planning report D&P/3257/01 30 October 2013 Morley House, 26-30 Holborn Viaduct in the City of London planning application no. 13/00747/FULMAJ

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

The proposal Demolition of the predominantly office, part retail and part education building at 26-30 Holborn Viaduct and a redevelopment of the site by the erection of a part 9 and part 14-storey building for use as a 226-guestroom hotel (10,180 sq.m.) on levels 0-13; with retail/private leisure use (437 sq.m.) on levels 0-2. The applicant The applicant is Tannen Morley Ltd and the architects are Stephan Reinke Architects Ltd.

Strategic issues The proposal aims to redevelop the site of a vacant office building on Holborn Viaduct, in the highly accessible Central Activities Zone of the City and to restore it to a vibrant beneficial use as a hotel, with associated retail and leisure uses. Principal considerations are the loss of office use, regeneration in the CAZ, its design and impact on strategic views and the historic environment; inclusive access, transport and energy.

Recommendation That the City of London Corporation be advised that while the application is broadly acceptable in strategic planning terms, it does not yet fully comply with some policies of the London Plan, for the reasons set out in paragraph 61 of this report; but that the possible remedies also set out in that paragraph, could address those deficiencies. The application does not need to be referred back to the Mayor if the Corporation resolves to refuse planning permission, but it must be referred back if it resolves to grant permission.

Context

1 On 20 September 2013, the Mayor of London received documents from the City of London Corporation 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 31 October 2013 to provide the Corporation with a statement setting out whether he considers that the application complies with the London Plan,

page 1 and his reasons for taking that view. The Mayor may also provide other comments. This report provides background information for the Mayor to use in making his decision.

2 The application is referable under Category 3E of the Schedule to the Order 2008: ”Development —(a) which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated; and (b) comprises or includes the provision of more than 2,500 square metres of floorspace for a use falling within any of the following classes in the Use Classes Order—(ix) class C1 (hotels); and (xii) class D2 (assembly and leisure).”

3 Once the City Corporation 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 or allow the Council to determine it itself, unless otherwise advised. In this instance if the Corporation resolves to refuse permission it need not refer the application back to the Mayor.

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 relates to the vacant, 1980s Morley House office building, constructed on two levels and sandwiched between the historic (Grade II listed) City Temple on its western side; and the Grade II Listed, William Haywood Gatehouse and Heritage staircase to the east, which links the elevated Holborn Viaduct to Farringdon Street below. Sir Christopher Wren’s Grade I Listed St Andrew’s Church is situated across the road to the west, but the site does not fall within any of the local conservation areas.

6 Although the building was in predominantly office use, it contained a ground level retail use (class A1) and a temporary educational use (class D1).The site is bounded on the north by Holborn Viaduct and on the south by Plumtree Court. There is a substantial height difference (approximately 9 metres) between the viaduct level and that of Plumtree Court, to the rear of the building.

Figure 1: Location plan showing the site edged in red. (Source: Application drawings).

7 The glazed and stone panel building fronts onto the south side of the viaduct, where it is seven storeys high, including floors within a tall mansard roof. The rear of the building faces

page 2 onto Plumtree Court, where it rises to 8/9 storeys. Plumtree Court has secondary or ancillary character and provides service bay access to Morley House.

8 The surrounding area is typified by vibrant activity, commercial offices and retail offers, given its location within the commercial core of the London. The site facing Morley House across Plumtree Court has recently been granted permission as the European headquarters for Goldman Sachs Bank and Plumtree Court will be the route into the service entrance for the building, which is located at the Farringdon Street end of Plumtree Court. Holborn has a large number of commercial offices located adjacent to it and Farringdon Station is undergoing a major redevelopment to accommodate a Crossrail link; resulting in a greatly increased footfall on Farringdon Street.

9 The site is very well served by public transport, with Morley House situated between Chancery Lane and St Paul’s underground stations on the Central line; with Farringdon main line and underground rail stations situated nearby. Both Holborn and Farringdon Street are bus routes, with frequent bus services passing the site.

