planning report D&P/4187/01 26 June 2017 Welbeck Street Car Park, Welbeck Street, in the planning application no. 17/01930/FULL

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 existing carpark and redevelopment to provide a new ten storey building for a 206-bedroom hotel with ground floor commercial use.

The applicant The applicant is Marylebone Lane LP, the agent is DP9 and the architect is Eric Parry Architects.

Strategic issues summary Principle of development: Redevelopment of the site to provide a 206-bedroom hotel within the CAZ is strongly supported (paragraphs 11-14). Sustainable development: Overall saving of 35%; however, further commitments/clarifications are required relating to BRUKL files, future proofing, communal networks and centralised energy centre, CHP details and cooling demand (paragraphs 20-22). Transport: Car free development welcomed; however, cycle hire docking capacity should be increased and a taxi rank provided, and drop off/pick up, coach and loading/unloading arrangements should be clarified and appropriately secured (paragraphs 23-27).

Recommendation That Westminster City Council be advised that whilst this application is broadly supported in strategic planning terms, the application does not yet comply with the London Plan for the reasons set out in paragraph 32 of this report. However, the resolution of these issues could lead to the application becoming compliant with the London Plan.

page 1 Context

1 On 22 May 2017, the Mayor of London received documents from Westminster City 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 30 June 2017 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 1C of the Mayor of London Order 2008:

 “Development which comprises or includes the erection of a building of (c) more than 30 metres high and is outside the .”

3 Once Westminster City 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 approximately 110 metres north of and is within the Central Activities Zone (CAZ). It sits at the junction of Marylebone Lane, Welbeck Street and Henrietta Place, and is currently occupied by a multi-storey carpark with retail use on the ground floor. The site is close to, but not within, the Stratford Place Conservation Area. There are, however, a number of listed buildings in proximity of the site including Stratford House and the Church of St. Peters, which are both Grade I listed, and the Grade II listed 8-10 Startford Place and 27-37 Wigmore Street.

6 The nearest section of the Transport for London Road Network (TLRN) is the A5 Edgware Road, which is 940 metres from the site; whilst the Strategic Road Network (SRN), Oxford Street, is 160 metres away. Twelve bus routes with a combined frequency of 110 services are available from three bus stops within 250 metres of the site. Additionally, Underground station is located 210 metres away, which is due to have Elizabeth Line services from 2018. The site therefore has a public transport accessibility level (PTAL) of 6b, which is the highest possible. This rating will be maintained following implementation of the central London bus review changes and Oxford Street Transformation project. The site is also located approximately 75 metres from a proposed quiet way route on Henrietta Place on the Central London Cycle Grid, and is within 100 metres of Marylebone Lane cycle hire docking station.

Details of the proposal

7 The applicant proposes to demolish the existing car park and erect a 10-storey (plus two basement levels) building to contain a 5-star hotel to be operated by Shiva Hotels Ltd, comprising:

 206 bedrooms (5,533 sq.m.);  signature restaurant at ground floor (344 sq.m.);  club lounge, spa and guest business facilities (837sq.m.); and,  auxiliary spaces (1,460 sq.m.).

page 2 Case history

8 GLA officers provided initial pre-application advice on this scheme on 24 February 2017, following a meeting held on 8 February 2017, covering issues with respect to: land use principles; employment and training; urban design; inclusive design; sustainable development/climate change; and, transport. The advice report (pre-application report reference number D&P/4187) issued by GLA officers concluded that the principle of providing a hotel at the scale proposed was supported in strategic terms; however, the issues raised in that report on employment and training, urban design, inclusive access, sustainable development/climate change mitigation and transportation would need to be addressed to ensure that the development complies with the London Plan. Strategic planning issues and relevant policies and guidance

9 The relevant issues and corresponding policies are as follows:

 Central Activities Zone London Plan; CAZ SPG;  Tourism/hotel London Plan;  Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG;  Inclusive design London Plan; Accessible London: achieving an inclusive environment SPG;  Transport London Plan; the Mayor’s Transport Strategy;  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.

10 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 Westminster’s City Plan: Consolidated with Basement and Mixed Use Revisions (2016); the saved policies in the Westminster Unitary Development Plan (2007, saved 2010); and The London Plan 2016 (The Spatial Development Strategy for London Consolidated with Alterations since 2011). The following are also relevant material considerations: The National Planning Policy Framework, Technical Guide to the National Planning Policy Framework and National Planning Practice Guidance. Principle of development

11 Achieving 40,000 net additional hotel rooms by 2036 is an objective of the London Plan as stated in Policy 4.5 ‘London’s visitor infrastructure’, with the Central Activities Zone (CAZ) identified as one of the preferred locations for the provision of hotels. The proposed scheme will deliver 206 bedrooms, which will contribute towards this target and is strongly supported.

12 The scheme is projected to deliver 220 new jobs (100 part-time and 120 full-time), and there will be a training and development programme for staff. This is welcomed; however, the applicant should submit a recruitment and training strategy that demonstrates how the development will continue to provide recruitment, training and employment opportunities during the lifetime of the development to people residing within the borough. This should be secured through a legal agreement.

13 The proposed development would result in the loss of 320 car parking spaces. This loss, however, would encourage sustainable travel behaviour in accordance with the London Plan and the Mayor’s Air Quality Strategy, which all emphasise the Mayor’s commitment to tackling air pollution and the role of public transport, walking and cycling in the process. Moreover, the applicant has submitted details of a car parking assessment, which concludes that due to low occupancy, the availability of other under-utilised car parks in the vicinity, and unlikely demand by page 3 residents, the loss of the car park would not adversely impact on-street or off-street parking. In view of the above, the loss of car parking spaces at this site is therefore supported at a strategic level.

