planning report PDU/2797/01 26 July 2011 Gate Gourmet site, Hatton Cross in the London Borough of planning application no. 01380/C/P4

Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008

The proposal Redevelopment of the site to provide a 583-bedroom hotel, associated access, and 131 car parking spaces. The applicant The applicant is Square Circle Developments Ltd., and the architect is Michael Drain Architects.

Strategic issues The principle of the development is broadly supported, however, further work, revisions, and commitments are required with regard to employment, urban design, inclusive access, sustainable development and transport, to address outstanding concerns.

Recommendation That Hounslow Council be advised that, while the application is generally acceptable in strategic planning terms, the application does not comply with the London Plan for the reasons set out in paragraph 63 of this report, however, that the possible remedies set out in paragraph 65 of this report could address these deficiencies.

Context

1 On 17 June 2011 the Mayor of London received documents from Hounslow Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 28 July 2011 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 1B(c) of the Schedule to the Order 2008: “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings… outside Central London and with a total floorspace of more than 15,000 square metres.”

page 1 3 Once Hounslow Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

4 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description

5 The application site is located in Hatton Cross, to the south of the Great South West Road (A30), close to London Airport. The site comprises two development plots. The main plot is 0.9 hectares, and is situated within a gyratory island, bound to the south and west by Faggs Road, to the east by Dick Turpin Way and to the north by the A30. The second plot, is 0.1 hectares, and lies adjacent the main site to the southwest. It is bound by Hatton Road, Faggs Road and Steam Farm Lane. The A30 forms part of the Transport for London Road Network, and the gyratory is also covered by red route restrictions. The site is located within the London Borough of Hounslow, but is on the boundary with the London Borough of . The site is also surrounded by Green Belt to the east, south and west.

6 The main plot is currently occupied by two storey commercial units. The premises have been used as an airline catering facility since the mid 1970s, but have recently been vacated, and the building is now unoccupied. The smaller plot was formerly used as staff car parking associated with operations at the catering facility.

7 A portion of the site falls within a public safety zone (PSZ), an area of designated land close to airport runways, within which development is restricted in order to control the number of people at increased risk of aircraft related hazards. The section of the site that falls within the PSZ is located towards the south, and encompasses approximately one third of the main plot, and all of the smaller plot.

8 Hatton Cross bus and underground station is located immediately to the northeast of the site, on the opposite side of the A30. The underground station is served by the , which provides access to Heathrow terminals and to central London. Hatton Cross bus station is served by nine services (90, 203, 285, 423, 482, 490, H25, H26, X26) which provide access to the Heathrow terminals, and to local areas such as Southall, Hounslow and Feltham. Furthermore, bus stops are located on Faggs Road, adjacent to the site, with the northbound stop served by six routes and the southbound stop served by three routes. The public transport accessibility level of the site is five out of six, where one is poor and six is excellent.

Details of the proposal

9 The proposal comprises the demolition of existing buildings at the site and the erection of a six-storey two-star or above hotel to provide 583 bedrooms. Associated access and car parking for 131 vehicles is also proposed on the main plot, while the smaller plot is identified for use as coach parking. Public realm and landscaping works are also proposed, along with proposed tree planting along the Great South West Road frontage. The later is subject to a separate planning application with Hillingdon Council, and is not referable to the Mayor. Case history

10 On 24 May 2011 a pre-planning application meeting was held with the Greater London Authority to discuss the principle of the above scheme. On 7 June 2011 officers issued a response stating that while the principle of the development was broadly acceptable, further work and

page 2 refinement was required with regard to land use, design, inclusive design, climate change and transport, to ensure the subsequent application would comply with London Plan policy. Strategic planning issues and relevant policies and guidance

11 The relevant issues and corresponding policies are as follows:

 Employment London Plan; PPS4; Industrial Capacity SPG  Tourism/visitor infrastructure London Plan; Good Practice Guide on Planning for Tourism (DCLG)  Opportunity Areas London Plan  Safety and security London Plan; Department for Transport Circular 01/2010  Urban design London Plan; PPS1  Green Belt London Plan; PPG2  Inclusive access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Transport and parking London Plan; the Mayor’s Transport Strategy; PPG13

12 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Hounslow 2003 Unitary Development Plan saved policies and the London Plan 2011.

