Aleksandra Milentijevic

London Borough of Tower Hamlets

Town Hall
Mulberry Place
5 Clove Crescent
E14 2BG

By email

Date: 29 July 2022

Our ref: 62545/01/BK/25616039v2
Your ref: PA/22/00210

Dear Aleksandra

Ailsa Wharf: response to planning application ref. PA/22/00210

consultation comments
We write on behalf of our client London River Lea One Limited, in respect of the application (ref.
PA/22/00210) submitted for the site at Ailsa Wharf in the London Borough of Tower Hamlets (LBTH).

Consultation feedback

Thank you for sending through all of the consultation responses received from consultees over the past
few weeks during the consultation period on the amended proposed development at the Ailsa Wharf
site. The consultees from which we have received response are listed in Appendix 1.

We have received the GLA Stage 1 report, which will be responded to separately and will copy you into
the issue for information. In parallel to this, a comprehensive response to the ES review is also being
submitted to the Council under separate cover.
We have also received responses from the following statutory consultees, confirming no comment or
that no action is currently required:
1 Planning Casework Unit (Department of Levelling Up, Housing and Communities)
2 NATS safeguarding
3 Transport for London Infrastructure Protection
4 London City Airport
5 Natural England

Nathaniel Lichfield & Partners Limited (trading as “Lichfields”) is registered in England, no. 2778116
Registered office at The Minster Building, 21 Mincing Lane, London EC3R 7AG
6 Marine Management Organisation – noted that any works within the Marine area require a licence
(a post-planning action noted by our client to action if and when required).

Appended to this letter is a full table summarising all comments received and setting out responses for
your review (see Appendix 2). Appendices 3-9 comprise additional clarifications to the comments set
out in the response table. The following documents are also submitted alongside this letter to address
consultation feedback and be included within the application material for approval:
1 Gateway One Fire Form, completed by Atelier Ten;
2 Updated Waste Management Strategy report (and associated appendices), prepared by Stantec, to
reflect consistent URS figures and clarify food waste comments;
3 Updated Whole Life Carbon Assessment and GLA Whole Life Carbon assessment template,
prepared by Stantec; and
4 Plans showing buffer zone between river, extant consent and proposed, prepared by Alan Baxter,:
a Proximity of Phase 2 building to river wall: ground floor (drawing ref. AIL-ABA-XX-XX-DR-S-
2111 P01); and
b Proximity of Phase 2 building to river wall: upper floors (drawing ref. AIL-ABA-XX-XX-DR-S-
2112 P01).

Minor scheme amendments

In addition to reviewing the consultation feedback, the design team have been undertaking
coordination work to ensure the buildability of the proposed development. There have been very slight
and essentially imperceptible changes that require the substitution of some drawings. We set out
changes below for clarity and to aid in identifying these:
1 Very minor road layout update around the entrance to the northeast car park area following
coordination;
2 Changes to doors on Level 00 from the core to the courtyard;
3 Relocation of cycle store from J2 Level 00 to the basement;
4 Additional new play space below the undercroft in J2;
5 Enclosure to the ramps that give access to the basement parking at in Phase 1; and
6 Very minor roof layout amends to locations of plant enclosure and planters on some roofs; and
7 Changes to opening types on West Elevation in Blocks E and F.

For avoidance of doubt, all alterations were very limited adjustments in plan and are included now for
completeness. None of the above changes have an impact on the EIA submission. Appendix 9 lists the
drawings to be substituted and superseded.

Since submission, it has also been noticed that there is a small discrepancy in the total commercial and
residential square footage that came from the excel file and has been copied into the Schedule of
Accommodation. To rectify this, we have provided an updated Schedule of Accommodation.

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Summary

As the Case Officer for this application, we would be grateful if you could please circulate the relevant
responses to consultees to re-confirm the acceptability of the proposals and keep us informed of this
process.

In parallel, we have responded to the GLA Stage 1 report and we are providing a comprehensive
response to the ES review under separate cover for review by the EIA Officer.

Overall, we consider we have responded to comments and made minor amendments to documents and
development as far as possible in order to accommodate feedback from consultees. We wish to reiterate
that Phase 1 of the extant consent (ref. PA/18/03461/S; S73 approved 16 January 2020) was
implemented in 2021, prior to the expiry of the permission. Given the progression of Phase 1, much of
the design could not be altered at this stage. Phase 1 was included in the new application for
completeness. A planning application strategy based on submission of a single comprehensive site-wide
application subsuming Phase 1 and delivering improvements to Building M and the riverside blocks and
spaces was expressly requested by Officers to provide a more holistic and manageable planning
solution. The early delivery of Phase 1 will enable the early provision of homes and affordable homes
and an early enacting development in the housing zone which constitutes a major benefit of this
approach, despite minor policy inconsistencies due to policy changes since the previous scheme was
granted.

