planning report D&P/1825d/01 27 June 2016 The Arena, Bennetsfield Road, Stockley Park, UB11 1AA in the London Borough of Hillingdon planning application no. 37800/APP/2016/1430

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 Erection of 81 room (Use Class C1) with ancillary bar/café and associated ancillary works including extension and reconfiguration of car park and landscaping. The applicant

The applicant is BBC Pension Trust Ltd, the architect is Urban Edge and the agent is Smith Jenkins Ltd.

Strategic issues summary Principle of development: The site is on the Green Belt in an international business park, which falls within the Heathrow Opportunity Area. The development comprises the redevelopment of previously developed land in the Green Belt and is therefore considered to be appropriate development in accordance with the NPPF. The development of a hotel on the site will complement and enhance the competitiveness of the business park and by extension that of London as an international city whilst providing full-time and part-time employment and structured training in line with London Plan policies and is strongly supported (paragraphs 16- 35). Transport: Further discussion, clarification and/or commitments with respect to car, cycle and coach parking are required (paragraphs 43-48).

Recommendation That Hillingdon Council be advised that while the application is generally acceptable in strategic planning terms, the application does not comply fully with the London Plan, for the reasons set out in paragraph 71 of this report; but that the possible remedies also set out in paragraph 71 of this report could address those deficiencies.

page 1 Context

1 On 16 May 2016 the Mayor of London received documents from Hillingdon 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 27 June 2016 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 3D of the Schedule to the Order 2008:

“Development (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and (b) which would involve the construction of a building with a floorspace of more than 1,000 square metres or a material change in the use of such a building.”

3 Once Hillingdon 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 site, formally known as The Arena, is situated within Stockley Park, West Drayton, and forms part of an international business park built during the 1980s. The business park is bounded by Stockley Road to the west, Stockley Pines Golf Course to the North, Dawley Road to the east, and the Grand Union Canal to the south. It falls within the Heathrow Opportunity Area and is designated as a Key Sub-Area in the Hillingdon Local Plan: Part 1 - Strategic Policies. The site is also located within the Green Belt.

6 The northern boundary of the application site is defined in part by the sloped landscape and existing tree line which forms part of the Stockley Park Golf Club and to the south there is a man-made lake which forms part of the existing Arena drainage strategy. The entire site’s topography slopes from north to south towards the lake.

7 The Arena serves as the leisure and amenity hub for the Business Park and the existing building is currently occupied by a health club, a wide variety of retail and restaurant units, a public house, and offices. The Arena building is locally listed, but does not form part of a Conservation Area.

8 Vehicular access to the site is via a private road off the public highway to the east of the A408 Stockley Road/Horton Road roundabout. Stockley Road leads to the M4, located 1.6 kilometres to the south. The public transport access level (PTAL) of the site is poor and estimated at 2 (on a scale where 1a is the lowest and 6b the highest). Three bus routes (U5, 350 & A10 “Heathrow Fast” service) serve the site from a stop on Stockley Park, Roundwood Road, located within 200m of the site. These bus routes operate at an average frequency of 4.6 buses per hour.

9 There are no London Underground stations within walking distance of the site and the nearest rail station is West Drayton, located approximately two kilometres west, and provides services between Oxford and London Paddington route.

page 2 10 The nearest section of the Transport for London Road Network (TLRN) is the Hayes Bypass/A312, located approximately 2.9km to the east of the site. The nearest section of the Strategic Road Network (SRN) is Uxbridge Road/A4020, located approximately 1.8km to the north-east. With regard to cycling, a QuietWay Phase 2 Route is planned to run 700 further north from the site.

