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PETER STEWART CONSULTANCY HERTSMERE HOUSE E14

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Position Statement of Peter Stewart MA (Cantab) Dip Arch RIBA MD DPD policy DM26 Building heights


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CONTENTS 1 Introduction and scope 3 Policy and guidance 4 Policy DM26 of LBTH’s Managing Development DPD (Submission version, May 2012)

and its evidence base 5 The Hertsmere House site and its setting 6 Consideration and conclusion Appendix A Peter Stewart CV Appendix B Hertsmere House site: townscape and heritage context Appendix C Canary Wharf cluster: diagrams showing massing of existing and consented

buildings ( NB: Appendix C is in a separate document at A3 size )


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1 INTRODUCTION AND SCOPE 1.1 My name is Peter Stewart. I am a chartered architect and principal of Peter Stewart

Consultancy, which provides advice on urban design, townscape, visual impact, and built heritage. The practice has advised on many major projects in Tower Hamlets. I am a former Director of Design Review at CABE. Further CV details are included at Appendix A.

1.2 This position statement has been prepared for the Examination in Public (EiP) into the Managing Development - Development Plan Document (Submission Version May 2012) (‘MD DPD’) of the London Borough of Tower Hamlets (LBTH).

1.3 This position statement is submitted on behalf on behalf of Commercial Estates Group

(CEG) in respect of land at Hertsmere House, E14. This position statement should be read with other statements submitted on behalf CEG.

1.4 The MD DPD sets out policies for the heights of new buildings in LBTH (DM26, MD DPD p70-73), The Hertsmere House site is located in a zone identified as suitable for an ‘indicative building height’ of 150m. There is an extant planning permission for a building on the Hertsmere House site, known as the Columbus Tower, which would be about 242m high.

1.5 The Inspector has requested that representations address a number of questions. These

are set out below in italics, with answers following each.

1.6 What particular part of the document is unsound? Policy DM26 paragraph 1 and paragraph 2b (MD DPD p70), and Figure 9 (same page) are unsound.

1.7 Which soundness test does it fail? The policy is not justified. The policy is not consistent with national policy.

1.8 Why does it fail?

The failures are explained in the evidence that follows which comprises: • A summary account of relevant national, London and local policy. • A summary account of policy DM26 and the evidence on which it is said to be based.


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• An account of the Hertsmere House site and the existing consent for the Columbus Tower project.

• Consideration of the effect of policy DM26 on the Hertsmere House site. • An explanation of how policy DM26 fails the tests of soundness and consistency in

respect of its application to the Hertsmere House site.

1.9 How could the document be made sound? What is the precise change/wording sought? These questions are addressed in section 5 at the end of this statement.


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2 POLICY AND GUIDANCE NPPF

2.1 At paragraph 56, the NPPF states that ‘Good design is a key aspect of sustainable

development, is indivisible from good planning, and should contribute positively to making places better for people.’

2.2 Paragraph 60 states that ‘Planning policies and decisions should not attempt to impose architectural styles or particular tastes and they should not stifle innovation, originality or initiative through unsubstantiated requirements to conform to certain development forms or styles. It is, however, proper to seek to promote or reinforce local distinctiveness.’

CABE / EH guidance on tall buildings

2.3 The CABE / EH ‘Guidance on tall buildings’ (2007) advocates a plan-led approach to the

location of tall buildings.

The London Plan 2011 2.4 London Plan policy 7.7 (London Plan p217-219) concerns the location and design of tall

and large buildings. It advocates a plan-led approach.

London Borough of Tower Hamlets Core Strategy Development Plan Document 2025.

2.5 Objectives SO22 and SO23 of the Core Strategy (p80) relate to the creation of distinct and durable places and set out objectives on design and heritage.