Officers understanding and agreement with this was confirmed at the pre-application stage. The GLA
pre-app feedback (dated 22 April 2021) notes in relation to a number of matters that it is acknowledged
that there are constraints to amending the design of Phase 1 due to its advanced stage and extant
consent, which may limit the potential of Phase 1 to meet up to date planning policy. The LBTH pre-app
feedback (dated 6 May 2021) notes that the proposed scheme does not include changes to the courtyard
blocks that form Phase 1 of the extant consent and this limitation is acknowledged. It is considered that
Officers agreed the strategy to maintain Phase 1 as is, complying with previous policy requirements and
making minor improvements where necessary, and encouraged implementation of Phase 1 on this
basis, ahead of the new application submission; this is the reason for someminor policy inconsistencies
in the site-wide application. We trust this is clear and that Officers recall the planning strategy agreed.

We trust the information provided is clear and includes the necessary additional details that were
requested by various consultees. However, if you do have any further queries, please do not hesitate to
contact me or my colleague Georgia Crowley.

Yours sincerely

Kelly Phillips
Planning Director

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Letter enclosures
Appendix 1: List of Consultees
Appendix 2: Consultation response table
Appendix 3: Document illustrating frosted glass for active frontages at cycle stores, prepared by Broadway Malyan
Appendix 4: Detailed response to LBTH noise comments, prepared by Scotch Partners
Appendix 5: GLA Whole Life Carbon response memo, prepared by Stantec
Appendix 6: GLA Energy response spreadsheet and all supporting evidence, prepared by Atelier Ten
Appendix 7: Detailed response to TfL comments, prepared by Steer
Appendix 8: Pre-development enquiry letter from Thames Water (dated 15 November 2021)
Appendix 9: List of submitted drawings for substitution
Gateway One Fire Form, completed by Atelier10
Updated Waste Management Strategy report and associated appendices, prepared by Stantec, to reflect consistent
URS figures and clarify food waste comments
Updated Whole Life Carbon Assessment and GLA Whole Life Carbon assessment template, prepared by Stantec
Plans showing buffer zone between river, extant consent and proposed, prepared by Alan Baxter,:
Proximity of Phase 2 building to river wall: ground floor (drawing ref. AIL-ABA-XX-XX-DR-S-2111 P01)
Proximity of Phase 2 building to river wall: upper floors (drawing ref. AIL-ABA-XX-XX-DR-S-2112 P01)
Updated Schedule of Accommodation (excel and PDF format)
General Arrangement Plans Level 00
General Arrangement Plans Level 01
General Arrangement Plans Level 02
General Arrangement Plans Level 05
General Arrangement Plans Level 06
General Arrangement Plans Level 07
General Arrangement Plans Level 08
General Arrangement Plans Level 09
General Arrangement Plans Level 10
General Arrangement Plans Level 22
General Arrangement Plans Level B01 - Basement
General Arrangement Plans Level 23 - Roof
General Arrangement Plans Levels 11 to 21
General Arrangement Plans Levels 03 and 4
Site Elevation 05 West Site Elevation

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Appendix 1: List of Consultees

The consultees from which we have received response are as follows:

1 LBTH departments on:
a Design
b Housing
c Waste
d Energy
e Noise
f Air Quality
g Contaminated Land
h Biodiversity
i Occupational Therapy
2 Greater London Authority (GLA) on:
a Whole Life Carbon
b Energy
3 Transport for London
4 Environment Agency
5 Health and Safety Executive
6 Thames Water
7 Port of London Authority
8 Canal and River Trust
9 Marine Management Organisation
10 Historic England

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 Appendix 2: Consultation response table