Details of the proposal

11 The applicant is seeking full planning permission for the construction of an 81-bedroom hotel (bar/restaurant included) with a total GIA floor area of approximately 2490 sq.m. over three levels. The hotel will be built partly above existing ground floor uses and partly over sailing the surface level car park, and will be operated by Travelodge. Case history

12 An application (reference number PDU/1825b/01) to provide an additional 2,305 sq.m. of office accommodation at Stockley Arena was referred to the Mayor in April 2013 for consideration. This application was supported by the Mayor on 28 August 2013 and granted permission by Hillingdon Council on 29 August 2013. Strategic planning issues and relevant policies and guidance

13 The relevant issues and corresponding policies are as follows:

 Green Belt London Plan;  Hotel London Plan;  Employment London Plan;  Urban design London Plan;  Access London Plan; Accessible London: achieving an inclusive environment 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;  Transport London Plan; the Mayor’s Transport Strategy; MALP Transport;

14 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plans in force for the area are the 2012 Hillingdon Local Plan: Part 1 - Strategic Policies, Saved policies of the Unitary Development Plan (2007), and The London Plan 2016 (The Spatial Development Strategy for London Consolidated with Alterations since 2011).

15 The following are also relevant material considerations:

 The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework.  Hillingdon Council’s Local Plan Part 2 (Revised Proposed Submission Version, October 2015), which comprises Development Management Policies, Site Allocations and Policies Map, are also relevant material considerations.

page 3 Principle of development: Development of hotel on Green Belt

16 The National Planning Policy Framework (NPPF) defines previously developed land (PDL) as: “Land which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure. This excludes: land that is or has been occupied by agricultural or forestry buildings; land that has been developed for minerals extraction or waste disposal by landfill purposes where provision for restoration has been made through development control procedures; land in built-up areas such as private residential gardens, parks, recreation grounds and allotments; and land that was previously-developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape in the process of time.”

17 As the proposed hotel will be built partly above existing ground floor uses and partly oversailing the surface level car park within the curtilage of the “The Arena” site, it is considered to be previously developed site.

18 London Plan Policy 7.16 ‘Green Belt’ notes that “the strongest protection should be given to London’s Green Belt, in accordance with national guidance. Inappropriate development should be refused, except in very special circumstances. Development will be supported if it is appropriate and helps secure the objectives of improving the Green Belt as set out in national guidance.”

19 The national guidance referred to above is articulated in the National Planning Policy Framework (NPPF) at paragraphs 88-92, which makes it clear that, with few exceptions, the construction of new buildings in the Green Belt should be regarded as inappropriate development. The NPPF further advises local authorities that when considering any planning application, they should ensure that substantial weight is given to any harm to the Green Belt and ‘very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.

20 The exceptions found under paragraph 89 in the NPPF are:

 Buildings for agriculture and forestry;  Provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it;  The extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building;

 The replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces;  Limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan; or  Limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.

21 The applicant contends that the proposal accords with bullet point six above since the proposal is for the redevelopment of previously developed land, which will have no greater material

page 4 impact than the existing buildings on the openness of the green belt and the purposes of including land within it. To illustrate the appropriateness of the proposal, the applicant cites the approval of the previous application (mentioned at paragraph at 12 of this report) for an office extension to The Arena to provide additional office floorspace accommodated through a single-storey extension to the central rotunda and southern wing, and a two-storey extension above the existing refuse storage and delivery area of the northern wing.

22 The current hotel application proposes a similar level of floorspace (2,489 sq.m. versus 2,305 sq.m.). Two key footprint and massing differences between the two schemes is that the current hotel application comprises a building that extends further to the north, but this is balanced against the fact that the hotel building is lower than the office scheme, which extended to a level above both the rotunda structure and the retaining walls of The Arena.

23 Based on the figures provided, the proposal would represent about a 40% uplift in GIA floorspace. As previously indicated, the site where the proposed building is to be located is primarily car parking and is within the curtilage of the developed site and therefore can be considered as previously developed land. The proposal, therefore, would not significantly increase the developed area of the site, and its impact on the openness of the Green Belt in this location is limited as the proposed building would be lower than the existing building.

24 In view of the above, it is considered that the current proposal meets the exception at bullet point six under paragraph 89 of the NPPF and is therefore considered to be appropriate development.

Very special circumstances (VSC)

25 Notwithstanding the above argument about the appropriateness of the development, should it be considered that it constitutes ‘inappropriate development’ within the Green Belt; the applicant, on the advice of the Council, has set out ‘very special circumstances’ justifying the proposed scheme. The Council’s pre-application advice letter acknowledges that though there is some policy support for a hotel at Stockley Park the building would still be deemed inappropriate. It should be noted that the Council, according to the applicant, has not considered the exception, mentioned above, set out in paragraph 89 of the NPPF.

