Written evidence submitted by Councillor Andrew Wood [FPS 137]



I am the Councillor for Canary Wharf ward in Tower Hamlets, east London, it has the highest and densest new build residential developments in western Europe, so we have a rather unique perspective on planning. We do not have a problem in delivering lots of new homes, we deliver more than our fair share but the problems we have are indicative of other issues with the existing and proposed new planning system.


My ward occupies about 40% of the Isle of Dogs and South Poplar area which is the single most important small growth area in the United Kingdom in terms of housing and jobs. For example, the GLA has a Maximum growth forecast for an additional 49,000 homes + 110,000 jobs in this small area.


I also helped found the Isle of Dogs Neighbourhood Planning forum, the largest in the country based on population size, circa 40,000 people. Our 2nd attempt at a Neighbourhood Plan goes to referendum next May 2021.


The Isle of Dogs and South Poplar area is likely to be tasked to deliver 1.04% of the governments new housing targets in an area you can walk across in thirty minutes and therefore merits special consideration. That % is likely to increase given political complaints elsewhere in England and an unwillingness to confront the green belt. Tower Hamlets Council does not complain about its targets unlike some others.


But it has had more development than any other part of the UK and Tower Hamlets has been the fastest growing local authority for at least the last twenty years and is the number one recipient of New Homes Bonus in the country every year, £189 million since 2011. Canary Wharf itself until COVID struck was also the most important deliverer of new office space in the country.


In 2021 in my ward, the 75 storey Landmark Pinnacle (239 meters tall with 984 apartments), the 68 & 56 storey South Quay Plaza (1,284 apartments), the 60 storey Newfoundland (575 apartments) and the 55 & 50 storey Wardian (756 apartments) will all complete construction within ten minutes’ walk of each other along Marsh Wall road, while walking between them you can admire the 63 storey Consort Place (634 apartments + hotel) under construction plus four short 42-44 storeys towers going up at Millharbour Village (1,513 apartments). You can see them from many parts of London. But for some odd reason, awareness of the scale of that development here is low nationally except for Westferry Printworks (1,524 apartments) also in my ward due to the scandal it caused.


But buildings of this height and density are in part because of the green belt forcing development upwards because London cannot grow outwards. But that density brings different problems especially related to affordability, quality and infrastructure.


These buildings are very complex mechanisms, some break often, are poorly managed, expensive to purchase, expensive to service and expensive to live in due to monopoly situations. They are too often not fit for purpose as homes but do have amazing views.


Working from Home will impact office demand at Canary Wharf so it is likely that demand for new build residential will decline for the next few years although the history of the Isle of Dogs suggests that development will return in a few years.


My other fundamental concern is that no planning system designed to cover England can effectively cover an area whose peers are not Whitstable or even Manchester but Manhattan, Hong Kong, Pudong and Dubai. And the rural focus in the consultation does not reflect the fact that many of the new homes in England will be in urban areas. So, the new planning system has to retain some flexibility to allow these very different areas to respond to local and unique issues.


If you are interested, we can offer you a very interesting tour of this area, including tea and biscuits in the tallest hotel in London. We are only 17 minutes from Westminster by Jubilee line.


  1. Is the current planning system working as it should do? What changes might need to be made? Are the Government’s proposals the right approach?


No, I do not believe the current system works. My area is clearly delivering the new homes we need in England but they are not affordable to normal people with normal jobs and we lack the infrastructure to support it (oddly despite generating huge amounts of s106 cash, CIL (£77 million in my ward alone), New Homes Bonus (£189 million so far) and in fact the local authority are closing existing facilities (the 116 year old local library) or not investing in a local 54 year old leisure center which may never re-open. So, we are losing infrastructure rather than seeing it increase in proportion to the population growth.


It is the gap between those new homes and the supporting social infrastructure which is the greatest failure of the current system. They need to be planned together at the same time and the Local Plan needs to also be an Infrastructure Plan whereas often it is an afterthought or a separate process. We need some mechanism to look at wider social infrastructure needs at the same as planning applications are submitted, which our local Neighbourhood Plan tries to achieve through an Infrastructure Impact Assessment. It uses widely available criteria about the recommended number of for examples Doctors per head of population or swimming pool capacity again per head of population. It then applies those ratios to new developments and if there is a gap in capacity it expects that the developer will offer one or more of those categories of infrastructure to help fill gaps. If all developments did that then across an area you will have the right mix of supporting infrastructure whether schools, community centres, sports halls, swimming pools, playgrounds, etc.