Consultee Summary of comments Applicant response

LBTH Design Overall design Design officers are broadly supportive of the design of the
1. Moderate increase in height across site proposed development and note it is a significant improvement
from consented scheme considered on the extant consent for the site.
acceptable.
2. Buildings layout, orientation and overall
massing considered an improvement
resulting in scheme that would sit better in
both existing and emerging character of the
wider area.
3. Urban design principles presented by the
proposals are supported by LBTH Place
Shaping.
4. Street layout, alignment with underpass
and bridge considered sensible.
5. Realignment and orientation of buildings
results in improved desire line from A12 to
park and will draw people to riverside space.
6. Do not object to heights and agree that
layout, landscape, public realm, movement
and connectivity are all improved from
previous approval.
Landscape Design officers are supportive of the overall landscape
1. Approved landscape scheme is masterplan and note the significant improvement in terms of
predominantly hard, overly complicated and landscaping, public realm, open space and connectivity, in
did not maximise opportunities for greening. comparison to the extant consent for the site. There are a
Revised design inc. new park is positive and number of competing requirements to be incorporated into the
considered a great improvement. public realm, including play space, accessible parking, future 10%
2. Proposed new public realm has potential accessible parking, circulation, service and emergency access,
to bring benefits to wider community. visitor cycle parking, iceberg refuse bins. The greening across the
3. Park acts as public interface to the river site has been thoroughly maximised whilst also accommodating
and ensures it does not feel privatised, helps all of the above requirements and a successful ground floor and
activate river and links to the river walk landscape has been achieved.
which will continue on to the Gasworks Site
and Levan Road sites. Regarding the bridge landing, the landing area is considered
4. The proposed new bridge crossing on sufficient and demonstrates continuity with the extant consent
Lochnagar Street and proposed park have for this area. The safeguarded land has been considered in the
not been considered as one system in design design and landscaping throughout, and appropriate distances
terms. This application and the separate for the landing area are safeguarded through these proposals.
bridge application should be considered in Throughout design development, the detailed landscaping has
tandem and the design of the bridge should been designed in conversation with the design of the bridge and
not impact on the good work presented here bridge landing area in order to minimise any impacts on public
in terms of layout, landscape, public realm realm and play space requirements while ensuring space is

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 and connectivity. At this time, the bridge provided to accommodate the level changes, circulation and
proposals could compromise Ailsa Wharf. accessibility that will be required.

The bridge is connected to the application via an agreement that

the applicant will submit the bridge application on behalf of LBTH
in due course, however the bridge is to be delivered by the
Council. Realistically, they cannot come forward in tandem due
to the timescales on which both projects are happening; the
bridge has always been envisaged as a separate application, this
has been agreed with the Council and this should be confirmed
by Planning officers in response to these design comments.

There will be conditions attached to the permission enabling the

bridge details to come forward in due course and the applicant
and Council will consult at length on the bridge application to
ensure it connects seamlessly with the Ailsa Wharf scheme and
other developments in the area. At present, it should be
confirmed that the appropriate land is reserved in the meantime.
Ground floor The team worked together though the pre-application process
1. Particularly in blocks A and B, much of gf is during various meetings with LBTH to increase ground floor
inactive. Park-facing units are active but activation. The ground floor uses include commercial spaces and
Lochnagar Street needs more activation. residential amenity/ entrances/ concierge and though there is
South and West elevations in particular need some plant equipment required by the façade line and cycle
further activation. stores we consider the gf layout to be an appropriate balance of
2. Block C is inactive other than one unit activity, with activity mostly concentrated in the attractive areas
facing park. It is understood that cycle where people are being encouraged to dwell.
parking requirements are significant but
design of gf does not allow for interaction The commercial and residential entrances will have transparent
between the cycle storage and the public glass to maximize activation. It was agreed during the pre-
realm and should be revisited. application process that the cycle stores are also considered
3. For example, the application could active spaces therefore these also contribute to active frontage,
consider a different finish to the gf to however in response to the comments, we have reviewed the
maximise visual permeability and connection facades for cycle stores. This has been discussed with Secure By
between the inside and out. Design Met Police Officers to ensure security principles are still
4. Block M gf provides more activity, but upheld. We propose that the gf cycle stores will now have a frost
again a different approach to the design of manifestation to increase activity and create a better visual
cycle storage to allow more visual connection connection between in and outside, while maintaining security
between inside and out should be explored. and avoiding direct surveillance. A document is provided at
Appendix 3 to illustrate this.
Single aspect The previously approved scheme contained 50% dual aspect
1. Officers consider there remains a number units. The design developed during the pre-application process
of single aspect units across all blocks. allowed for 50% dual aspect and after discussions with the GLA
and LBTH and careful design development, this was reviewed
and maximised to enable 71% dual aspect units which is a
significant improvement on the approved scheme.