10 Holborn Viaduct forms part of the Strategic Road Network (SRN), whilst Farringdon Street, 40m east of the site forms part of the Transport for London Network (TLRN).The site is served directly by 5 bus routes (8, 25, 242 and 521 and N8) on Holborn Viaduct, with a further 4 routes (17, 45, 63 and N63) available within an acceptable walking distance of the site, on Charterhouse Street. The site is 170m from City Thameslink station and 340m east of Chancery Lane station served by Central line London Underground Services. The nearest cycle hire docking station is a temporary manual operation in Stonecutter Street. Consequently, the site has a public transport accessibility level (PTAL) of 6 on a scale of 1 to 6, where 6 is the most accessible.

Details of the proposal

11 The application is for a redevelopment to create 11,224 sq.m. of floorspace to comprise:

 A ground plane with an active frontage and a variety of offers along Holborn Viaduct.  A high quality hotel with accommodation comprising 226 guestrooms and supporting facilities, including a basement level gym/leisure facility.  An accessible inner courtyard adjunct to the hotel.  Accessible and high quality roof terraces on both wings of the building.  A building design of outstanding architectural and sustainable quality appropriate to its setting.

12 With regard to access, in view of the existing use of Plumtree Court as a service access to the adjacent bank, it proposed that the service entrance to the hotel should also be situated in that location. A secondary use is for the basement gym/leisure facility to have an entrance at this level.

13 This site is unique in its location on two main streets in Central London, thereby creating a dual-level crossroad. This level difference allows an intermediate level to be constructed between the viaduct level and Plumtree Court to provide an inner courtyard as illustrated below:

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Figure 2: A cross-section of the proposal (Source: Applicant’s Design & Access Statement). Case history

14 No previous applications have been referred to the Mayor; nor any pre-application discussions held with GLA officers. Strategic planning issues and relevant policies and guidance

15 The relevant issues and corresponding policies are as follows:

 Regeneration London Plan; the Mayor’s Economic Development Strategy  World City role London Plan  Tourism/leisure London Plan; Good Practice Guide on Planning for Tourism (DCLG)  Mix of uses London Plan  Urban design London Plan;  Tall buildings/views London Plan, Revised View Management Framework SPG  Historic Environment London Plan; World Heritage Sites SPG;  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Transport/Parking London Plan; the Mayor’s Transport Strategy; Revised Early Minor Alteration to the London Plan Land for Transport Functions SPG;  Crossrail London Plan; Mayoral Community Infrastructure Levy; Crossrail SPG  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy

16 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 September 2011 City of London Core Strategy DPD and the July 2011 London Plan (with 2013 Alterations).

page 4 17 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The City of London Site Allocations Development Plan Document Land use policy, loss of office space and the principle of a hotel use

18 The application site lies within the Central Activities Zone (CAZ) as defined in the London Plan, wherein policies 2.10 and 2.11 aim to sustain and enhance the City of London as the iconic core of a strategically important, globally-oriented financial and business centre. The policies look to sustain and manage the CAZ’s varied strategic functions, especially its attraction as one of the world’s leading visitor destinations. Policy 2.11 further affirms the Mayor’s commitment and stakeholders’ obligation to seek solutions to the constraints on office provision and other commercial development imposed by heritage designations, without compromising local environmental quality.

19 These strategic policies are supported by policy CS1 of the City’s Core Strategy document, which aims to promote inward investment by encouraging developers and businesses to invest and locate in the City. The policy looks to ensure that the City provides 1.15 million square metres of additional high quality office space over the plan period 2011-2026, to meet the demand from long-term employment growth and strengthen the beneficial clusters of activities within the City that contribute to London’s role as the world’s preeminent international finance and business hub. Implicit in this policy is a presumption against the loss of existing office space unless there are compelling reasons to justify a departure from that policy.