2.6 SP10 (p81-83) is the strategic policy which sets out how LBTH will achieve these design related objectives.

2.7 Parts 5 of SP10 relates to tall buildings and states:

‘5. The following locations are where tall buildings will be acceptable: Canary Wharf Aldgate


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a. The above locations are identified as they meet the following criteria: i. Be part of an existing economic cluster and respond to existing built character of the area. ii. Have a large floor-plate office building typology. iii. Be in areas of high accessibility. b. Appropriate sites for tall buildings will be identified within the Sites and Placemaking DPD. All tall buildings including those outside of the above locations will be assessed against criteria set out in the Development Management DPD.’


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3 POLICY DM26 OF LBTH’s MANAGING DEVELOPMENT DPD (SUBMISSION VERSION, MAY 2012) (MD1) AND ITS EVIDENCE BASE

3.1 Policy DM26 (p70) concerns building heights. Part 1 of the policy DM26 states that:

Outside of those areas identified in the Core Strategy as acceptable for tall buildings, building heights will be considered in accordance with the town centre hierarchy (as illustrated in figures 9 and 10) and the criteria stated in part (2).

3.2 Figure 9 (p70) defines ‘maximum height (Above Ordnance Datum)’ as up to 240m for Preferred Office Locations and up to 150m for ‘Central Activity Zone, Activity Areas and Major Centre (and respondent to context elsewhere). Figure 9 appears to cover the whole borough, not just those areas outside the areas stated in Core Strategy paragraph SP10 to be acceptable for tall buildings (Canary Wharf and Aldgate), because it refers to Preferred Office Locations (which are in Canary Wharf and Aldgate). (Figure 10 appears later in the document in another section (p84) and does not seem to be relevant.)

3.3 The POL for Canary Wharf is defined on p139 of the MD DPD. It excludes the Hertsmere

House site (the boundary of the POL adjoins the boundary of the Hertsmere House site).

3.4 Part 2 of policy DM26 sets out more detailed criteria. Paragraph 2b states ‘Within the Tower Hamlets Activity Area development will need to provide a transition between taller buildings in Aldgate and Canary Wharf Preferred Office Locations and the lower heights of the surrounding areas.’

3.5 The following documents are stated to be the ‘key evidence base’ for policy DM26: LBTH Building Heights Note (2011) LBTH Conservation Strategy (2010) LBTH Town Centre Spatial Strategy Spatial Baseline (2009) LBTH Urban Structure and Characterisation Study (2009)

LBTH ‘Building heights note’ Version 2, April 2012 (EB35)

3.6 The original version of this document dated December 2011 (EB34) has been replaced by a second version, ‘Version 2’, dated April 2012 (although the MD DPD (p73) refers to the 2011 version). My evidence discusses version 2. The ‘Building heights note’ explains the methodology that underlies policy DM26(1). The rationale can be summarised as follows:


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3.7 One Canada Square is the tallest building in LBTH (245m AOD); it has iconic status; other existing and permitted buildings are lower, so One Canada Square sets the benchmark; 240m is the maximum height ‘likely to be acceptable’ in a POL, in the absence of guidance to the contrary.

3.8 In the ‘Central Activity Zone, Activity Areas and the Major Centre’, the ‘height of buildings

should correspond to the town centre hierarchy while responding to local context and heritage assets’. Analysis of building heights in the Marsh Wall East area is said to have led to a height of 150m AOD as being ‘the most appropriate indicative building height (subject to the criteria stated in policy DM26(2)).’

3.9 The Building Heights note gives a list of heights of existing and consented tall building projects in Canary Wharf.

3.10 The list includes the Columbus Tower project at 242m and the City Pride project at 215m – both outside the POL, one to its north and one to its south.

3.11 The Hertsmere House site, according to the DPD, is in a zone where the 150m indicative height applies. LBTH Conservation Strategy (2010) (EB37) LBTH Town Centre Spatial Strategy Spatial Baseline (2009) (EB71)

3.12 These documents do not contain anything directly relevant to the question of tall buildings

and building heights beyond what would be found in national policy and guidance on conservation and urban design.

LBTH Urban Structure and Characterisation Study (2009) (EB73)

3.13 This document includes the following recommendations:

Rec 13 Promote an integrated, coherent approach to building heights and density, responding to proximity of centres.