26 The introduction of a hotel as a catalyst for continued growth and development of the business park is the applicant’s argument to justify that ‘very special circumstances’ exist. Stockley Park, the applicant asserts, requires a hotel to enable it to remain competitive in attracting investors and occupiers in order to remain as one of Europe’s leading business parks and to support economic growth.

27 The applicant posits that the park is lagging behind most other business parks and as one of the first suburban ones in the UK it must be modernised in order to keep pace with other business parks and town centre locations. Part of this modernisation process includes the availability of easily accessible ancillary services and facilities (including quality overnight accommodation), which are becoming the minimum amenity requirements for businesses when deciding on a location. The demand for accommodation is further amplified given the number of firms located in business parks with differing requirements, which results in a greater diversity of occupiers and occupier needs.

28 Table 1 below, submitted by the applicant, shows how Stockley Park compares with other key business parks in the United Kingdom with regards to the provision of hotel accommodation on site or nearby.

page 5 Table 1 – Key UK Business Parks and Hotel Provision

Business Park Approx Approx. No. Hotel Provision . Size Companies / (acres) Jobs Provided * 4 star Aztec Hotel & Spa and Lodge on the Park Aztec West, Bristol Unknown 100 / 7000 (both on site)

Birchwood Park, Warrington 125 165 / 6000. Pentahotel (on site) Birmingham Business Park, Express (at Solihull Parkway 148 100 entrance) Cambridge Science Park 152 100/5000 Travelodge (close by) Cheadale Royal Business De Vere Hotel and Park 70 Unknown (both on site) Cobalt International Business Park, Newcastle 20 major occupiers Village Hotel & Leisure Upon Tyne 250 / 14,000 Club (on site) Doncaster Lakeside Business Travelodge (on site) and Park 54 Unknown Premier Inn (close by) Discovery Park, Sandwich Kent 220 134 / 2400 None

Novotel, Hotel and Edinburgh Park, Edinburgh 134 Unknown Premier Inn (all on site)

Green Park Reading 195 Unknown Millennium Hotel (on site)

4 start Beales Hotel and

Travelodge (both on site)

and Jarvis and Hatfield Business Park 200 Unknown / 13,000 Premier Inn (adjacent) Milton Park, Abingdon 250 160 / 6500 Premier Inn (at entrance) Paragon Business Village, Wakefield 130 Unknown Premier Inn (on site) Mecure Sheffield Parkway Sheffield Business Par 200 Unknown / 2000 Hotel (on site) Stockley Park 150 Unknown None Thorpe Park Hotel and Thorpe Park, Leeds 135 60 / 4500 Spa (on site) 4 star Holiday Inn and Winnersh Triangle 85 50 / Unknown Travelodge (both on site).

29 Enabling London to compete successfully at the international level with a strong and diverse economy and an entrepreneurial spirit that benefits every Londoner from all parts of London forms part of the Mayor’s vision and objectives outlined in the London Plan.

30 Policy 2.1 of the London Plan states that the Mayor and the GLA Group, and all other strategic agencies should ensure that London retains and extends its global role as a sustainable

page 6 centre for business, innovation, creativity, health, education and research, culture and art and as a place to live, visit and enjoy.

31 London Plan Policy 4.5 ‘London’s Visitor Infrastructure’ states that the Mayor “will support London’s visitor economy and stimulate its growth, taking into account the needs of business as well as leisure visitors and seeking to improve the range and quality of provision especially in outer London.” Policy 4.5 also sets a target of 40,000 net additional hotel rooms by 2036 and identifies town centres, intensification areas and Opportunity Areas (once there is adequate public transportation to central London and other international and national transport hubs) as locations for additional provision beyond the Central Activities Zone (CAZ). 32 As indicated earlier, the site lies within the Heathrow Opportunity Area and is identified as a prime location for a diverse range of office activity, and by extension employment generation, by the London Plan and Hillingdon’s development plans. Hillingdon Local Plan: Part 1 - Strategic Policies at Table 5.3 under paragraph 5.31 and Paragraph 2.17 of Hillingdon’s Local Plan Part 2: Development Management Policies (Draft 2015) also identify the provision of a hotel as key to enhancing growth in the business park. Stockley Park is also designated as a strategic employment site within the Hillingdon Local Plan: Part 1 - Strategic Policies.

