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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).

Affordable housing


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.


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.


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)


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”.


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.


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

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