13 The Hounslow Core Strategy (Issues and Options 2007) and the Hounslow Employment DPD (adopted 2008), are also relevant material considerations. Principle of development

14 London Plan Policy 4.4 seeks a rigorous approach to industrial land management, to ensure a sufficient stock of land and premises to meet the future needs of different types of industrial and related uses. The application site is not identified as a strategic industrial location by the London Plan, nor is it designated as a local employment site within the Council’s local development plan. To a certain extent, however, the site would be protected by the nature of the existing general industrial (B2) use.

15 Whilst GLA officers are content that the loss of B2 employment use on this site does not cause concern at the strategic level, the Council should satisfy itself that the loss of general industrial employment use on this site does not undermine wider employment capacity in the borough. Officers acknowledge that the proposed hotel use would provide various alternative local employment opportunities, and on this basis the applicant is strongly encouraged to provide local employment initiatives as part of these proposals, as promoted by London Plan Policy 4.12.

16 London Plan Policy 4.5 seeks the provision of a further 40,000 net additional hotel bedrooms in the period up to 2031, to support London’s growth and development as a global tourist and business destination. The London Plan states that beyond the Central Activities Zone, capacity for this additional provision should be identified within town centres, and in other locations such as Opportunity Areas, subject to these sites having good public transport access, to central London, and other national and international transport termini.

page 3 17 The application site is located outside Hounslow town centre, but is within the indicative boundary for the wider hinterland of the Heathrow Opportunity Area. Additionally, the Heathrow area is recognised in the West London Sub Regional Development Framework as being a likely location for future hotel provision, driven by the expansion of following the opening of terminal five. It is also noted that the site has a very good public transport accessibility level, is located close to Hatton Cross underground station, and is well served by bus routes providing access to and from the airport.

18 At the request of GLA officers, the applicant has sought to demonstrate how the proposal would fit within the existing context of hotel provision in the vicinity of Heathrow airport. Information has been provided on existing hotel location and capacity, market testing, and current occupancy levels. Consideration has also been given to permitted and proposed hotel development within the Heathrow area. On the basis of the material provided, and in the context of strategic policy, the principle of a hotel use at this site, in close proximity to Hatton Cross underground station, within the indicative boundary on the Heathrow Opportunity Area, is acceptable in accordance with London Plan Policy 4.5.

19 Policy 7.13 of the London Plan seeks to minimise physical risk to new developments. As discussed in paragraph seven of this report, a portion of the application site falls within a public safety zone (PSZ). Department for Transport Circular 01/2010 states that there should be a general presumption that development should not increase the number of people living, working or congregating within PSZs. The submitted design and access statement sets out the applicant’s response to the PSZ. Officers note that the portions of the application site that lie within the PSZ have been allocated as car and coach parking. This approach ensures that no part of the hotel building would fall within the PSZ, which is supported. The circular identifies long stay and employee car parking (with minimum stays greater than six hours) as development that may be acceptable within the PSZ. The Council should satisfy itself that the car and coach parking proposed within the PSZ would not increase the number of people congregating in these areas, when compared to the current use, and ensure that the parking is long stay.

Urban design

20 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 7 which address both general design principles and specific design issues, with new development required to have regard to its context, and reinforce or enhance the character, legibility, and permeability of the neighbourhood (Policy 7.1).