33 The supporting documents submitted by the applicant indicate that five fulltime and 16 part-time jobs will be created from the proposed development. Given the positive impact the provision of the hotel is expected to have on the competitiveness and attractiveness of the business park to potential investors, it is also expected to contribute indirectly to the creation of additional jobs in the medium to long term.

34 In addition, Travelodge’s New Hotel Opening’s team is responsible for taking forward the recruitment and training of employees and they will ensure that employment, training and apprenticeship posts are made available to persons within Hillingdon liaising with Job Centre Plus. Overall, those who join Travelodge are given training as a matter of routine, with the aim of achieving at least a level two national vocational qualification. This proposed recruitment and training strategy fulfils the requirements of London Plan policies 4.12 ’Improving Opportunities for All’.

35 In summary, the proposed development of a hotel in the Green Belt is supported as it comprises the redevelopment of previously developed land that will deliver significant economic benefits.

Urban and inclusive design

36 The proposed development will deliver a sympathetic and appropriately scaled addition to the site as it will be lower in height than the other buildings on the site. The proposed hotel is laid out in a “T” shape with the majority of floorspace provided on the first and second floors with just the entrance/lobby, linen intake and other ancillary services accommodated on the ground floor. The remainder of the ground floor is allocated to undercroft car parking. The entrance/lobby is situated close to the rotunda and this emphasises the relationship between the new building and the core of The Arena—the rotunda.

37 Officers support the intention to keep the height of the new building below that of the others on the site and are broadly satisfied that the proposed building will not have an adverse impact on Green Belt openness, given that they will generally be seen in the context of the adjacent large-scale business park buildings.

38 Several trees located internally to the site, however, will be removed to enable the proposed development to proceed. Whilst the loss of these trees does not raise an objection in principle,

page 7 their removal will need to be suitably mitigated in accordance with London Plan policies 7.16 and 7.21. The grassed open space area to the east of the Arena may provide a suitable location for the reprovision of trees; however, GLA officers would welcome further discussions with the applicant with respect to the tree replacement strategy prior to the Mayor’s decision making stage.

39 GLA officers are also of the view that the large expanse of hard-surfaced car parking (to the west of the Arena) offers a valuable opportunity to introduce planting and soft landscaping to enhance the feel and appreciation of this space as Green Belt.

40 In accordance with London Plan Policy 4.5 ‘London’s Visitor Infrastructure’, at least 10% of bedrooms provided in new should be wheelchair accessible. The design and access statement submitted by the applicant indicates that there will be three adaptive rooms and eight accessible rooms and as such the scheme meets the required 10% provision.

41 Any new areas of footpath and public realm have been designed in such a way that newly provided street furniture and planting has been positioned out of the main pedestrian routes with sufficient clear space left for unhindered movement of all leisure users. Where the change in site levels have dictated the implementation of stepped accesses, alternative ramped accessed have also been considered and incorporated to reduce any access restrictions.

42 The development of the site has been designed with reference to the Disability Discrimination Act, in order to provide easy practical access to the development, and good plot visibility to make navigability easier for users who have visual impediments. The units will feature easily identifiable and level entrances, while independent access around the site will continue to be available without the need to use steps or steep gradients. Dedicated disabled parking will be provided directly adjacent to the proposed unit and its entrance and will be designed to meet current standards. Further features that meet Part M standards are proposed and are in keeping with Travelodge’s guide for disabled and inclusive design in its brand standards, which is a comprehensive guidance. Transport

Highway impact

43 No change to the site access is proposed. Both pedestrian and vehicular access to the site is to be gained through the existing access via Bennetsfield Road, which forms part of a private road through Stockley Park. TfL is satisfied with this arrangement being maintained.