In many areas local authorities do not own enough public land on which to deliver new social infrastructure, we need new developments to help deliver them.


So, I support changing the current system but am not convinced either that it will deliver much actual change nor increase build rates nor solve the infrastructure problem I outline.


The cladding scandal shows that the quality of new build is also deeply suspect. We have endemic problems with many tall buildings which I detail below.


We also have a problem with the planning system in Tower Hamlets whereby Council officers make the decision whether to approve or reject an application. They then present a report as to why Councillors should approve or reject a scheme with all of the evidence marshalled to support their view. They do not present a neutral report with pros and cons of a scheme allowing Councillors to weigh up the evidence and to make the final decision. This maybe because too many of those Councillors are clearly not prepared for meetings, have not read the reports nor understand the policies, do not know the area and look to others for guidance and therefore cannot be trusted to make decisions without clear guidance.


Ironically and in retrospect the London Docklands Development Corporation, a government quango did a better job than the democratic Tower Hamlets Council has done in recent years. So, it is not always true that democratic control of the planning system produces better outcomes although some other local authorities have done a very good job like Barking and Dagenham.


Homes of Multiple occupation are a big problem locally as result in the loss of family homes and income for the local authority. For example, within 10 minutes’ walk of where I live a single person (not trading as an organisation) has bought over 100 family sized homes often adjoining each other, 3 and 4 bed in size and then converted them into bedsits using multiple individual planning applications to make each of them as big as possible. In one area he has joined their back gardens so that students inside can party together. An estate of family homes has become a student hostel. The planning system cannot track properly a large increase in residents which has an impact on utilities and transport. The local authority has greater call on its resources but no extra Council tax. And no extra income from s106, CIL, New Homes Bonus etc. And we also lose families and therefore children from our area. I suspect the new planning system will make that worse.


  1. In seeking to build 300,000 homes a year, is the greatest obstacle the planning system or the subsequent build-out of properties with permission?


The greatest obstacle is the willingness / ability of people and investors to buy new build property and for investors to invest in property in the expectation that they can make a return. In Tower Hamlets much of that demand is from investors, foreign and domestic so demand is driven by external factors like the willingness to invest in the UK, foreign exchange rates, perceived risks in their domestic home territories, taxes and other alternative investment opportunities. Much of the recent investment comes from Asian companies and families.


The typical purchaser might be a dentist in Singapore, raising a mortgage to buy an off-plan property in London, which they intend to rent out as part of a long term investment strategy. For others it maybe building a safe base in a safe jurisdiction.


If that demand is there, then buildings can be completed quickly. In 2015 on a sales tour in Asia, all 330 apartments at Baltimore Wharf where sold at the beginning of the tour in Singapore. Galliard in 2015 also had people queuing overnight to buy at their now almost complete Millharbour development


Much of that sales activity has slowed in recent years, Ballymore just delayed the opening of their sales office for Millharbour Village 1,513 homes but we have an increasing interest in student housing from developers including for a 1,600 bedsit scheme in 3 towers up to 46 storeys in height. Private rented sector apartments and co-living homes (the Collective) are also increasingly important as alternatives as the demand for new build for sale private apartments declines.


Any new system needs to be flexible enough to allow these different types of development. But unless people can afford to buy or rent those homes, they won’t be built so affordability is key. And we need to reduce the price of new build property, both up front but also in service charges.


Build out rates are much less of an issue in urban areas, once you start building a tower you have to finish it as people cannot live in half-built towers. So, a key issue is not how quickly large rural sites can be built out but the initial decision to start building towers in urban areas.


And on the Isle of Dogs the main problem is that in order to prove that development has started in order to retain their 3 year planning application developers demolish often good quality, relatively young 1980’s and 90s built commercial buildings. But then when financial problems hit, the site is then left empty, so we have too many empty sites with extant planning permissions. As an example, some five years ago the most profitable McDonalds restaurant in London next to Canary Wharf was demolished in order to allow construction, which then never started so years later we have a shuttered and hoarded site full of weeds and rubbish and no restaurant generating tax and employment. In other cases, they just build up to the basement level and then stop so for example the best site in the whole of London, the riverside JP Morgan site has been unused and empty for eleven years now.


We therefore need to find a way of avoiding demolition so that developers can prove they started work to keep their extant planning permission. Or else we need to encourage meanwhile use for sites so that productive land is not lost for decades, Canary Wharf Group have done an excellent job in this area by creating temporary parks. None of that is in the new planning system.


