planning report GLA/4529/01 & 4529a/01 14 January 2019 Olympia Exhibition Centre & Olympia Way in the London Borough of Hammersmith & Fulham planning application no. 2018/03102/OUT & 2018/03100/FUL
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 Full application for redevelopment of Olympia Exhibition Centre comprising demolition, refurbishment, extension and alteration to existing exhibition halls; erection of 13 storey buildings for office use; erection of 10 storey building on G-Gate site; partial demolition, alterations and extension of Maclise Road Car Park; roof level public realm deck; logistics centre; use of venue for exhibition, live music, theatre, restaurant/bar, retail, hotel, cinema, office, co-working and conference space. Outline application for erection of buildings up to 4 storeys on Olympia Way for flexible Class A1-A4, B1 and D1 space. The applicant The applicant is Olympus Property Holding Ltd and the architects are Heatherwick Studios and SPPARC.
Strategic issues Land use principle: The proposals to regenerate Olympia Exhibition Centre as a major visitor attraction, and new business, leisure and cultural quarter, enhancing London’s world city status, are strongly supported in principle by London Plan and draft London Plan policies (paras. 16-25).
Design and heritage: The proposals would introduce significant new build elements of significant scale and townscape impact, however the quality of the proposals is high, and the impact on the setting of heritage assets and the loss of historic fabric would result in less than substantial harm. Such harm is outweighed by the benefits of the proposals. Some further revisions to design are required (paras. 26-55).
Climate change and drainage: Additional technical information is required in relation to the applicant’s energy strategy and SuDS strategy (paras.59-62).
Transport: The significant increase in public transport trips must be appropriately mitigated: gateline capacity and facility enhancements at Kensington Olympia station and £1.8m contribution towards bus capacity improvements are required. Conditions and obligations to protect safety and operations on the transport network are required. Visitor car parking should be reduced to blue badge parking only (paras. 63-89).
Recommendation That Hammersmith & Fulham Council be advised that whilst the principle of the development is strongly supported, the application does not yet fully comply with the London Plan and draft London Plan, for the reasons set out in paragraph 92 of this report. However, the resolution of those issues could lead to the application becoming compliant with the London Plan and draft London Plan. Context
1 On 15 October 2018, the Mayor of London received documents from Hammersmith & Fulham 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 must 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 the following categories of the Schedule to the Order 2008:
• 1B(c): “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.”
• Category 1C: “Development which comprises or includes the erection of a building of…more than 30 metres high and is outside the City of London”
3 Once Hammersmith & Fulham 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 environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 has been taken into account in the consideration of this case.
5 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description
6 The application proposals relate to the Olympia Exhibition Centre, located to the north of Hammersmith Road within the London borough of Hammersmith & Fulham, close to the boundary with the Royal Borough of Kensington & Chelsea. The 4.8 hectare site is largely occupied by five main structures and a currently vacant plot of land to the south west, known as G-Gate. The main exhibition centre consists of two linked domed exhibition halls (known as the Grand Hall and the National Hall) which have entrances on to Olympia Way to the east and turn the corner on to Hammersmith Road. The Central Hall fronts on to Hammersmith Road with its distinctive 1930s façade. To the north of the site is the Pillar Hall and the former Maclise Road Car Park. To the west, fronting on to Blythe Road, is further exhibition space known as the West Hall (Olympia West), and the G-Gate site.