Car parking

44 The Arena car park currently provides 140 dedicated surface car parking spaces. Adjacent to the Arena car park, the Virgin Active car park provides 75 parking spaces and the Stockley Park Golf Club car park provides 125 parking spaces. As part of the proposed development, the Arena car park will be increased by 20 spaces. TfL is not satisfied that this increase in car parking has been sufficiently justified. The parking survey results carried out over the seven days in May show that there are never less than 35 vacant spaces available across the site, with Stockley Park Golf Club having a considerable quantum of vacant spaces throughout the 24hrs, particularly at night when it is predicted that hotel car parking usage will be at its peak. Subsequently, TfL recommends that the applicant explores the possibility of leasing existing car parking spaces on site rather than further increasing parking quantum.

45 Given the number of proposed bedrooms in the hotel, one coach bay should be provided in line with London Plan’s parking standards. TfL asks that the bay with auto-tracking, showing the location of this bay should be submitted and secured by condition.

page 8 46 TfL expects there will be a minimal uplift in highway demand resulting from the development, and consequently a negligible impact on the highway network. Therefore TfL will not be seeking mitigation measures.

Cycle parking

47 Cycle parking is to be provided in line with the latest London Plan cycle parking standards, equating to 4 long-stay and 2 short-stay cycle parking spaces. Cycle parking should be covered against the elements for short-term and in a secure interior location for long-term parking (staff/guests). The applicant is requested to revise the proposed design of parking spaces to accommodate this, with the long-term cycle parking inside.

Construction and servicing

48 A framework Delivery and Servicing Plan will be required, along with a framework Construction and Logistics Plan. TfL requests that a workplace Travel Plan is prepared in order to encourage sustainable modes of transport. These documents should be secured via condition/s106. Sustainable development

Energy efficiency standards

49 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 will be improved beyond the minimum backstop values required by building regulations. Other features include energy efficient lighting, BMS systems, lighting controls and heat recovery.

50 The demand for cooling will be minimised through optimised pipe routes, limited glazed areas to prevent excessive solar gains and efficient MVHR systems. The applicant has provided the BRUKL worksheet according to which Criterion 3 is met. The applicant has additionally provided the actual and notional building’s cooling demand demonstrating reduction in the demand, in line with the Cooling Hierarchy.

51 The development is estimated to achieve a reduction of 5 tonnes per annum (3%) in regulated CO2 emissions compared to a 2013 Building Regulations compliant development. The applicant has however provided two separate BRUKL worksheets, one for the baseline and one for the ‘be lean’ scenario, none of which demonstrate compliance. The applicant should clarify why the TER as produced by the ‘be lean’ BRUKL is not being used for the notional building’s carbon performance and should also provide the full BRUKL files for each case.

52 According to the BRUKL worksheets provided, the development does not meet the Part L of the Building Regulations with passive design and energy efficiency measures only. The applicant should therefore model additional energy efficiency measures and commit to the development exceeding 2013 Building Regulations compliance through energy efficiency alone.

District heating

53 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development. Based on the London Heat Map the development is in an opportunity area located within a small distance from a proposed network. The applicant should therefore contact the local borough energy officer to determine

page 9 the current situation of this opportunity area, evidence of any correspondence should be provided to demonstrate that this has been fully investigated.

54 The applicant should provide a commitment ensuring that the development is designed to allow future connection to a district heating network should one become available. The applicant should also commit to installing a site heat network linking all uses on the site.

55 The applicant should confirm if a single energy centre is being proposed and provide further information on the energy centre such as its size (m2), its location and a layout.

Combined Heat and Power

56 The applicant is proposing to install a 40 kWth gas fired CHP unit. The CHP is sized to provide the domestic hot water load. A reduction in regulated CO2 emissions of 30 tonnes per annum (15%) will be achieved through this second part of the energy hierarchy.

57 Further information on the CHP should be provided including the total space heating and domestic hot water (DHW) demand of the development (MWh annually) and the proportion of heat met by the CHP. The applicant should also provide the analysis used to determine the size of the CHP including, suitable monthly demand profiles for heating, cooling and electrical loads. The plant efficiencies used when modelling carbon savings should be based on the gross fuel input for gas rather than the net values often provided by manufacturers.

Renewable energy technologies

58 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install ASHPs and Photovoltaic (PV) technologies.