20 In this instance, a viability assessment for re-letting the existing building as offices has been submitted on behalf of the applicant. It demonstrates the relative secondary location of the application site and the availability of more attractive office options in ‘The City’; that due to the constraints of its poor configuration and siting adjacent to listed buildings and strategic views, a refurbishment for office use would not achieve sufficient floor plates necessary to meet contemporary office requirements; and furthermore, that the building has been marketed unsuccessfully for office and alternative uses for a considerable period of time. The assessment therefore concludes that the premises cannot be let in their existing format other than on ‘give- away’ terms, which is simply not viable. Although several parties have enquired to purchase the freehold ownership of the building, none have been interested in its refurbishment or redevelopment for office purposes, which further underlines the conclusion that the site is not viable for continued office use.

21 On the other hand, the proposal to develop a hotel in that location is supported in strategic policy terms. London Plan policy 4.5 states the Mayor’s commitment and stakeholders’ objective to support and stimulate the growth of London’s visitor economy by taking into account the needs of business as well as leisure visitors; achieve 40,000 net additional hotel bedrooms in London by 2031, of which at least 10% should be wheelchair accessible; and to improve the range and quality of provision. The policy further provides that within the CAZ, strategically important hotel provision should be focussed on its opportunity areas, with smaller scale provision in CAZ fringe locations with good public transport, such as the subject application site.

22 On balance, it is accepted that the existing building is outdated and unlikely to attract a viable letting or continued office occupation. Its replacement with a modern, 226-guestroom hotel, would make a positive contribution to the regeneration of the site and its surrounding, if it is of an exemplary design that is compatible with, respectful of and complementary to the adjoining listed/ historic buildings, as well as important views within the City. It is also well positioned as a Central

page 5 London hotel, close to Farringdon Station, which will be accessible as a super interchange to major London airports.

Urban design

23 The proportions and rhythm of the hotel’s high-profile facade onto Holborn Viaduct are specifically designed to match the adjoining City Temple on the west and the Viaduct Gatehouses to the east, which is welcomed. A taller element would be sited to its rear, facing onto Plum Tree Court.

Figures 3 & 4: Computer-generated images of development as seen from Holborn Viaduct (Source: Applicant’s Design & Access Statement).

24 Only the higher levels of the east and west-facing elevations of the taller building would be visible from the viaduct; whilst its south-facing rear elevation would back onto the less active, predominantly servicing uses on Plumtree Court. 25 The treatment at street level on Plumtree Court represents a missed opportunity, designed to consolidate rather than ameliorate the relative isolation, lack of activity and low level of security on that street (as illustrated below); with the proposed ground floor occupied by inactive uses such as a combined heat and power plant, transformers, generators and a sub-station, instead of active uses such as a cafe, restaurant or other food and drink establishment. The applicant is, therefore, requested to consider the feasibility of relocating the A3/private leisure use from the basement up to street level (see Figure 2 above) and moving the plant and equipment into the basement.

Figure 5: Plumtree Court elevation showing the lack an active street frontage. (Source: Design & Access Statement).

page 6 26 The inclusion of a secluded landscaped courtyard at intermediate level, between Holborn Viaduct and Plumtree Court, would provide some welcome relief from the hive of activity and traffic of the surrounding City environment and is fully supported.

27 Whilst there is no objection to the principle of the hotel being significantly taller than many of the contextual buildings, the taller element needs to be of exemplary design for it to be acceptable in strategic planning terms. A criticism of the current scheme is the poor quality and lack of detailing on the highly exposed gable end that is particularly visible on the approach from the east on Holborn Viaduct. The applicant is requested to provide more details of this flank wall prior to as part of any further referral of this case back to the Mayor.

Figure 6: A view of the gable east-facing gable end onto Holborn Viaduct. (Source: The applicant’s Townscape and Visual Assessment document).

28 Furthermore, due to its siting within the corridor of strategic views, such as St Paul’s Cathedral, the applicant is requested to submit verified views, in line with the requirements of the London Views Management Framework (LVMF).