Rec 33 Direct building heights to increase gradually from the edge to the centre of a neighbourhood. The scale of the increase will differ from place to place. It might mean three storeys increasing to seven in one centre, and be higher or lower than this in another.


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4 THE HERTSMERE HOUSE SITE AND ITS SETTING 4.1 The Hertsmere House site (‘the Site’) is located in the Isle of Dogs, at the west end of

West India Dock North. 4.2 The existing townscape in the area around the Site is dominated by the cluster of tall

buildings and medium scale commercial development associated with Canary Wharf, south-east of the Site.

4.3 The most notable individual characteristic of the Site itself is its dramatic location at the

end of a linear dock which is about 800m long (see Figure 1 below). In townscape terms this location is very particular because of the views afforded along the length of the dock. The visual interest of the location is enhanced by the presence of the adjacent Grade 1 listed warehouses. These contain bars, restaurant and shops at ground floor level, which with the adjacent London Marriott Hotel West India Quay to the east of the warehouses make this an area with a strong relationship with Canary Wharf.

4.4 A new Crossrail station is under construction in the dock. When complete this can be expected to shift the centre of gravity of the Isle of Dogs northwards, making West India Dock North a still more significant location. Further major development such as the consented scheme at North Quay, east of the Marriott hotel, will contribute further to this shift.

The Columbus Tower project

4.5 The consented project for the Site proposes a mixed use tower, 242m tall. It presents a slender aspect to the east-west direction and a wider aspect when seen from the north and south.

4.6 The curved form and profiled top of the proposed building mark it out from the typically more regular forms of tall buildings found in the main Canary Wharf cluster, as is appropriate to its particular location – see Figures C1 and C2 in Appendix C.

4.7 The design of the tower responds to the character of its setting as set out above – in particular, to its special location at the end of a dock.

4.8 The first version of the project was granted detailed planning consent by the London Borough of Tower Hamlets. A subsequent, very similar version was granted detailed planning consent by the Mayor of London in 2009 after recovery of the planning application – this recovery demonstrating the London-wide significance of the Site.


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CABE and English Heritage were consulted about the planning application and did not raise objections to the height of building proposed. Heritage sensitivity of the Site

4.9 The Site is partly in a Conservation Area, and it adjoins a Grade 1 listed building,– see figures 1 and 2 over. It also lies in the backdrop of a protected LVMF view from Greenwich Park.

4.10 Peter Stewart Consultancy prepared the townscape and visual impact assessment

(TVIA) for the Columbus Tower project which was granted planning consent in 2009. This assessment considered the site’s heritage sensitivity in detail. Its impact on its setting, including nearby listed buildings and conservation areas, was assessed in the Environmental Statement for the project and there were no unacceptable adverse impacts. A summary account of these aspects is given in Appendix B.


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Fig. 1 Hertsmere House site (red) and nearby conservation areas (green)

Fig. 2 Hertsmere House site (red) and nearby listed buildings and structures (as indicated in key)


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5 CONSIDERATION AND CONCLUSION Consideration

5.1 There is no good reason to apply a height limit to the Site. I am not aware of any evidence that LBTH have provided that would lead to the conclusion that a height limit is desirable, let alone necessary. The policy is not based on evidence and is therefore unsound.

5.2 The CABE/EH Guidance on tall buildings, and urban design guidance generally, suggest

that a site-specific response based on an understanding of a site and its setting should inform the form of a building, including its height.

5.3 The 240m limit for the POL in LBTH’s Building Heights Note Version 2, roughly the height of the tallest existing and consented buildings, derives mainly from aviation considerations in respect of London City Airport (which have determined the heights of existing buildings and consents to which the note refers), and so this figure is not arbitrary.