59 The applicant is proposing a 3-pipe VRF heat pump system which allows simultaneous heating and cooling of rooms with heat being recovered from areas which are in cooling mode and used for heating other areas. In order to demonstrate compliance with the energy hierarchy the use of CHP should be optimised before considering the use of renewables for heating. Further information should be provided on how the ASHPs proposed will not impact on the optimisation of the CHP system and on ensuring that the development is designed to connect to district heating in the future.

60 The applicant is proposing to install a PV array of 50m2 (7.5 kWp) which is expected to produce circa 7.1MWh of electricity annually. A detailed roof layout should be provided indicating the likely location of the proposed PV.

61 A reduction in regulated CO2 emissions of 16 tonnes per annum (8%) will be achieved through this third element of the energy hierarchy.

Overall carbon savings

62 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.

63 A reduction of 51 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected, equivalent to an overall saving of 26%.

64 The carbon dioxide savings fall short of the target within Policy 5.2 of the London Plan. The applicant should consider the scope for additional measures aimed at achieving further

page 10 carbon reductions and compliance with the Part L of the Building Regulations through passive design and energy efficiency measures only.

Climate change adaptation

65 As discussed in the urban design section of this report, this scheme offers a valuable opportunity to introduce planting and soft landscaping to enhance the feel and appreciation of this site as Green Belt. Therefore, in accordance with the aims of London Plan policies 5.10, 5.11, 5.13, 7.19 and 7.21 the applicant is strongly encouraged to: provide replacement tree planting; introduce additional planting to soften the car parking area east of the Arena; and, provide a biodiverse green/brown roof. Collectively these greening measures will help to mitigate the urban heat island effect, and provide ecology and sustainable urban drainage benefits for the site. Full details of the urban greening measures should be secured by way of planning condition as well as the proposed drainage strategy. Community Infrastructure Levy

66 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly policies 6.5 and 8.3, which will contribute towards the funding of Crossrail. The Mayor has arranged boroughs into three charging bands. The rate for Hillingdon is £35/sq.m. The required CIL should be confirmed by the applicant and Council once the components of the development or phase thereof have themselves been finalised.

67 London Councils are also able to introduce CIL charges, which are payable in addition to the Mayor’s CIL. Hillingdon has adopted a CIL charging schedule and more details are available on the Council’s website. Local planning authority’s position

68 Hillingdon Council’s position is unknown at this time. Legal considerations

69 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, 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 (the next bit is optional) 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

70 There are no financial considerations at this stage.

page 11 Conclusion

71 London Plan policies on Green Belt, hotel development, employment, urban design, inclusive design, sustainable development and transport are relevant to this application. The application is broadly acceptable in strategic planning terms, however further information or action is needed on the matters set out below:  Green Belt: The applicant should respond to the issues raised in the urban design section of this report to ensure that the impact on Green Belt openness would be suitably minimised and mitigated in accordance with London Plan Policy 7.16.  Employment and training: The provision of jobs and training for local residents is supported in accordance with London Plan policy 4.12 and should be secured as a planning condition.  Transport: Further discussion, clarification and/or commitments as set out in paragraphs 43-48 of this report are sought with respect to car, cycle and coach parking; construction, delivery and servicing; and, travel planning, to ensure accordance with London Plan policies 6.3, 6.9, and 6.14 .

 Sustainable development: To ensure compliance with London Plan Policy 5.2, the applicant should address the issues raised under Climate Change (paragraphs 49-64) of this

report relating to the reduction of CO2. In addressing these matters close attention should be paid to the methodologies recommended in the same paragraphs. The applicant is also encouraged to explore further options for district networking in accordance with the aims of London Plan Policy 5.6. With respect to climate change adaptation, the applicant should incorporate urban greening and biodiversity measures to ensure accordance with London Plan policies 5.10, 5.11, 7.19 and 7.21.

72 Whilst the proposed hotel is supported, the proposed development does not yet comply with the London Plan. However, the resolution of the above issues could lead to the application becoming compliant with the London Plan.

for further information, contact GLA Planning Unit (Development & Projects Team): Stewart Murray, Assistant Director – Planning 020 7983 4271 email [email protected] Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Andrew Payne, Case Officer 020 7983 4650 email [email protected]

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