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 Materials/ architecture The materials are broadly supported and the final material
1. Waterside buildings: responds to heritage details will be conditioned to be discharged in due course. All be
of area well. Provided the quality of the brick high quality and in keeping with the design approach to the
proposed is secured through condition, LBTH scheme, linking to its heritage. The applicant team wished to
Place Shaping have no issue. create an individual identity for Building M due to its location
2. Lower buildings: same brick as used for within the site which gives it a slightly different context to the
base of the waterside buildings would be riverside area. Building M marks the entry to the site from the
employed, visually linking the buildings which A12 and creates a gateway from Lochnagar Street. Officers
they adjoin. LBTH Place Shaping support this considered the architecture and distinctiveness of Building M
approach. acceptable, provided materials be conditioned, which is agreed.
3. Building M: LBTH Place Shaping do not
have issue with architectural quality of this
block but query why the building is
considered to need an individual identity.
Overall though, there is no significant
negative impact from use of red brick for this
building. Acceptable subject to quality of the
material being secured by condition (or
identified in planning drawings and agreed
pre-determination)
LBTH Housing Building M Building M
1. Building M is close to the A12 so will need 1. Building M is sealed unit. The mitigation of noise and pollution
to ensure that all mitigation measures are has already been dealt with in the design and is detailed in the
included within the design to stop noise and technical submission on noise and air quality in the ES. All
pollution into the homes that face onto this competing design matters were thoroughly considered and the
busy road. design of Building M is of extremely high quality to ensure the
2. Some of the 3 bed 5 person units do not conditions inside the units are appropriate and desirable.
appear to have charging points? 2. Accessible units provide charging points. Adaptable layouts
3. Will there be any car parking spaces on- will not indicate the allocated charging point now but allow area
site for the affordable rented wheelchair for adaptation if required by a wheelchair user.
users as most of the units will be in Building 3. Accessible spaces are provided as per policy requirement.
M. Where would the drop off be situated for Spaces aren't assigned to units but this will be discussed with the
these wheelchair users along with the car RP and apportioned appropriately at the relevant time. A car
parking spaces? park management plan can be secured by condition.
5. In 4 person units throughout the block, the 5. The units have been designed appropriately to balance a
bathroom door opens out into the general number of amenity and layout matters, maximise space and
living area of the unit. Could these be create desirable units therefore we consider this change is not
reconfigured so that all the bathroom doors required and have not provided revised floorplans at this time.
of this type of unit to open outwards onto Should the case officer however consider this is a definitive
the hallway? requirement, we can review further.
6. Internal hallway doors would have to be 6. We note this advice and doors all can be automated. This
automated for the wheelchair units. Main would likely be by fob access, to be confirmed with the RP at the
front/exit of the building would also need to relevant time.
be automated for the wheelchair users; this
could be by fob arrangement.

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 Block B2 Block B2
1. Check the daylight/ sunlight into the 1. The BRE Report discusses daylight expectations in internalised
kitchens of plots B201.03-05, the kitchen kitchens and states at paragraph 2.2.15: “Non-daylit internal
areas are set back into these properties? kitchens should be avoided wherever possible, especially if the
2. Plots B2.02-6-8 appears to have an inner kitchen is used as a dining area too. Daylight levels in kitchen
door before you get to the front door of the areas should be checked. If the layout means that a small internal
property? kitchen is inevitable, it should be directly linked to a well daylit
3. It is noted that the scheme is now room.” By reference to the daylight distribution drawings
delivering 4 bed intermediate units, will appended to the submitted EIA, it can be seen that even where
these units be shared ownership? Will they direct daylight penetration does not reach the kitchen spaces
meet with the GLAs affordability criteria? they are linked to a living space that receives good daylight
4. Is the developer proposing to deliver the access and therefore are considered acceptable in terms of the
council’s current rental policy of 50% London relevant guidance.
Affordable Rent and 50% Tower Hamlets 2. The additional door is a fire requirement, to create a protected
Living Rental levels? Has the applicant lobby. This must remain in place for fire safety purposes.
engaged with an RP for this scheme to date? 3. Policy H6 of the London Plan requests a minimum of 30%
intermediate products. This is reiterated in the Local Plan, where
30% intermediate housing is requested and the policy specifically
requests larger intermediate units are included in the mix. The
scheme proposes the affordable housing delivery of 898
habitable rooms, split 64:36 in favour of affordable rent (broken
down into 50% LAR and 50% Tower Hamlets Living Rent) with the
remaining being intermediate shared ownership units. There are
3x 4-bed intermediate units located in Block E. We consider the
proposed mix therefore seeks to meet policy requirements and
are confident that the units can be let and are appropriately
designed and located to provide necessary intermediate product
units in this area.
4. As above, the proposed development intends to provide policy
compliant tenure of 50% LAR and 50% Tower Hamlets Living
Rent. We have sought to discuss the scheme with RPs thus far
however, in our experience, they tend to engage more
constructively at later stages once consent is gained. We strongly
believe that the scheme will; gain interest and meet need and
demand for affordable housing in this area.
LBTH Waste The waste comments are summarised as 1. The URS number discrepancy has been checked with tables
follows: and plans. The plans are correct and the Waste Management
1. Please check number of URS bins to be Strategy has been brought into line to ensure consistency.
provided – numbers change. 2. All units are within 30m of the food waste disposal points. For
2. Confirm carrying distances for all waste waste, 67% of units fall within the 30m carry distance with the
storage. remaining 33% requiring a carry distance of between 30-44m.
3. The submitted information needs to This has been evaluated during the pre-application and design
demonstrate that the vehicle can stop, with development stages and this compromise has been agreed due
the vehicles’ stabilisers deployed, and carry to other constraints across the scheme.