14 In summary, the principle of replacing an under used multi-storey car park in the CAZ, with a high quality hotel providing 206 bedrooms is strongly supported in strategic planning terms.

Urban design

15 The proposal is not considered by GLA officers to cause any harm to neighbouring listed buildings. The scheme is well thought out and significantly improves on the existing condition, with servicing contained within the northern portion of the site to enable good levels of active frontage to all street facing edges. This is welcomed.

16 The applicant intends to link the scheme with wider public realm works focused on the junction of Marylebone Lane and Henrietta Place. This is welcomed. As suggested by GLA officers at the pre-application stage, an indicative design of the potential public realm is included in the design statement submitted with the application and it demonstrates how the ground floor layout would tie into these works, including alignment of all building entrances to secure consistency between the two.

Height and massing

17 The form and massing strategy is supported and broadly aligned with the scale of the existing car park, responding to the neighbouring context by stepping back from the western edge to mitigate overshadowing effects.

Appearance

18 The architectural response is welcomed and has been developed to achieve a sense of depth to elevations and a distinctive appearance in oblique views. The use of high quality ceramic tiles is supported, and, as noted at the pre-application stage, the applicant is encouraged to implement a refined colour palette. Inclusive design and access

19 Ten percent of the bedrooms will be wheelchair accessible in compliance with London Plan Policy 4.5, and provision will be made within accessible rooms for charging powered wheelchairs or mobility scooters. This is welcomed. Entry points and vertical and horizontal movement within the building have also been designed to be accessible. Sustainable development

Energy

20 Based on the energy assessment, an on-site reduction of 248 tonnes of CO2 per year in regulated emissions is expected, compared to a 2013 Building Regulations compliant development, equivalent to an overall saving of 35%, which meets the target within Policy 5.2 of the London Plan. However, additional information/commitments are required relating to BRUKL files, future proofing, communal networks and centralised energy centre, CHP details and cooling demand.

21 Full details of the outstanding issues relating to energy have been provided directly to the applicant and Council.

page 4 Flood risk and surface water run-off

22 A Flood Risk Assessment (FRA) has been undertaken, which confirms that the site is within Flood Zone 1; however, parts of the site are at risk of surface water flooding. A Sustainable Surface Water Report has been submitted with the application, which confirms that Sustainable Drainage Systems (SuDS) in the form of a greenroof and attenuation storage tanks will be provided. This proposed strategy accords with London Plan Policy 5.13 ‘Sustainable drainage’ and should be secured by condition. The incorporation of a greenroof into the design of the building also accords with London Plan Policy 5.10 ‘Urban greening’. Transport

Access and vehicle parking

23 The proposed car free development is welcomed. The applicant, however, should clarify the provision of Blue Badge parking and drop off/pick up for staff, guests and visitors with mobility difficulties. A formal taxi rank should also be provided.

Trip generation

24 The trip generation data submitted should be reviewed given that 23% of trips are expected to be by car despite the site’s central London location and care free nature of the development. In reviewing the data, deliveries should be disaggregated from this figure.

Walking and cycling

25 Legible London signage should be updated to improve wayfinding in the area and secured by condition. Whilst cycle parking meets minimum London Plan standards, the detailed arrangements should meet the London Cycle Design Standards and showers should be provided for staff who cycle. All cycle parking and cyclist facilities should be secured by condition.

26 To mitigate the scheme’s impact on the existing docking stations, a contribution of £75,000 towards increasing capacity via an extension to the docking station, either at Marylebone Lane or Chapel Place, should be secured.

Servicing and construction, and travel planning

27 The final servicing and delivery plan and construction management plan should both be secured by condition. The servicing and delivery plan should make clear that trips of this nature will not occur during the AM or PM peak, and also ensure pedestrian and cyclist safety. A full hotel travel plan, outlining measures to encourage active and sustainable modes of transport should be secured by s106 agreement. Community Infrastructure Levy

28 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly Policies 6.5 and 8.3 toward the funding of Crossrail. The rate for Westminster is £50 per square metre. Local planning authority’s position

29 Westminster City Council is assessing the application and officers are likely to recommend approval.

page 5 Legal considerations

30 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. 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

31 There are no financial considerations at this stage. Conclusion

32 London Plan policies on CAZ, tourism, urban design, inclusive access, sustainable development/climate change and transport are relevant to this application. Whilst the principle of the application is acceptable in strategic planning terms, on balance, it does not 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:

 Principle of development: The redevelopment of the site to provide a 206-bedroom, high quality hotel within the CAZ is strongly supported in strategic planning terms. The Council should secure a recruitment and training strategy that demonstrates how the development will provide recruitment, training and employment opportunities to people residing within the borough during the lifetime of the development.  Sustainable development/climate change: Overall saving of 35%, which accords with London Plan Policy 5.2; however, further commitments/clarifications are required relating to BRUKL files, future proofing, communal networks and centralised energy centre, CHP details and cooling demand.  Transport: Car free development is welcomed; however, cycle hire docking capacity should be increased and a taxi rank provided and drop off/pick up, coach and loading/unloading arrangements should be clarified and appropriately secured.

for further information, contact the GLA Planning Unit (Development & Projects Team): Juliemma McLoughlin, Assistant Director - Planning 020 7983 4271 email [email protected] Sarah Considine, Senior Manager - Development & Projects 020 7983 5751 email [email protected] Andrew Payne, Case Officer 020 7983 4650 email [email protected]

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