Site specific design principles

21 The application site is subject to numerous design constraints including the proximity of the airport and associated safety zones, the proximity of the site to the Green Belt, and the heavily trafficked nature of the surrounding roads. GLA officers acknowledge these restrictions, as well as the fact that low-cost hotel design also offers its own constraints, in terms of the design of elevations, the sizes of rooms and location of entrances and services. Nonetheless, the site forms part of a gateway to London traversed by visitors arriving from terminal four and overland from the west, and therefore demands a high-quality design that offers visitors some of their first impressions of the city. In addition, the site is located within an area of poor-quality buildings, and as such, any new building has the potential to act as a character-defining element of Hatton Cross.

Impact on surrounding Green Belt

22 Very limited detail has been provided on how the proposal would respond to the adjacent Green Belt. The applicant should agree assessment points for views of the proposal from

page 4 surrounding Green Belt locations with the Council, and provide visualisations so that the scheme may be assessed fully against the principles of London Plan polices 7.6 and 7.16. The impact of the development should be considered in conjunction with existing development, and should not detrimentally impact on the character of the Green Belt. Where the adjacent land has an open and/or biodiverse character, the development should seek to ensure that it preserves and enhances this character as much as possible.

Layout and external detail

23 The public safety zone constraint has resulted in the building being located in the northern portion of the site. This is beneficial as the mass of the building would address the A30, providing a solid perimeter frontage, in a way that many of the surrounding buildings do not. This is supported.

24 The layout is relatively logical, and while it is acknowledged that the entrance is effectively rear-facing (rather than an ‘address’ facing the A30), the reasons for this are understood. Officers acknowledge the applicant’s intention to direct visitors to the entrance through the design and detailing of the building and public realm. The fact that the entrance is not instantly legible from the main pedestrian arrival point, Hatton Cross station, would be assisted by the proposed ground floor layout, whereby the active frontage and ground treatment would lead the pedestrian around the building to the main entrance. GLA officers would, however, expect wayfinding signage to be permanently integrated as part of the building fabric or landscape design.

25 Notwithstanding the absence of a front entrance onto the A30, the building would manage to address this main route through its massing and detailing. The proposed landscaping works in this location would also play an important role in addressing the A30, and facilitating wayfinding, however, it is acknowledged that the landscaping proposals in this part of the site would be subject to a separate, non-strategic, planning application with Hillingdon Council. Nevertheless, GLA officers expect the landscaping to work in conjunction with the building design on this frontage, and to contribute to the qualities of place that this location currently lacks.

26 The proposed provision of long-term parking outside the hotel, with short-term parking inside the main building perimeter, is a product of the public safety zone considerations, but has the potential to be confusing to visitors. Management of this distinction should be included within the management plan, and secured by the Council through planning condition.

27 The proposed facade design achieves the architect’s desire to provide a building of monolithic proportions. Whilst there is not an in principle objection to the approach, particularly given the surrounding airport buildings and context, its impact on the Green Belt will need to be assessed as discussed in paragraph 22. The continual frontage would provide a dynamic appearance which is welcomed, given the fact that it would be visible from the public realm on all sides. The slight changes in appearance at the building’s corners, which are a result of the changes in window spacing, are supported. The proposed choice of brick as the facing material is preferential to render or other, more artificial treatments in this case, however, careful attention to the choice of stock is warranted, to ensure the building would not appear overpowering or monotonous. The grey brick sample shown within the design and access statement would appear to be suitable, however, visualisations of the building within its wider context, as requested in paragraph 22, should be provided to confirm this. Additionally, the applicant should confirm whether roof areas would be visible from rooms, or aircraft. If the roof proves to be visible it should be treated as a ‘fifth elevation’, and visualisations should be provided so that its impact may be assessed.

page 5 28 The design and access statement recognises the desire of future operators to use external signage, and identifies a number of opportunities where this may be suitable. While it is acknowledged that the detail on signage is likely to be subject to a further, non-strategic, application to accommodate end-user requirements, the Council should ensure that opportunities for signage are managed carefully so that they would not detract from the overall architectural language of the building. This is particularly important with respect to the corners of the building, which are key to the overall architectural integrity of the development. While it is not the intention of officers to unreasonably constrict the corporate requirements of the eventual operator, it is important to ensure that potential occupiers are aware of the requirements of the building to sit appropriately within the local context, while providing managed opportunities for advertising and wayfinding.