7 The Grand Hall and the Pillar Hall (formerly the Minor Hall) are Grade II* listed buildings. The National Hall, Olympia Central (formerly Olympia 2), and the Maclise Road Car Park are Grade II listed buildings. The site lies within the Olympia and Avonmore Conservation Area and is also adjacent to the boundaries of two other conservation areas: Brook Green to the north-west and Dorcas Estate to the south-west across Hammersmith Road. Other heritage assets in close proximity include the West Kensington Post Office building and Blythe House on Blythe Road.
page 2 8 Hammersmith Road forms part of the Strategic Road Network (SRN), and is served by a number of bus services providing frequent services to various destinations, including some 24 hour services. Kensington Olympia Station is located approximately 50 metres to the north east of the site, and is served by London Overground and Southern Rail services. London Underground services between Earl’s Court and Kensington Olympia are also periodically available; however, these services are limited, and normally scheduled around events at the Olympia exhibition centre and at weekends. The site is within walking distance (960 metres) of Baron’s Court and West Kensington London Underground stations, hence the site has a PTAL of between 5 and 6a, on a scale of 0 to 6b, where 6b is the highest. Details of the proposal
9 Full planning permission is sought (LPA ref: 2018/03100/FUL; GLA ref: 4259a) for the redevelopment of the Olympia Exhibition Centre site involving alterations and extensions to the existing exhibition space, and new build and conversion to create significant new office space as well as hotel, theatre, live music, cultural, restaurant and retail space. The proposals involve a new public realm deck at roof level, public realm at ground level and a logistics centre at ground and two basement levels under Central Hall. The full planning application comprises:
• Central Hall - demolition with retention of listed façade to Hammersmith Road, erection of new 13 storey building for office, exhibition, flexible (Class A1-A4) retail/financial and professional services /restaurant/bar, and flexible (B1/D1) office/conference uses, new site-wide logistics centre, car/cycle parking and plant within ground and two new basement levels; • G-gate site - erection of 10 storey building with two levels of basement for use as a theatre, exhibition and restaurant/bar use at ground/level and roof level; • National Hall - internal and external alterations comprising three storey roof-level extension for use as hotel, part use of National Hall for hotel and ancillary use, two levels of internal decks for use as exhibition space and restaurant/bar use, alterations to existing basement and associated internal and external works • West Hall - alterations and extension to provide two additional storeys for use as live music and performance space • Maclise Road Multi Storey Car Park - partial demolition, alterations and extension for use as hotel, cinema, and flexible co-working/conference use • Grand and National Halls - demolition of existing accommodation and circulation spaces between halls and construction of new Level 2 public realm deck with glazed canopy comprising flexible use (A1-A4) retail/restaurant/bar/financial and professional services; • Pillar Hall - Internal and external alterations for use of building for restaurant/bar use • Grand Hall - internal and external alterations including creation of two levels of internal decks for use as exhibition space and flexible exhibition/restaurant/bar use; • Plant and energy centres; pedestrian/vehicle/cycle/highway works; public realm, landscaping and associated works.
10 Separate listed building consent is sought for the above works to the listed buildings (LPA ref: 2018/03103/LBC).
11 A separate application for outline planning permission is also submitted (LPA ref: 2018/03102/OUT; GLA ref: 4259) for the erection of four storey commercial buildings on the eastern side of Olympia Way (on land owned by Network Rail). This is referred to the Mayor on the basis of paragraph 2 of the Schedule to the Order, as it forms part of more substantial proposed development on adjoining land. page 3 Case history
12 Whilst the exhibition halls have been subject to numerous planning and listed building consent applications for alterations, the only proposals that have been referable to the GLA were the applications at the G-Gate site in 2008 (revised in 2013) for the erection of a new 10 storey building for hotel use (LPA refs: 2008/00547/FUL and 2013/03806/FUL; GLA refs: 2137 & 2137a). The permission on this site has been implemented, but not fully built out. Strategic planning issues and relevant policies and guidance
13 The relevant issues and corresponding strategic policies and guidance are as follows:
• Land use principles London Plan; Culture & Night Time Economy SPG; Mayor’s Culture Strategy; • Urban design London Plan; Character & Context SPG; • Historic environment London Plan; • Inclusive access London Plan; Accessible London: Achieving an Inclusive Environment SPG; • Climate change, flood London Plan; Sustainable Design and Construction SPG; the risk and drainage London Environment Strategy • Transport London Plan; the Mayor’s Transport Strategy;
14 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 Hammersmith and Fulham Local Plan (2018) and the 2016 London Plan (Consolidated with alterations since 2011).