29 Overall, the building would be finished in a simple, but entirely appropriate palette of materials that comprise beige limestone, stainless steel and high quality ‘clear vision’ glazing that are applied consistently throughout the scheme, with its individual elements carefully selected to reflect the adjoining and emerging character of the local area, which is welcomed. Inclusive design and access

30 The London Plan (policy 7.2) requires all new developments to meet the highest standards of accessibility and inclusion, not just the minimum required under the Building Regulations. This, together with the Supplementary Planning Guidance- ‘Accessible London achieving an inclusive environment’, underpins the principles of inclusive design and aims to achieve an accessible and inclusive environment across London.

31 The application was accompanied by a design and access statement, which provides a floor by floor summary of the provisions made to facilitate ease of movement by disabled visitors and others with impaired mobility. A major concern is that the main entrances to the hotel and adjoining shop are on a stretch of Holborn Viaduct with bus priority measures in place and is therefore constrained in terms of picking up and dropping off disabled visitors by private car or taxi. As TfL makes clear below, the applicant should devise a strategy for vehicles to pick and drop off passengers off the adjoining strategic roads, but not on secondary back streets, to ensure the free flow of bus and other traffic. Details of this should be provided prior to or as part of any further referral of this case back to the Mayor.

page 7 32 The access statement also confirms that some guestrooms would be specifically designed for wheelchair users and others with special needs. The proposal to provide inter-connecting doors between such rooms and the adjoining rooms for the use of accompanying carers where necessary is especially supported; however, the statement does not specify that the proportion of rooms for special needs rooms meets the required 10% specified in the London Plan, or identify their location within the development. It would be particularly useful if the applicant would provide a typical floor layout of those special guestrooms, to ensure compliance with the strategic requirements. Transport for London’s comments

33 The trip generation methodology used to calculate new trips likely to be generated from the site is considered acceptable, including the approach to calculate the anticipated impact based on the current office use. This demonstrates and is therefore accepted that the volume of new trips created will have a negligible impact on the capacity of the local highway, bus and London Underground services.

34 The car-free proposal is welcomed by TfL in recognition of the site’s excellent accessibility. To accord with London Plan policy, the applicant should liaise with the City of London Corporation and TfL to identify appropriate location(s) for at least one on site or on street Blue Badge bay close to the site or an existing facility nearby that the development could utilise.

35 The development suggests cycle parking will be provided in accordance with London Plan policy 6.13. This suggests 1 space per 10 staff, to be located within the building in a secure location, which is supported. The number of spaces should however be specified. The provision of shower facilities for staff is also supported. In addition, TfL recommends an element of visitor cycle parking be provided in and around the building, to accord with the Revised Early Minor Alterations to the London Plan.

36 The vehicular access into the site and servicing bay is proposed to remain from Plumtree Court via Shoe Lane, with an on-street servicing bay provided. The proposal not to service the site from Holborn Viaduct is supported by TfL, which recognises the constraints for taxi pick-up and drop-off. Due to the additional dwell time in taxis picking up from the site and the incidence of the bus lane, TfL requests that a facility or strategy for all mini-cabs picking up is identified off the SRN and TLRN. This will ensure that the impact on bus services and cycle movements is minimised in line with London Plan policy 6.9 and 6.7.

37 As there are existing pressures on the closest nearby cycle hire docking stations, and the manual operation in Stonecutter Street is due to cease soon, it is TfL’s view that provision of a new docking station in the vicinity of the site would be the only satisfactory way to mitigate the impact of additional demand from this development. In accordance with London Plan policy 6.9, TfL seeks a contribution of £187,000 for a 30-space docking station. This should be secured through the section 106 agreement. TfL requests discussion with the Corporation of London and the applicant on this matter.