5.4 The 150m figure, which DM26 applies to the Site, is clearly arbitrary (as would be any figure below 240m if applied generally, as is proposed, rather than based on site-specific assessment). The diagram that accompanied the explanation of how the figure was arrived at, which appeared in version 1 of the note, was based on a particular cross section of townscape at Marsh Wall East on the opposite side of the Canary Wharf cluster from the Site, an area that has very little in common with the area around the Site.

5.5 The distinction between a greater indicative height in the POL and lower level outside

means that the MD DPD has the effect of relating building height to directly land use – i.e. the tallest buildings are to be office buildings. This is arbitrary and even perverse. It would run the risk of strengthening the monocultural tendencies of the Canary Wharf cluster, when it would be preferable for these to be dissipated.

5.6 General height restrictions across a large borough cannot be site specific or place-

specific. A blanket height limit across a borough would be a crude ‘one size fits all’ approach, entirely unsuited to London’s complex cityscape, with its layers of history and particular character which varies greatly from place to place, often within the space of a street or two. Protecting heritage assets and sensitive environments from harm is an important aspect of planning, but blanket prescriptions obviously cannot achieve this as they are not context-specific.

5.7 By contrast, the consent for the Columbus Tower on the Site is a sophisticated place-

specific response, in relation to immediate and wider setting.


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5.8 Specifically, the consent demonstrates that a 242m tall building does not harm the

heritage significance of the adjacent Conservation Area or Grade 1 listed buildings or other nearby heritage assets, details of which are given in Appendix B.

5.9 As well as its heritage context, the Hertsmere House site is particular in other ways. Its location at the end of a dock is dramatic. This dock is set to increase in significance with the arrival of the Crossrail station.

5.10 A number of established planning consents for projects outside the POL exceed the 150m figure – not least the Columbus Tower consent (242m), but also the consent for the City Pride site to the south-west of the main cluster. There is no evidence that these proposed buildings are in any sense ‘too tall’ – nor is this suggested in LBTH’s Building heights note, which refers to both of these consents as part of its evidence base.

5.11 Once the principle of a tall building on the Hertsmere House site had been established, there was no suggestion (let alone evidence) during the process that led to the planning consent that a lower building (e.g. 150m rather than 242m) would in any sense be preferable for the site. Rather, the result would still have been a prominent tall building next to some much lower older buildings, but one that was less slender and elegant, less suitable for its dramatic location, less attractive commercially and less likely to be built.

5.12 The Site is also particular, by comparison with sites along Marsh Wall to the south of the

main cluster, for example, because a tall building here will form the north-west corner of the group of tall buildings for the foreseeable future; there is little prospect of any other tall building north or west of the site that would form part of the Canary Wharf cluster.

5.13 In the zone north-west of the POL in which the Hertsmere House site lies, outside the POL and inside the Activity Area, the Hertsmere House site is the only development site – all the rest of the land in this area is either occupied by listed buildings or by recently redeveloped buildings.

5.14 Applied to the Site, a 150m height restriction would not produce a legible hierarchy of different places with buildings of different scales – a tall building on the Site (such as the proposed Columbus Tower) would clearly be read as part of the Canary Wharf cluster (see figures C1 and C2 in Appendix C). Furthermore it would not reflect the particular importance of the location at the end of the dock – an example of the importance of site-specific consideration.


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Why does policy DM26 fail the soundness test?

5.15 The first version of the ‘Building heights note’ referred to a maximum height of 150m in the CAZ; version 2 of the same note refers to 150m as the ‘most appropriate indicative building height’. The title of Figure 9 of the DPD refers to ‘indicative building heights’, but the table itself refers to ‘maximum height’. It is unclear in the text, therefore as to whether 150m is an indicative figure or a maximum. LBTH have made clear in their Statement of Common Ground with CEG that it is indicative (discussed further below). But there is no good reason to apply even an indicative figure to the Hertsmere House site.

5.16 Paragraph 60 of the NPPF says that planning policies should not stifle initiative through ‘unsubstantiated requirements to conform to certain development forms’. That would be the effect of a height restriction of 150m applied to the Site, which is based on aesthetic preference rather than anything more substantial.