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 out the collections in a safe manner at all 3. All locations where the vehicle stops in on private highway or a
locations. Details should be provided. dedicated area off street (in front of block A). Areas where the
4. Turning circle at block A tight – please vehicle stops are 5.5m – 5.8m in width and the bins are directly
confirm it works. adjacent to the place the vehicle stops. There is no LBTH
5. Block C - what is the vehicle reversing guidance available for the deployment of stabilisers.
distance here? Confirm the space is 4. Vehicle tracking was provided as per the guidance document.
appropriate. The manoeuvre shown is relatively basic in that it is only one
6. Block M - there is a tree positioned very reversing manoeuvre. Bridge design and pedestrian routes will
close to the units, and a car park space, be considered as part of the design process with a view to
which could impact the waste activities. segregation.
Details on any conflict needed. 5. The reversing distance is approximately 25m. Cars would have
7. More detail is required on the collection of to wait for the collection to be carried out, which isn’t
the food waste. uncommon when residential waste collection operations are
8. All multi-storey residential developments taking place. The car park has 6m clear width. There is no LBTH
must have a separate space for the short- guidance available for the deployment of stabilisers.
term storage of bulky items of furniture or 6. There is no conflict here. The safe systems of work that should
electrical items, at ground level. Provide be in place allow for operators to collect URS through the use of
details the crane lift for which they will have had extensive training. At
9. Query regarding the future car park spaces no point should containers be lifted above parked cars. If the
and the implications on the collections and tree canopy growth starts to obstruct collection activities a
the movement of the vehicle through the request will be made to have it cut back.
estate. Provide further details 7. Details added into the updated Waste Management Strategy
10. All commercial units should have report for food waste presentation and collection. Block M
sufficient waste storage facilities. Details collection directly from store within the 10m drag distance and
required. food waste stores beyond the 10m having containers presented
kerbside by the facilities team and then being returned once
cleared.
8. There are 2 bulky stores being provided for the development
within block J (Phase 1) and block B (Phase 2). These will supply
some short term storage space. The provision of the removal of
bulky waste from the site will be highly managed by the facilities
team. They will co-ordinate with residents ensuring that a
collection has been agreed before presentation of items. Where
required the facilities team will assist in the correct presentation.
Additionally, there will be an agreed education and enforcement
regime which will help to ensure that all residents are aware of
their responsibilities around the presentation and collection of
bulky waste items.
9. Parking restrictions and enforcement will be provided
throughout the estate to prevent parking on the internal estate
roads – unless in dedicated bays. This can be identified in due
course through a car park management strategy.
10. The commercial units are being supplied to tenants on a
‘shell and core’ basis, as is common and widely accepted. The
tenants will then be expected to fit out the internal space in line