38 TfL welcomes the Space Syntax pedestrian analysis submitted, this work should ideally be expanded upon to cover the quality of the local environment and assess the identified predominate pedestrian routes to and from the site. There are a number of planned and future public realm, pedestrian and cycle enhancements within the vicinity of the site. TfL requests discussion with the applicant and the City Corporation on the approach to public realm enhancements in the vicinity of the site. A request may also be made for an appropriate contribution to improve links to nearby transport hubs, including the Charterhouse Street junction, which links to the forthcoming Crossrail station at Farringdon.

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39 A travel plan has been submitted and should be secured, along with any necessary measures or financial contributions through the section 106 agreement, for example cycle vouchers and car club membership. A construction logistics plan (CLP) should also be secured by condition in line with London Plan policy 6.14.

40 It is important that cycle safety measures are enforced during construction. In particular, TfL wishes to ensure that construction vehicles are fitted with cycle specific safety equipment, including side-bars, blind spot mirrors and detection equipment to reduce the risk of collisions on the capital’s roads. TfL requests that these requirements be secured in the section 106 agreement and are to be included in the final CLP to be submitted for approval by the Corporation prior to commencement.

41 The site sits within close proximity to the Central Line tunnels. There are a number of potential constraints on the redevelopment of a site situated above London Underground tunnels. In accordance with London Plan policy 6.2; TfL requires discussions with the applicant over the design and methods of demolition and construction. Detailed conditions have been suggested through the response to the Corporation.

42 It is requested that a delivery and servicing plan (DSP) be also secured for the site by condition to ensure conformity with London Plan policy 6.14.

43 In accordance with London Plan policy 8.3, it is noted that the proposed development is within the City of London, where the Mayoral charge is £50 per square metre gross internal area (GIA).

44 The mechanism for contributions to be made payable towards Crossrail has been set out in the Mayor’s Supplementary Planning Guidance (SPG) ‘Use of planning obligations in the funding of Crossrail and the Mayoral Community Infrastructure Levy’ (April 2013) and London Plan policies 6.5 and 8.3. The SPG states that contributions should be sought in respect of uplift in floorspace for B1 office, hotel and retail uses (with an uplift of at least 500sqm). The site is within the Central London charging zone and therefore the applicant will need to provide the existing and proposed GIA floorspace to ensure the Crossrail contribution is calculated correctly.

45 The applicant should note however, that the Mayor’s CIL charge will be treated as a credit towards the section 106 liability and therefore only the greater of the two sums will normally be sought.

Summary

46 To summarise, a contribution towards a Barclays Cycle Hire station, an increase in cycle parking, the identification of convenient parking for disabled visitors, and floorspace information to calculate the Crossrail/CIL liabilities are requested. This is in addition to TfL’s requests for a DSP, CLP and Travel Plan. Energy issues

Energy efficiency standards

47 A range of passive design features and demand reduction measures are proposed to reduce the carbon dioxide (CO2) emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include low energy lighting, high efficiency cooling and

page 9 ventilation systems and integration of a building management system. The demand for cooling will be minimised through highly performing solar glazing and low energy lighting.

48 The development is estimated to achieve a reduction of 69.5 tonnes per annum (10%) in regulated CO2 emissions compared to a 2010 Building Regulations compliant development, as shown in the table below. District heating

49 The applicant has identified that Citigen district heating network is within the vicinity of the development, but is not proposing to connect to the network, following communication with E-On (the Citigen operator). The applicant should provide evidence of correspondence with E-On about the opportunity of connection of this specific site, confirming what it states in the energy report. The London Heat Map suggests that there may be a more direct route directly from the Citigen plant to the site that would not need to cross the railways. If possible, connection to the network should continue to be prioritised.

50 The applicant has provided a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available.

51 The applicant proposes to install a site heat network. The applicant should confirm that all hotel rooms and other uses (e.g. rooftop bar) will be connected to the site heat network. The site heat network will be supplied from a single energy centre located at ground level and identified in the design and access statement drawings.