5.17 DM26 as drafted is therefore not consistent with national policy. Such a limit would be an unnecessary and undesirable restraint on development.

5.18 There is no evidence that any harm would result from a building on the Site taller than the 150m indicative limit proposed.

5.19 By contrast, there is evidence – in the form of the existing consent – that a building of 242m high has been found acceptable on this site – after intensive scrutiny. As noted above, the Columbus Tower is listed in LBTH’s evidence base (Building heights note) without any suggestion that the consented height is not acceptable.

5.20 Good design – a key aspect of sustainable development (NPPF paragraph 56) is site specific, as national guidance such as By Design: Urban Design in the Planning System - Towards Better Practice (DCLG, 2000) tells us. Good design is not fostered by unsubstantiated requirements to conform to certain development forms.

5.21 Paragraph 152 of the NPPF states that ‘Local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Significant adverse impacts on any of these dimensions should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued.’ There is no evidence that limiting the height of development at the Site to 150m would avoid any adverse environmental impacts.

5.22 Paragraph 182 of the NPPF states that ‘the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence’.


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It has been demonstrated above that the indicative height limit as applied to the Site, as an aspect of the plan, does not pass this test.

5.23 DM26 as drafted is not justified by any evidence, in respect of its effect on development of the Hertsmere House site. The policy clearly could have an adverse economic impact. So to comply with the NPPF, an alternative option should be pursued that does not impose a limit. This is set out at the end of this section.

Comments on LBTH position in Statement of Common Ground

5.24 LBTH’s position in the Statement of Common Ground (between CEG and LBTH), in relation to DM26, is that Figure 9 is indicative, that buildings exceeding the indicative height figure are not precluded, and that more detailed guidance may be provided, as allowed for in Figure 9. This is in effect an acknowledgement that the policy is too general in its application to be sound in relation to the particular circumstances considered in my evidence – which, as I have stated, require place-specific design.

5.25 LBTH state that Figure 9 is provided ‘to balance the requirement of statutory stakeholders such as English Heritage as well as developers, landowners and residents’. This implies (presumably) that there is evidence that some of these parties have expressed a preference for a height limit, but I am not aware of any evidence that this is the case; and as stated above, English Heritage have not opposed a 242m high building on the Site.

How could the document be made sound? What is the precise change/wording sought?

5.26 The above defects could be rectified by the following:

• Amend DM26 para 1 to read ‘Outside of those areas identified in the Core Strategy as

acceptable for tall buildings, building heights will be considered in accordance with the criteria stated in part (2).’

• Omit Figure 9 • Omit DM26 paragraph 2b.

Peter Stewart Peter Stewart Consultancy 70 Cowcross Street, London EC1M 6EJ September 2012


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APPENDIX A PETER STEWART: QUALIFICATIONS AND EXPERIENCE

1. My name is Peter Stewart. I am a registered architect and I practise as an independent

expert adviser in architectural and planning matters. 2. I have a degree in architecture from the University of Cambridge and a postgraduate

diploma in architecture from the Polytechnic of Central London (now the University of Westminster). I am a member of the Royal Institute of British Architects. Between 1982 and 1996 I was employed in a number of architectural practices in London and was involved in the design and construction of substantial commercial and residential projects in central and inner London and elsewhere, many of which were on sensitive sites.

3. In 1997 I was appointed Deputy Secretary of the Royal Fine Art Commission (RFAC),

which was a non-statutory consultee in the planning process. In 1999 the RFAC was wound up by the Government and I joined the staff of the replacement body, the Commission for Architecture and the Built Environment (CABE). Until 2005 I was Director of CABE's design review programme, which offers expert advice on major development proposals. CABE (now Design Council CABE) is a non-statutory consultee for significant projects in England.

4. My work at CABE involved me in advising on a wide range of projects, including many of the most significant projects in England during my time there, and these included many where local authorities sought advice on proposals for tall buildings. My responsibilities included preparing CABE's case for a number of planning inquiries where this subject was central to the issues considered, including the public inquiries into the Heron Tower in the City of London and the ‘Shard’ tower in London Bridge.