29 With the exception of proposals for the northern-most portion of the site (discussed in paragraph 25), the applicant has proposed a hard landscaping approach for the development. Although the potential of hard landscaping to direct pedestrians around the site is recognised, the lack of soft landscaping is of concern. The applicant has stated that the approach is a result of public safety zone considerations, and the need to ensure aircraft safety through the avoidance of bird attraction. Officers acknowledge these constraints, and on this basis would not seek the provision of a biodiverse roof in this instance. However, the main entrance area and associated car park, which would effectively sit within a hard-surfaced bowl surrounded by roads, would be likely to appear rather unyielding, and would do little to enhance the hotel’s main entrance. The applicant should, therefore, seek further opportunities for appropriate softening of the landscape. The treatment as presently proposed for the hotel forecourt would not contribute to visual amenity, and does not adequately respond to London Plan Policy 5.10 on urban greening.

Internal guest experience

30 Paragraph 4.30, in support of London Plan Policy 4.5, seeks to ensure that new visitor accommodation is of a high quality, and positively contributes to visitors’ impressions of their time in London, in order to encourage repeat visits. Although there are no adopted London Plan standards for hotel room quality, every opportunity should be taken to ensure that guests within the hotel, especially occupiers of the inward-facing rooms, are offered the best possible standard of accommodation.

31 The plans submitted indicate that several of the internal-facing rooms would have views restricted by plant, or other structures, rather than overlooking the courtyard. These internal walls, and roofs where visible, should offer a treatment that is attractive, and enables the maximum possible light levels to reach rooms.

32 The applicant should also ensure that corridors between lifts and rooms are as easy and as direct as possible. The cross-building route on the first floor, past the service area, should be accessible to guests with rooms on the northern side of the building, and all doors should offer easy-opening mechanisms for passengers with luggage, especially as some journeys between the core and rooms would involve passing through three doors. The provision of six lifts within the central core should manage the expected demand, and is supported. Inclusive access

33 London Plan Policy 7.2 seeks to ensure that proposals aim for the highest standards of accessibility and inclusion (not just the minimum), and that the design process has considered how everyone, including disabled and deaf people, older people, children and young people, will be able to use the places and spaces that are proposed. The GLA strongly recommends that the Council requires an accessibility management plan to be secured by condition, in order to ensure the

page 6 development meets the highest standards of inclusive design, and is appropriately managed and maintained in terms of access and inclusion.

34 The applicant is proposing that all rooms on the curved corner parts of the building be designed for wheelchair users. This would exceed the strategic minimum 10% target for the provision of wheelchair accessible hotel rooms, and is supported in accordance with London Plan Policy 4.5. The applicant also identifies five additional rooms, one on each floor, in the linking wing, as suitable for being made accessible. This proposal is strongly encouraged, as it would provide wheelchair accessible rooms which are very close to the public lift core. While the applicant has confirmed the size of the wheelchair accessible rooms, a proposed layout has not been provided. The applicant is, therefore, requested to provide indicative plans demonstrating that grab rails and hoists could be installed if required.

35 London Plan Policy 6.13, and Table 6.2, outline the requirements for car parking within development proposals to meet the needs of disabled people. Officers note that eight blue badge parking spaces (six percent of the overall car parking provision) have been proposed on the hotel forecourt. This would provide easy and direct access to the main entrance for disabled visitors arriving by car, and is supported. The applicant should, however, seek to improve the provision further, by providing additional blue badge parking spaces under cover within the undercroft parking area. The applicant acknowledges the potential for this within the design and access statement, also stating that an additional ramp would be required to provide direct access from the car park into the hotel lobby. The necessary ramp should be provided, with additional blue badge parking bays located in close proximity to it.