  1. How can the planning system ensure that buildings are beautiful and fit for purpose?


It was noticeable in the consultation but also independent presentations by stakeholders to explain how it might work that much of the language about beauty was aimed at rural areas or small towns. I am not sure you can do much in urban areas where the typology is for tall concrete, glass and steel towers.


But buildings fit for purpose I believe has been a major failure of the current planning system. Many of our new local buildings have major issues that compromise their ability to be fit for purpose as safe and secure homes free from worry. Locally we have issues with:


    1. Heating, ventilation, hot water and lift systems breaking down for extended periodsissues with durability, maintenance, specification, spare parts availability etc. – how do we ensure these buildings work mechanically and are properly maintained as a single failure may affect thousands of people. Do you want to live in a 27 storey tower with broken lifts or not have hot water for your morning shower?
    2. Build quality and durability – some new apartments already look old and tired through the use of cheap non-durable materials. I am not sure they will last their design life.
    3. Anti-social behavior – no developer designs place where teenagers can go and hang out, as a result they congregate in places you do not want them to be in. Cannabis smoke smells and interior noise are other problems due to poor ventilation or isolation.
    4. Heat build-up – poorly lagged pipes, large expanses of glass, limited ability to open windows etc often mean heat in summer is a bigger issue then cold is in winter.
    5. Monopoly provision of services – in many buildings residents have no choice over who supplies their hot water and heating or a range of other services not least who manages their block. We are creating large captive monopoly markets containing millions of people. It is too difficult to get control of your own buildings and even if you do some of these contracts are for several decades into the future. Poor or no choice in a market has never had good outcomes. This applies even more to s106 affordable housing where there is even less choice and fewer options.
    6. Service charges & sinking fund – I pay £5,400 a year in service charge for a 2 bedroom apartment 1987 built 10 storeys high with a gym and concierge, normal services for the area. £3,000 of that is sinking funds. Residents own the freehold and manage the estate, so I know that £5,400 is correct and fair. I worry deeply that many people are not building up their own sinking funds or that their service charges will become unaffordable over time. And that assumes the freeholder is not ripping you off.
    7. Management / Leasehold I am sure you are already aware of many of these issues.
    8. Fire safety – in Tower Hamlets 282 buildings have applied to MHCLG for financial help to fix their cladding issues, the highest number in the country. In addition, we have housing association properties plus buildings with other fire safety issues who did not apply to MHCLG and are not in the 282 number. I believe that in total 300 to 400 buildings locally have fire safety issues and that tens of thousands of people must be affected. But cannot be sure that any one person has that complete list of affected buildings except I hope the London Fire Brigade.
    9. Construction – with multi-year construction close to or next to existing residents how you manage the construction process is as important as the planning process, arguably more so for the health and sanity of residents, would you live meters away from the construction of a 68 storey building which takes 4-5 years to build? Some people report suicidal thoughts from construction noise and Tower Hamlets Council has allowed late morning and late evening work with it seems no resistance at all.
    10. Construction safety – construction sites have become safer, but the result has often been to push risk out onto surrounding streets and pavements. A tour of the area can quickly demonstrate this.


We are working locally to better document, illustrate and evidence what I stated above.


  1. What approach should be used to determine the housing need and requirement of a local authority?


My area delivers a disproportionate number of the new homes for both London and Tower Hamlets so our experience of targets set by the Mayor of London maybe useful although my response below may be a better answer to Q2 then Q4. We are providing a strategic supply to allow London to keep growing as other areas are unwilling / unable to meet London’s demand for new homes. But that means a dramatic increase in population well above what the existing infrastructure was sized for.


But we have been delivering those new homes for a generation now and must be the most reliable deliverer of new homes for some decades now as new developments become taller and denser to levels not seen elsewhere in the UK.


Every Mayor of London has allocated the highest or 2nd highest housing targets in London to Tower Hamlets (in competition with our neighbour Newham). The Isle of Dogs and South Poplar area has the following targets.



The governments new housing target would substantially increase even those targets as once again Tower Hamlets has the highest housing targets in England, 6,121 homes a year. 57% of all new housing in Tower Hamlets is allocated to this area in the new Local Plan which implies a target of 52,300 homes over 15 years versus the maximum growth forecast of 49,000 over a longer 22-year period by the GLA.