5. I am the principal author of a number of CABE publications, including Design Review,

which sets out CABE's method for assessing projects, and of the original version of the joint CABE / EH Guidance on Tall Buildings.

6. In 2005 I founded a specialist consultancy advising on architecture, urban design and

planning. The consultancy offers both strategic and project-related advice to private and public sector clients.

7. The consultancy's clients have included, in the public sector, English Heritage, CABE, the London Development Agency, the East Midlands Development Agency, the London Thames Gateway Development Corporation, the Tate Gallery, and the Home Office; and in the private sector, British Land, Chelsfield Partners, Derwent London, Hammerson, Land Securities, London and Regional Properties, Qatari Diar, Stanhope plc, and Stratford City Developments Ltd.


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8. In my role as a consultant, I have given evidence on architecture, townscape and

conservation matters as an expert witness at a number of planning inquiries since 2005. 9. I have in the past fifteen years served in the following capacities, in each case providing

independent expert advice to planning authorities about the effect of major new development on sensitive contexts: • Chair of the regional design review panel for the East Midlands; • member of the London Advisory Committee of English Heritage; • member of the design review panel for the Stratford City development in east London,

which includes the Olympic Village; • member of the design review panel for the Convoys Wharf project in Deptford, in

south east London.

I have also served as the Chair of a conservation area advisory committee in the London Borough of Hackney.

10. I have contributed essays and articles to the architectural and planning press, on a broad

range of matters relating to my work at CABE and subsequently. I have spoken on the subject of tall buildings at events held by the RTPI and by the London Region of English Heritage. I have prepared and delivered training in architecture and urban design for Urban Design London, and for council officers and planning committee members at a number of local authorities; and I have facilitated training sessions for several of the English regional design review panels. I have also contributed to training sessions for the Planning Inspectorate.


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APPENDIX B HERTSMERE HOUSE SITE: TOWNSCAPE AND HERITAGE CONTEXT

1. The Hertsmere House site (‘the Site’) is located in the Isle of Dogs, at the west end of an

800m long dock, West India Dock North, and to the north-west of the Canary Wharf estate Hertsmere Road lies to the west of the Site, with North Quay located to the north and 17 Columbus Courtyard to the south and to the east.

2. The principal road serving the site is Hertsmere Road, which feeds off Westferry Road

and the roundabout at Westferry Circus to the south-west (A1206). The DLR station at West India Quay lies directly east of the Site, and the DLR and Tube stations at Canary Wharf to the south-east.

3. Peter Stewart Consultancy prepared the townscape and visual impact assessment (TVIA) for the Columbus Tower project, proposed for the Hertsmere House site, which was granted planning consent in 2009. The account that follows is based on material in that report.

Historical development of the area

4. The Isle of Dogs was a largely undeveloped area, with few buildings other than windmills along its western edge, until the beginning of the nineteenth century.

5. Major change in the peninsula arrived with the development of the West India Docks which followed the passage of a Parliamentary Act permitting the development in 1799. The West India Import Dock was opened in 1802, with the Export Dock to its south following in 1806.

6. The docks consisted of two parallel basins, each half a mile long (circa 800m); a 500 foot (c. 152 m) wide Import Dock and a 400 foot (c. 122 m) wide Export Dock beside it. A depth of 31 feet (9.44 m) was provided. The docks are seen as important in the creation of the modern Port of London as well as setting a precedent for commercial dock design.

7. A warehouse was built on the Site sometime between the opening of the docks and 1868.

8. The London Docklands Development Corporation (LDDC) was created in 1981 to oversee the regeneration of the Docklands, which had declined since the Second World War. In 1982, an Enterprise Zone was designated around the Docks on the Isle of Dogs. Its designation granted developers tax and planning concessions in an effort to encourage redevelopment.