36 The design of the landscaping and the public realm will be crucial to determining how inclusive the development would be to many people. The pedestrian routes to the hotel should ensure full and easy access for all users. Officers note that the ramped approach to the entrance is at a gradient gentler than 1:20, and has been prioritised as the primary pedestrian access route to the hotel. This is strongly supported. The applicant is, however, asked to reconsider the use of tapering steps and angled steps within the public realm at Faggs Road, as these can present access problems for the visually impaired. Sustainable development

37 London Plan climate change policies, set out in Chapter 5, collectively require developments to make the fullest contribution to the mitigation of, and adaptation to, climate change, and to minimise carbon dioxide emissions. London Plan Policy 5.2 sets out an energy hierarchy for assessing applications, London Plan Policy 5.3 ensures future developments meet the highest standards of sustainable design and construction, and London Plan policies 5.9-5.15 promote and support the most effective climate change adaptation measures including passive thermal regulation, urban greening, and water management.

Energy efficiency

38 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters would be improved beyond the minimum backstop values required by building regulations. This is supported. Other features include mechanical ventilation with heat recovery and energy efficient lighting.

39 The development is estimated to achieve a reduction of 37 tonnes per annum (6.2%) in regulated carbon dioxide emissions compared to a 2010 Building Regulations compliant scheme.

page 7 District heating

40 The applicant has provided a commitment to ensure the development would be designed to connect to a future district heating system, however, the potential a link into the heat infrastructure at Heathrow airport does not appear to have been explored. The applicant is strongly encouraged to engage with BAA and Heathrow to assess whether there is any potential to link into the wider district heating network at the airport. Evidence of correspondence should be provided, along with details of any possible constraints, to allow officers to fully assess the scheme against London Plan Policy 5.5.

41 The applicant should also provide a drawing showing the location, layout and dimension of the proposed energy centre, and demonstrate how future connectivity to a district heating network could be provided.

Combined heat and power

42 London Plan Policy 5.6 requires proposals to evaluate the feasibility of combined heat and power (CHP) systems, and paragraph 5.37, in support of this policy, states that CHP systems must be designed to run efficiently and be optimally sized. The applicant has proposed a 100kWe CHP plant to meet the hotel’s hot water demand. Based on the material provided this would achieve a reduction in regulated carbon dioxide emissions of 107 tonnes per annum (19.2%).

43 Officers note that the energy strategy would appear to indicate that the CHP plant would only be used to supply a proportion of the hot water requirements of the hotel. However, the applicant should optimise the CHP plant so that it contributes not only to the development’s hot water demand, but also provides a proportion of the developments space heating and pre-heating requirements of the ventilation air, prior to considering renewables, in line with the principles of London Plan policies 5.2 and 5.6.

Cooling

44 The applicant has indicated that the hotel would be air conditioned by either a four pipe fan coil system, or a chilled beam system, integrated into the ceiling bulkhead above the corridor to the room.

Renewable technologies

45 London Plan Policy 5.7 requires that, within the framework of the energy hierarchy, development proposals should provide a reduction in carbon dioxide emissions through the use of onsite renewable energy generation, where feasible. In response to this the applicant has proposed a ground source heat pump system which would provide 75% of the hotels heating demand, and 100% of the cooling demand. This would result in a reduction in regulated carbon dioxide emissions of 24 tonnes per annum (5.4%). However, given the comment in paragraph 43 above, regarding the need to optimise the CHP to provide a proportion of the developments space heating demand, the applicant should re-evaluate the renewable option proposed, considering alternatives, if appropriate, such as photovoltaic panels.

Energy assessment summary

46 The estimated regulated carbon emissions of the development are 425 tonnes of carbon dioxide per year, after the cumulative effect of energy efficiency measures, CHP, and renewable energy has been taken into account. This equates to a reduction of 168 tonnes per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent

page 8 to an overall saving of 28%. The applicant should, however, ensure the CHP system has been optimised, and review the approach to renewable technologies accordingly.

