the
impact of the development on views of the World Heritage Site, stating that views as a whole
“from London Bridge would be more constrained, with the proposed ‘bookend’ building
Local planning authority’s position
36 The Corporation of London case officer’s recommendation will be for approval.
37 Under the arrangements set out in article 3 of the Town and Country Planning (Mayor of
London) Order 2000 the Mayor has an opportunity to make representations to the Corporation
at this stage. If the Corporation subsequently resolves to grant planning permission, it must
allow the Mayor an opportunity to decide whether to direct it to refuse planning permission.
There is no obligation at this present stage for the Mayor to indicate his intentions regarding a
possible direction, and no such decision should be inferred from the Mayor’s comments unless
38 There are no financial considerations at this stage.
39 The proposal is considered to deliver good quality architecture, which will positively
contribute to London’s World City image and will generate improvements within the public realm
through the continuation of the Riverside walkway and the creation of an additional area of
public open space surrounded by active retail frontage. However, further justification should be
provided to demonstrate why the plant at ground floor level within the south-western corner of
the building cannot be accommodated elsewhere to ensure that the entire river front of the
building is ‘active’ space. Additional information should also be submitted regarding how the
proposed water feature would work. The proposal is not considered to harm the World Heritage
site. The density of the development has been suitably maximised given the sensitive historic
riverside context of the site and the proximity and scale of adjacent buildings.
40 The provision of residential units (as part of a mixed use scheme) is beneficial and is
consistent with London Plan policy, which seeks to increase housing provision to sustain
economic development. An adequate level of affordable housing must be guaranteed through a
legal agreement requiring payment of a sizeable off-site contribution. This should be calculated
on the basis of being equivalent to 50% on site affordable provision. Any variation from this
would need to be justified by a financial appraisal. Further details are also required in relation
to the off site proposal, in terms of the site and the host borough agreement.
41 Little detail has been provided to demonstrate that the scheme would incorporate the
principles of inclusive design. An access statement should be submitted to demonstrate this. In
addition details should be submitted to confirm that 10% of the proposed residential units
would be wheelchair accessible and that all units have been designed to lifetime homes
42 The applicant also needs to illustrate that the building has been designed in accordance
with sustainable design and construction principles. An assessment of energy demand for the
proposed development should also be submitted and this assessment should demonstrate the
steps taken to apply the Mayor's energy hierarchy, in line with London Plan policies.
43 On balance, subject to the above comments, the proposed development would be in the
interests of good strategic planning in London.
for further information, contact Planning Decisions Unit:
Giles Dolphin, Planning Decisions Manager
020 7983 4271 email firstname.lastname@example.org
Colin Wilson, Acting Team Leader Development Control
020 7983 4783 email email@example.com
Case Officer, Lee Ogilvie
020 798 4493 email firstname.lastname@example.org