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 with their needs. This includes for the provision of waste and
recycling storage and segregation. They will then be in a position
to contract out the waste and recycling collections in line with
their needs. This will be done in line with all licencing
requirements for waste movement and processing.
LBTH Energy Energy Officers confirmed that the use of a We concur that the use of boilers in Phase 1 was agreed during
boiler is currently proposed within Phase 1 to the pre-application stage and give Phase 1 is currently being built
deliver a portion of the heat demand. Whilst out on site, amending the design is currently unfeasible. As such,
boilers are not normally accepted and we have aimed to make Phase 2 more environmentally friendly
alternative low carbon sources should be and compliant with up-to-date energy requirements.
used, in this instance the boiler is considered
acceptable due to its incorporation within The applicant team has reviewed the submitted proposed energy
PA/16/02692 and the scale of development strategy and considers that this is a robust and appropriate
already commenced under that planning scheme for the proposed development to ensure energy
permission. efficiency and renewable energy generation where possible,
while accommodating the existing Phase 1 energy strategy and
Energy Officers asked the applicant team to other requirements of the scheme.
further review the opportunities for
renewable energy in the scheme and Atelier Ten have reviewed and confirm that there are no further
maximise PV solar panels. A plan of the total opportunities for solar panels and renewable energy generation
proposed PV panel installation panels is also at Ailsa Wharf. The roof space has been fully maximised for PV
requested to confirm the rood area has been panels. The final quantum on the roofs is considerable but Is
maximised in the context of other constraints linked to the genuine availability of space. PVs are located at roof
relating to the use of roof space. (L08) of F2, G, J and K – these are currently as efficiently placed
as possible and cannot be moved or expanded to cover more
Model additional energy efficiency measures roof space due to other competing requirements such as amenity
to meet the energy efficiency target and space and green/brown roof.
review the opportunities to deliver
renewable energy generating technologies.
Maximise solar PV then submit the total PV
system output (kept) and a plan showing that
the proposed installation has been
maximised for the available roof area and
clearly outlining any constraints to further
PV.
LBTH Noise The noise comments and detailed responses, noise level history chart and sample construction noise
calculations are included at Appendix 4.
LBTH Air No objection to the scheme. Requested Lichfields requests to review the conditions in due course and
Quality conditions relating to dust management, air will confirm against previous set and already discharged
quality, construction plant and mechanical conditions.
ventilation.
LBTH A pre-commencement and pre-occupation Remediation preparatory works for the site begun taking place in
Contaminated condition is requested regarding details of October 2021 and are being completed in Summer 2022.
Land remediation however, the response notes

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 that if the site has already been remediated, A pre-commencement condition is not required as this was
this could remove the need for a pre- approved in relation to Condition 3 of the original planning
commencement part of the condition. permission ref. PA/16/02692, under ref. PA/19/00189 (approved
6 November 2019 for parts ai and aii and approved 19 November
for part aiii of the condition). Parts aiv and av were approved in
relation to the implemented permission ref. PA/18/03461, under
ref. PA/21/00223 (approved 8 April 2021).

The remaining part of Condition 3 (part c) requires a post-

completion report to be undertaken. This will be carried through
to the new permission.
LBTH Biodiversity Officers request conditions to On the conditions, Lichfields requests to review the conditions in
Biodiversity secure: due course and will confirm against previous set and already
• Safe and legal eradication and disposal of discharged conditions.
the Japanese knotweed.
• No illumination to be directed at On lighting, a sensitive lighting scheme designed in accordance
treelines near the river. with ‘Guidance Note 08/18’ (BCT, ILP, 2018) to minimise light
• Biodiversity mitigation and spill into sensitive habitats will be implemented.
enhancements are implemented.
The 511sqm of semi-natural vegetation includes appropriately
The Officers request clarification on 511sqm designed flower-rich grassland, but also the intertidal terrace
of semi-natural habitat and note that prarie which will comprise native wetland species. The condition
planting will not be considered flower-rich proposing that 511sqm of is 'medow suing native species' is
grassland. therefore not appropriate as some of this incudes wetland area
which should still be considered semi-natural habitat.
Replacement of Tilia tomentosa trees(toxic
to bees) with native Tilia cordata, T. The request for replacement tree type is noted and this can be
platyphyllos, or their hybrid T x europaea. agreed and conditioned.
LBTH The Occupational Therapist sets out a We have already made provisions for everything the
Occupational number of matters for inclusion in the Occupational Therapist requests, including all wheelchair
Therapy wheelchair units including: accessible lifts. As such, we considered this matter is covered off.
• Two fully wheelchair accessible lifts. We do not believe the feedback requires any additional drawings
• Wheelchair charging points. etc to prepared at this stage and therefore there should be no
• Specifics regarding kitchen and further outstanding matters.
bathroom arrangements.
• Internal level access (ie: no wooden Regarding Part M4(3)(2)b accessible units in Block M, Block M
thresholds). wheelchair units are shown in the planning application as
M(4)(3)(2)a adaptable units as there would be a disproportionate
There is a request that wheelchair units are number of wheelchair units in the building and adaptable units
delivered as Part M4(3)(2)b accessible units, can be made into wheelchair units as and when required. This
not adaptable. We understand this relates to felt like the most appropriate solution however 2b and 2a units
Block M. have the same size requirement, it is only the fit out that differs.
As such, we can mark some of the units as being provided as Part
M4(3)(2)b if required. If so, we would like to confirm a