Urban greening

47 London Plan Policy 5.10 seeks to promote and support urban greening, such as new planting in the public realm, and green infrastructure, to contribute to the adaptation to, and mitigation of, the effects of climate change. As discussed in paragraph 29 of this report, while officers note there are various restrictions on planting within the public protection zone, the applicant is strongly encouraged to seek to incorporate further urban greening, wherever possible, to soften the nature of the proposal, and mitigate its contribution to the urban heat island effect.

Sustainable drainage

48 London Plan Policy 5.13 seeks to ensure that development utilises sustainable urban drainage systems (SUDS), unless there are practical reasons for not doing so, and aims to achieve greenfield run-off rates. The applicant has carried out a flood risk assessment and surface water run off assessment, and is proposing the use of permeable paving and attenuation tanks to reduce surface water run off rates. Based on the material provided, it is expected that this will reduce surface water run off at the site by 50% over existing rates. This is supported. The Council should secure the proposed provision of SUDS through planning condition. Transport

49 The access proposals for the site include the modification of the controlled junction onto Dick Turpin Way, to provide a dedicated right turn lane into the site. On the basis of the material provided, TfL is content that the proposed modifications to the main site access from Dick Turpin Way are broadly acceptable.

50 In addition, it is proposed to introduce a left-in entry only secondary access into the site from Faggs Road, which will be for service vehicles and coaches only. TfL does not object to the introduction of the left-in only access into the site from Faggs Road, on the basis that it will be for a limited number of coach and service vehicles.

51 The Great South West Road is part of the Transport for London Road Network (TLRN) and a red route for which TfL is the highway authority. The other roads that form the gyratory surrounding the site, mainly sections of Dick Turpin Way and Faggs Road, are under red route control but are not within the TLRN public highway boundary. Instead these are covered by TfL Side Road Orders. On this basis, TfL is the statutory Traffic Authority under the Traffic Management Act 2004, while the local authority would be the highway authority. These works will, therefore, need to be secured via a section 278 agreement (in consultation with TfL) between the applicant and the local authority (unless the extent of work involves anything that is within the TLRN boundary). In this instance, the borough boundaries are such that there will also be works where Hillingdon Council will need to be party to the section 278 agreement as the relevant Highway Authority.

Coach, car and cycle parking

52 The smaller island site to the southwest of the main site on the other side of Faggs Road is proposed to accommodate coach parking for three coaches, and the main site incorporates a single coach drop off. The track plots provided in the transport assessment demonstrate that coaches can successfully access these coach bays.

page 9 53 Paragraph 6A.9, supporting Table 6.2 in the London Plan, states that hotel developments should provide coach parking at one space per 50 rooms. This would be equivalent to twelve coach parking spaces to serve the site. On balance, given the location and nature of the site, TfL is content that the proposal to provide three coach parking bays is acceptable in line with London Plan Policy 6.13.

54 The applicant proposes to provide 131 car parking spaces for the 583 room hotel. In this instance TfL is broadly satisfied that the level of provision is acceptable, however, the Council should seek to secure the proposed provision of electric vehicle charging points by way of planning condition, to ensure accordance with London Plan Policy 6.13.

55 Cycle parking has been proposed at a level of one space per ten staff. This is in accordance with standards in Table 6.3 of the London Plan, and is therefore acceptable. The applicant should, however, seek to provide showers, lockers, and a changing area within the building, in line with London Plan Policy 6.9, to encourage staff to cycle to work.

Trip generation

56 TfL is satisfied that the trip generation assessment methodology is acceptable, and demonstrates that there would be a net reduction in traffic when compared to the permitted use during the weekday morning and evening peak hours, and over the 24 hour weekday period.

Highway impact

57 The highway impact assessment considers the gross vehicular trips assigned to the network, which is the correct methodology, given that the surveys were undertaken after previous activities at the site had ceased. The assessment indicates that there would not be a noticeable impact on the operation of the gyratory and adjacent highway network, and on this basis TfL has no objections to the proposal based on highway impact.