I do not think that it is possible to build those numbers even if we go up to 75 storeys and densities on average twice that recommended in the old London Plan. The same applies to London as a whole, we have never come close to delivering the 90,000 homes required.


The only way of creating new homes in sufficient numbers would be to go back and look at our history;

I do not believe national targets can deliver that.


We are among the most pro-development Councils in England, with global interest in investing in property here, commercially available land that can be built on, decent but not great transport connections. If you cannot hit those targets in Tower Hamlets then I am not sure we can deliver those targets nationally.


But it should be noted that Tower Hamlets Council is very anti-development for political reasons in some areas with excellent transport connectivity.


  1. What is the best approach to ensure public engagement in the planning system? What role should modern technology and data play in this?


The use of social media and 3D models are key as are Neighbourhood Planning Forums.


I run a Facebook group with over 22,000 members and we debate these issues often even if it is clear that many people locally have consultation fatigue, there are just so many application and plans, it is easy to lack track of what is happening. But it is hard to convert Local Plan and planning application content into useable information on social media. Planning applications routinely have over 300 separate PDF documents as large files are split into smaller PDF documents. I have thousands of screenshots on my computer as I convert PDF files into a more accessible format. This needs to change.


Most people are only interested in a small number of key issues and numbers e.g. the affordable housing %, number of parking spaces, height, number, play space per child etc, it should be easy to create standard templates containing this information.


3D maps are key because as the saying goes a picture paints a 1,000 words, it allows for an immediate visual understanding of many of the issues related to planning. Location, layout, massing relative heights, sunlight/daylight, wind flow, transport access, design, protected views etc etc


The MHCLG consultation mentions 3D only twice, this is a huge missed opportunity to move dramatically ahead in the use of technology that speeds up processes, reduces costs and makes information much more accessible.


You should have a look at how Singapore uses its 3D model and also have Vu.City give you a presentation as hard to convey in words how transformative 3D models can be to the planning process and public engagement.


Lastly Neighbourhood Planning Forums are an essential bridge to local communities, they bring local knowledge, local contacts, local media and existing social groups into the planning system. They can help disseminate information and help provide engagement in a structured way.


  1. How can the planning system ensure adequate and reasonable protection for areas and buildings of environmental, historical, and architectural importance?


Tower Hamlets has not been very good at this so I can only offer negative examples. Cutting down trees in an estate garden in order to deliver new homes in an area with poor air quality for example.


East London suffered more bomb damage in World War 1 & 2 than anywhere else in the country. But there is no protection for example for historic walls showing shrapnel damage from WW2. Historic England won’t do it, and neither will LB Tower Hamlets, who do not even have a list of affected sites. But that bomb damage is also why we have little historical architecture left. We need to think about how to protect this part of our history not just buildings as a whole.


  1. What changes, if any, are needed to the green belt?


It needs to be reduced in size. It is not a green belt but an anti-growth mechanism. And very few other countries use such crude mechanisms, you have to wonder why.


The result is that growth is being squeezed into relatively small parts of London; Old Oak Common, Stratford, Greenwich Peninsula, Vauxhall, Aldgate, Royal Docks and the Isle of Dogs. All of those developments are generally much denser than the rest of London and the UK.


We are in effect building cities within cities which look very different as is very clear if you look at the New London Architecture 1:2000-scale model of London at Store street.


It also means that you cannot deliver cheap housing because these buildings are not cheap to build nor service. That plus high affordable housing policy requirements 35-50% + high Community Infrastructure Rates £280 per square meter + marketing costs (often overseas) + land values etc etc mean these are not affordable buildings to the average person.


Without major government subsidy or foreign purchasers willing to pay a premium for UK property (which can then be used to subsidise affordable homes) it is difficult to have cheap homes in urban areas. 


Why not allow some development on green belts but in a controlled manner;



  1. What progress has been made since the Committee’s 2018 report on capturing land value and how might the proposals improve outcomes? What further steps might also be needed?


Tower Hamlets probably together with a few other inner London Boroughs has probably done the best to capture land values through CIL and affordable housing % because of global demand for property in this area and the premium people were willing to pay.


It would be interesting perhaps via some database to compare that value capture across different planning applications across England to see how different the values are. For example, the CIL rates per meter, the affordable housing %, the purchase price for 25% of intermediate homes, the rents as a % of market values etc. To then see what emerges. Much of that information different local authorities will already hold.


Please let me know if you have any questions or issues and as reminder, we are close to Parliament and can provide an interesting and useful tour of the area illustrating many of these challenges.



October 2020