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 percentage that should be Part M4(3)(2)b as opposed to
M(4)(3)(2)a please.
GLA Whole Life The GLA has provided a spreadsheet of their comments, in which Stantec has provided their comments. Please
Carbon find the completed response spreadsheet at Appendix 5.
GLA Energy The GLA has provided a spreadsheet of their comments, noting that the energy strategy has some
inconsistencies with the London Plan and additional information or consideration is required, to which Atelier
Ten has responded. Please find the completed the response spreadsheet at Appendix 6.

Supporting documentation is also provided alongside this letter. This comprises:

• GLA carbon emission reporting spreadsheets;
• GLA pre-application advice note referring to overheating;
• Screenshot of enquiry to Olympic Park District Heat Network;
• Site wide heat network plans;
• Supporting information on PVs including extracts from the application submission and maps of solar
insolation and amenity space required at roof level;
• SAP worksheets; and
• Good Homes Alliance early stage overhearing tool.
Transport for See detailed response prepared by Steer which summarises comments and provides responses at Appendix 7.
London
Environment The EA request: Alan Baxter have provided a plan to confirm the buffer zone
Agency • plans to be provided which show the between the main river and proposed development. The two
buffer zone between the main river and drawings showing the distance of the extant consent and the
development in comparison to the proposed development to the river wall are provide alongside
previously consented scheme. this submission.
• Confirmation that the raising strategy is
the same as previously consented. We can confirm that the raising strategy is the same as
• For details to be provided if tree planting consented, and that tree planting can be secure by condition.
within 16m of new flood defence.
• For details of aquatic biodiversity Regarding aquatic biodiversity, this was not scoped into the ES
loss/gain as a result of the flood and therefore we consider the request unnecessary as this
defences. environmental impact does not need to be quantified in relation
to the proposed development, in accordance with the ES Scoping
exercise undertaken prior to the application submission.
Health and A Fire Statement Gateway One form is Atelier Ten have provided a completed Gateway One Form. This
Safety required to be submitted alongside the Fire is submitted alongside this letter.
Executive Strategy.
Thames Water Thames Water confirmed that the surface A pre-development enquiry with Thames Water was undertaken
water capacity is acceptable. In relation to in November 2021 and it was confirmed that there is sufficient
foul water, Thames Water requested further capacity for the full development. Please see letter from Thames
information on the foul water infrastructure Water dated 15 November 2021 at Appendix 8. As such, the
of the development and request a condition condition relating to capacity for over 99 dwellings is irrelevant
confirming foul water capacity exists to and not required.
handle the development. The comments cite
that capacity is available for 99 dwellings and

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 capacity will need to be agreed thereafter Regarding any proposed conditions, Condition 5 of the
(secured via condition). Overall, Thames implemented permission ref. PA/18/03461 on the piling has
Water is working with the developer on the been discharged In relation to the extant consent under
application to identify and deliver off site application ref. PA/21/00223 (approved 14 July 2022) and we
water infrastructure. expect this to be carried through to the new development.
Lichfields requests to review the conditions in due course and
As development is located 15m of a strategic will confirm against previous set and already discharged
sewer, a condition relating to piling method conditions.
statement is required.

Due to location within 15m of underground

water assets, an informative is to be added
to the decision notifying of this.
Port of London This part of the River Lea is outside of the The applicant is aware of the requirements for licenses in this
Authority PLA’s navigational jurisdiction but within its area and will apply if and when necessary.
landownership. Therefore, any works in, over
or under the river in this area may require an The submitted application does not include the bridge as this will
estates license. be detailed in a separate application to come forward in due
course, as agreed with LBTH. The PLA are aware of ongoing
The PLA note that the submitted application discussions and will continue to be consulted on the bridge
does not include detailed proposals for the proposals as appropriate.
footbridge over the River Lea in this area but
allows for an area of safeguarded land The applicant confirms agreement to condition to provide
(624sqm in size). As per ongoing discussions, lifesaving equipment along the river edge and to include detail
there must be appropriate safeguarded land on the river in the CEMP.
for future access/exit ramps.
Lichfields requests to review the conditions in due course and
Essential riparian equipment (eg: life buoys, will confirm against previous set and already discharged
grab chains, escape ladders) along river edge conditions.
should be conditioned to be included in the
landscaping.