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9. Originally the Enterprise Zone spawned the building of fairly small scale commercial

buildings, of which the present building on the Site, completed in 1987 is an example. By 1985 the more ambitious planning of the Canary Wharf Estate was underway. This took the grid suggested by the linear docks as the starting point for a formal masterplan, centred around a focal tall building at One Canada Square.

10. The construction of the 50 storey One Canada Square, completed in 1991, marked a step change in the scale of redevelopment in the Docklands. By 2002, the tall buildings to the west of One Canada Square, the HSBC and Citigroup towers, were also complete. Large scale development has since moved south to occupy sites and Heron Quay, South Quay and Millwall Docks.

11. The resulting townscape and urban grain in the wider area around the Site is varied and

rapidly changing. There are areas of relatively coherent development, and areas with a mix of buildings that vary considerably in type, form and scale. Like much of the Docklands, only fragments now remain of elements of the built environment which pre-date the Second World War. Conservation areas, listed buildings and locally listed buildings in the wider vicinity of the Site are discussed below.

12. The built environment near the Site suffered heavy bombing damage during World War II and has been extensively redeveloped over the last 25 years. Little remains in the wider area of the pre-war building stock, other than the docks themselves and former dock-related buildings, including original warehouses and occasional individual houses, workshops and office buildings or public houses. The townscape is, therefore, predominantly modern and varied in character, but it includes significant historic buildings and structures, some of them close to the Site – these are discussed further below. Townscape character of area surrounding the Site

13. The most notable feature of the townscape of this part of the Isle of Dogs is the significant cluster of tall office buildings around One Canada Square, including the Citigroup and HSBC Buildings, the Heron Quays developments and the Barclays Building at One Churchill Place. More recently, significant residential development at a large scale has taken place south of the cluster of office buildings, including the Pan Peninsula towers, and this is set to continue.

14. There are a number of other proposals with extant planning consents, and if these additional schemes are realised there will be a significant increase in the extent of the Canary Wharf cluster. Further office and in some cases mixed use development at a


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very large scale has been granted planning consent at North Quay, Canary Riverside, Heron Quays and Wood Wharf.

15. Directly to the south of the Site there are the 10 storey commercial office buildings surrounding Columbus Courtyard while to the south- east this scale rises to the 20 storey commercial office buildings which surround Founders Court.

16. To the west the bulk drops dramatically to the single and double storey scale of the Grade II listed Cannon Workshops and a number of associated ancillary buildings. To the north the scale of the adjoining Grade I listed warehouses, designed by the Gwilts in the early 19th century, steps up incrementally from 1 and 2 storeys at the western end to 4 and 5 storeys in the middle and 5 and 6 storeys at the eastern end.

17. To the east of the warehouses, the 32 storey West India Quay Tower has a curved glazed frontage, with a lower terracotta clad podium set to the west to relate to the scale and form of the historic warehouses. East of this, north of the dock and beyond the DLR line which runs south to Canary Wharf, planning consent has been granted for the North Quay project which includes buildings of up to 220m tall.

18. The predominant urban grain of the site and surrounding context is characterised by a regular grid. This is an extension of the historical context of the docklands area and associated infrastructure such as the docks, quaysides and warehouse buildings, which in turn was a major determinant of the Beaux Arts planning principles applied in the master-planning of the Canary Wharf Estate.

19. The Cannon Workshops and warehouses relate to this regularity in the urban grain. However, there is also a more incidental condition to the north- west, which was originally created by the former moat or ditch that once served as a security barrier between the quay sides and the surrounding area. Maritime Greenwich World Heritage Site

20. Tall buildings on the Isle of Dogs are visible from the Maritime Greenwich World Heritage Site (‘WHS’), and impact on the ‘Outstanding Universal Value’ of the World Heritage Site is a consideration in terms of any further proposed tall buildings in the area, including the Site.