Combined heat and power

52 The applicant proposes to install a 100 kWe gas-fired CHP unit as the lead heat source for the site heat network. The CHP is sized to provide the majority of the domestic hot water load. A reduction in regulated CO2 emissions of 101.4 tonnes per annum (16%) will be achieved through this second part of the energy hierarchy (see table below).

Renewable technologies

53 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 28 sq.m. of photovoltaic (PV) panels on the roof of the building. A roof plan has been provided showing the portion of roof where the PV array will be installed.

54 A reduction in regulated CO2 emissions of 2 tonnes per annum (0.4%) will be achieved through this third element of the energy hierarchy (see table below).

Overall carbon savings

55 Based on the energy assessment submitted at stage I, the table below shows the residual

CO2 emissions after each stage of the energy hierarchy and the CO2 emission reductions at each stage of the energy hierarchy.

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Table: CO2 emission reductions from application of the energy hierarchy

Total residual regulated Regulated CO2 emissions CO2 emissions reductions (tonnes per annum) (tonnes per annum) (per cent) Baseline i.e. 2010 Building Regulations 690.9 Energy Efficiency 621.4 69.5 10% CHP 520 101.4 16% Renewable energy 517.9 2.1 0.4% Total 173 25%

56 A reduction of 173 tonnes of CO2 per year in regulated emissions compared to a 2010 Building Regulations compliant development is expected, equivalent to an overall saving of 25%.

57 The CO2 savings meet the target set within Policy 5.2 of the London Plan and applicable to this scheme, which was submitted for stage 1 before the 1 October 2013. However, further information needs to be provided on the feasibility of connecting to the nearby Citigen heat network before the proposals can be deemed acceptable.

Local planning authority’s position

58 At the time of writing, it had still not been ascertained when officers of the City Corporation would be reporting this application to the planning committee or what their recommendation was likely to be. Legal considerations

59 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 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. 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

60 There are no financial considerations at this stage. Conclusion

61 London Plan policies on the loss of office space, London’s World City role, regeneration, tourism/leisure design, inclusive access, transport and energy are relevant to this application. Whilst the application is broadly acceptable in strategic planning terms, on balance, it does not yet fully comply with the London Plan. The following changes might, however, remedy the above- mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

page 11  Design: The uses at street level on Plumtree Court represent a missed opportunity to ameliorate the relative isolation, lack of activity and low level of security of that street by the introduction of an active frontage, with uses such as a cafe, restaurant or other food and drink establishment. The applicant is, therefore, requested to consider relocating the A3/private leisure use from basement to street level, and moving the plant and equipment into the basement if viable and realistic for letting. The applicant is also requested to address the lack of detailing on the east-facing flank wall to be seen on the approach from Holborn Viaduct. Verified views of the building and its impact on strategic viewing corridors should be submitted prior to or as part of any further referral of this case back to the Mayor.  Inclusive access: The applicant should confirm the proportion and identify the location of wheelchair accessible guestrooms within the hotel, provide a typical floor plan of such units; and devise a strategy for the pickup and dropping off of disabled visitors off the strategic road network.  Transport: TfL requests a financial contribution towards the provision of a Barclays Cycle Hire station, an increase in cycle parking, the identification of convenient parking for disabled visitors, and floorspace information to calculate the Crossrail/Mayor’s CIL liabilities. This is in addition to TfL’s requests for a delivery and servicing plan, a construction logistics plan and a travel plan.

 Energy: The applicant should confirm that all hotel rooms and other uses (e.g. rooftop bar) will be connected to the site heat network. The site heat network will be supplied from a single energy centre located at ground level and identified in the design and access statement drawings. Additional information is also required on the feasibility of connecting to the nearby ‘Citigen’ heat network, before the proposals can be confirmed as being acceptable.

for further information, contact Development & Projects: Stewart Murray, Assistant Director- Planning 020 7983 4271 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] David Blankson-Hemans, Senior Strategic Planner (Case Officer) 020 7983 4268 email [email protected]

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