The full CEMP (which will be conditioned)

must give consideration to maximisation of
the River Lea during construction stage.
Canal and River Suitably worded planning conditions must be Regarding the conditions, Lichfields requests to review the
Trust sought for: conditions in due course and will confirm against previous set
- Pollution control and already discharged conditions.
- Final CEMP
All drainage in the basement areas is connected to the foul
Mitigation measures will be required to drainage which discharges to the public sewer rather than the
prevent egress of water into basement car river, therefore there should be no concern for Canal & River
park and buildings, as set out in the Flood Trust. The basement car parks are also part of the Phase 1
Risk Assessment. An alarmed separator consented scheme and have been approved previously,
should be considered. therefore we would expect consistency to be applied.

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 No oil interceptors/by-pass separators are currently provided as
No extracted/perched groundwater should they are not required by the EA for covered car parks.
be allowed to be discharged into the River
Lea during the demolition/ construction Regarding the request that 'no extracted/perched groundwater
works. This is consistent with p.31 of Chapter should be allowed to be discharged into the River Lea during the
F of the previous ES. demolition/ construction works', this is not envisaged to be
problematic and is already included within the previously
The Delivery and Servicing Plan and approved ES. We expect this to be carried through to the new
Construction Logistics Plan should consider permission.
the opportunity for the developer to
transport construction materials and The delivery of construction by waterborne freight is unlikely to
demolition waste associated with the be feasible due to viability and offloading materials at the site.
development by using waterborne freight. This was not a condition requirement previously therefore we
would seek for this to be excluded.
Historic An appropriately worded archaeological Condition 4 was discharged in relation to the original application
England condition should be secured given the nature ref. PA/16/02692, under ref. PA/19/01821 (approved 9 October
of the development. 2019). This was carried forward to the S73 implemented consent
ref. PA/18/03461 and we would expect this is carried forward
again. The archaeological work has been thoroughly undertaken,
as detailed in the submitted ES and work is now taking place for
Phase 1 on site.

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Appendix 3: Document illustrating frosted glass for active frontages at cycle
stores, prepared by Broadway Malyan

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Appendix 4: Detailed response to LBTH noise comments, prepared by Scotch
Partners

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Appendix 5: GLA Whole Life Carbon response memo, prepared by Stantec

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Appendix 6: GLA Energy response spreadsheet and all supporting evidence,
prepared by Atelier Ten

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Appendix 7: Detailed response to TfL comments, prepared by Steer

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Appendix 8: Pre-development enquiry letter from Thames Water (dated 15
November 2021)

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Appendix 9: List of submitted drawings for substitution

Drawing title Drawing number Previous Superseded

rev. no. rev. no.
General Arrangement Plans Level 00 AIL-BMA-P2-00-PL-A-90300 P11 P12
General Arrangement Plans Level 01 AIL-BMA-P2-01-PL-A-90301 P11 P12
General Arrangement Plans Level 02 AIL-BMA-P2-02-PL-A-90302 P12 P13
General Arrangement Plans Level 05 AIL-BMA-P2-05-PL-A-90310 P1 P2
General Arrangement Plans Level 06 AIL-BMA-P2-06-PL-A-90311 P1 P2
General Arrangement Plans Level 07 AIL-BMA-P2-07-PL-A-90312 P1 P2
General Arrangement Plans Level 08 AIL-BMA-P2-08-PL-A-90303 P9 P10
General Arrangement Plans Level 09 AIL-BMA-P2-09-PL-A-90304 P9 P10
General Arrangement Plans Level 10 AIL-BMA-P2-10-PL-A-90305 P9 P10
General Arrangement Plans Level 22 AIL-BMA-P2-22-PL-A-90307 P9 P10
General Arrangement Plans Level B01 - Basement AIL-BMA-P2-BS-PL-A-90399 P8 P9
General Arrangement Plans Level 23 - Roof AIL-BMA-P2-RF-PL-A-90309 P8 P9
General Arrangement Plans Levels 11 to 21 AIL-BMA-P2-XX-PL-A-90306 P10 P11
General Arrangement Plans Levels 03 and 4 AIL-BMA-P2-XX-PL-A-90308 P1 P2
Site Elevation 05 West Site Elevation AIL-BMA-P2-XX-EL-A-90505 P4 P5

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