21. The panoramic view from the statue of General Wolfe, within the WHS is one of the strategic views identified in the LVMF (Assessment Point 5A.1). This panoramic view encompasses, in the foreground, an axial view of Greenwich Royal Naval Hospital and the Queen’s House. The position of the cluster of towers at Canary Wharf in the


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background was displaced from the main axis in order not to detract from the view of the historic buildings. This grouping provides a separate focus of interest, supplemented in recent years by further high buildings at Heron Quays and Pan Peninsula.

22. The Mayor of London’s London View Management SPG (2012) states of this view that ‘The composition of the view would benefit from further, incremental consolidation of the clusters of taller buildings on the Isle of Dogs and the City of London. However any consolidation of clustering of taller buildings on the Isle of Dogs needs to consider how the significance of the axis view from the Royal Observatory towards Queen Mary’s House could be appreciated.’

Conservation areas

23. A small section of the northern part of the Site lies within the West India Dock Conservation Area. The majority of the Site lies outside the Conservation Area. There is no obvious reason for the exact location of the line of the Conservation Area designation, which cuts across the existing building on the Site which is of no architectural or historic interest.

24. The West India Dock Conservation Area covers the north-west corner of the former West India Docks. The historic warehouses along North Quay and other historic buildings around the main dock entrance are the focus of this area, and many of these buildings are listed (see below).

25. The Conservation Area was designated in November 1982, and a Character Appraisal and Management Guidelines document was issued in February 2007. This document identifies the character and interest of the area as deriving from the significant concentration of historic buildings associated with the enclosed docks. It notes that the Site is ‘identified as a development site.’

26. The document also identifies a number of important views of and from the Conservation Area, including across the West India Dock, towards the warehouse buildings at the north-west of the dock; views in and out of the former Cannon Workshops; and views across the rear garden of the Dockmaster’s House towards Greig House (the latter view is looking in the opposite direction from the Site).

27. There are a number of other Conservation Areas in the wider area: Narrow Street Conservation Area; St Matthias Church Poplar Conservation Area; All Saints Conservation Area; St Anne’s Church Conservation Area; Lansbury Conservation Area. The tall buildings of the Isle of Dogs are visible from all of these conservation areas, and


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the effect of the Columbus Tower project on each of these Conservation Areas was considered as part of the Environmental Statement for that project. Listed buildings

28. There are a number of listed buildings in close proximity to the Site, most of them falling within the West India Dock Conservation Area. West India Dock Wall

29. The walls of the West India Import Dock, immediately to the east of the Site, are Grade I listed. The dock walls are not seen readily, due to the presence of false quay structures that extend out into the dock. North Quay warehouses

30. The warehouse and general offices at the western end of North Quay, which lie immediately to the north of the Site, are Grade I listed. They are the remaining part of a series of nine Georgian warehouses, most of them of five storeys, designed and built by George Gwilt and his son. The others were destroyed by bombing during World War II.

31. The historic warehouses are robust brick structures which hold their own visually in an area dominated by modern development. They have been converted to provide café/bars at ground floor with spill out terraces and one of the buildings has been converted to a local history museum. Cannon Workshops

32. The Cannon Workshops are situated directly to the west of the Site, on the opposite side of Hertsmere Road. They are listed at Grade II. The buildings were constructed in 1824-5 to designs by Sir John Rennie. This quadrangle of single storey buildings originally had a cooperage at its centre. The buildings became the Port of London’s Central Stores Depot in 1923, before being converted into small business units in the early 1980s.


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Other listed buildings within the West India Dock Conservation Area

33. Other listed structures and buildings within West India Dock Conservation Area include the West India Dock Former Guard House, the Entrance Gates to West India Docks, the Former Excise Office, the Railings and Gatepiers to the Former Excise Office, the Railings to the West of the Main Gate at West India Dock and the constable's cottages on Garford Street. These are all Grade II listed. Other listed buildings

34. Other listed buildings in the area include Church of St Anne’s, Limehouse, The Church of

St Matthias, and terraced buildings in Narrow Street.

35. The effect of the Columbus Tower project on each of these listed buildings was considered as part of the Environmental Statement for that project.

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