Public transport

58 Given the predicted number of bus and Underground trips, and the capacity of the existing network, TfL is content that the proposal would not result in a noticeable impact, and on this basis, no mitigation measures towards bus and/or Underground services are sought.

Travel plan

59 The draft travel plan is generally acceptable, but requires further information regarding funding. This should be addressed in the final document, which should be secured by the Council through the section 106 agreement or an appropriate planning condition, to ensure accordance with London Plan Policy 6.3. Local planning authority’s position

60 The Council is expected to formally consider the application at planning committee in August/September 2011. Legal considerations

61 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the

page 10 Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

62 There are no financial considerations at this stage. Conclusion

63 London Plan policies on employment, visitor infrastructure, opportunity areas, urban design, inclusive access, sustainable development and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Employment: The proposed loss of general industrial use at the site does not raise any strategic concerns, and is acceptable in line with London Plan Policy 4.4. However, the applicant should demonstrate compliance with London Plan Policy 4.12, with regard to local employment initiatives.  Visitor infrastructure and opportunity areas: The principle of a hotel development at the site, within the indicative boundary of the Heathrow Opportunity Area, is supported in line with London Plan Policy 4.5.  Urban design: Whilst the design rationale is generally supported, there are a number of outstanding concerns that need to be addressed to ensure compliance with London Plan policies 7.6, 7.16, 5.10 and 4.5.  Inclusive access: Whilst the approach to inclusive access is broadly acceptable, commitments and revisions are sought to ensure the highest standards of accessibility and inclusion, in line with London Plan Policy 7.2.  Sustainable development: While the proposed carbon dioxide savings are welcomed, there are outstanding concerns with the proposed strategic that need to be addressed to ensure compliance with London Plan policies 5.2, 5.5, 5.6, 5.7, 5.10 and 5.13.  Transport: Whilst the proposal is broadly acceptable in transport terms, revisions and commitments are sought in relation to London Plan policies 6.3, 6.9 and 6.13.

64 Whilst the application is broadly acceptable in strategic planning terms, on balance, the application does not comply with the London Plan.

65 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:  Employment: The applicant should seek to provide local employment initiatives as part of the proposal in line with London Plan Policy 4.12.  Urban design: The applicant should address the comments made in the urban design section of this report, and, in particular, provide visualisations of the proposal within its Green Belt context, provide confirmation of whether roof areas would be visible from rooms or aircraft (providing visualisations where necessary), seek to introduce appropriate soft

page 11 landscaping, and agree to planning conditions to secure integrated wayfinding approaches as part of the landscape strategy, signage management, and high quality corridors and inward-facing rooms, to ensure compliance with the principles of London Plan polices 4.5, 5.10, 7.6 and 7.16.  Inclusive access: The applicant should commit to providing the five additional wheelchair accessible rooms proposed, provide indicative plans demonstrating that grab rails and hoists could be installed in wheelchair accessible rooms if required, seek to provide additional blue badge car parking spaces within the undercroft (with associated ramped access), and agree to a planning condition to secure an accessibility management plan, to ensure accordance with the principles of London Plan Policy 7.2.  Sustainable development: The applicant should explore the potential for connection to the heat infrastructure at Heathrow airport, provide drawings of the energy centre demonstrating possible future connectivity, and ensure that the proposed combined heat and power plant is optimised, before considering renewable technologies to ensure compliance with London Plan polices 5.2, 5.5, 5.6 and 5.7. The applicant should also seek to introduce further urban greening, and agree to a planning condition to secure the proposed SUDS, to ensure accordance with London Plan polices 5.10 and 5.13.  Transport: The applicant should seek to provide showers, lockers and a changing area within the building for cyclists, commit to planning conditions to secure electric vehicle charging points and the travel plan to ensure accordance with London Plan policies 6.3, 6.9 and 6.13.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Graham Clements, Case Officer 020 7983 4265 email [email protected]

page 12