15 The following are also relevant material considerations: • The National Planning Policy Framework (2018); • National Planning Practice Guidance; • Draft London Plan showing minor suggested changes (August 2018) which should be taken into account on the basis explained in the NPPF. Principle of development
Culture, leisure and entertainment uses
16 London Plan Policy 2.1 states that the Mayor and the GLA group will ensure that London retains and extends its global role as a sustainable centre for business, innovation, creativity, health, education and research, culture and art and as a place to live, visit and enjoy. London Plan Policy 4.5 and draft London Plan Policy E10 seek to support and enhance London’s visitor infrastructure by extending the range and quality of provision, particularly in areas that are well served by public transport. London Plan Policy 4.6 and draft London Plan Policy HC5 seek to support and protect London’s cultural venues, and support the development of new cultural venues, in town centres and areas of good public transport accessibility. These policies are supported by the Mayor’s Culture Strategy and the Culture and Night Time Economy SPG which seek to protect and promote cultural uses in London.
page 4 17 Since the closure of Earl’s Court, Olympia is the only major exhibition centre in central London. The proposals seek to retain, refurbish and expand the cultural and commercial offer of the existing venue, enhancing its competitiveness as an international major exhibition and cultural venue. The proposals would refurbish the main exhibition halls, introducing internal mezzanine levels to enhance their flexibility and attractiveness to a wide range of exhibitors and events. The proposed new development surrounding the retained halls would include additional cultural uses, including a live music venue, rehearsal and studio space, a cinema and a major new theatre.
18 The proposals would introduce a significant increase in the quantum and quality of existing cultural and arts uses, and this is strongly supported in light of the above London Plan and draft London Plan policies.
Hotel and retail development
19 London Plan Policy 4.5 and draft London Plan policy E10 seek to focus new hotel development within the Central Activities Zone (CAZ) and town centres that are well connected to public transport. Policy 4.5 recognises that it may be appropriate to locate visitor accommodation outside of these areas where they are related to major visitor attractions of sub-regional or greater significance.
20 The proposals would introduce a 211 room hotel within the conversion of the Maclise Road car park, and a 123 room hotel as part of the extension to National Hall. Whilst the site is not within CAZ or a town centre, it is well connected to public transport, and the hotels would be directly related to the major new visitor attraction which, as set out above, would be of international importance. The provision of hotel uses on this site is therefore supported.
21 A total of 12,968 sq.m. of flexible Use Class A floorspace is proposed within the redevelopment, distributed throughout the exhibition complex and the Olympia Way outline proposals. The applicant would accept a maximum cap on Class A1 retail use of 2,100sq.m. (which would be distributed in smaller portions throughout the scheme), with the rest of the floorspace occupied by food and drink uses (Use Class A3/A4) and Class A2 financial and professional services. At just over 1% of the total floorspace within the development, the proposed retail floorspace is clearly ancillary to the commercial, entertainment and cultural uses, and would be provided to support the new office and visitor uses. The retail, plus the proposed food and drink uses would support the viability and competitiveness of the venue as a major visitor attraction and are supported in principle.
Office development
22 In addition to the exhibition space and cultural venues, the proposals seek to introduce up to 68,867sq.m. of new office development at the site (this figure includes 15,295sq.m. which is sought to be flexible use and could be occupied by other uses; the main element of office development proposed above Central Hall amounts to 53,572 sq.m.). London Plan Policy 4.2 supports increases in office stock in viable locations and where there is authoritative, strategic and local evidence of sustained demand for office-based activities. Draft London Plan Policy E1 states that new office development should be focused in town centres and other existing office clusters supported by improvements to public transport, walking and cycling.
page 5 23 The site is not in a designated town centre, and sits between the designated town centres at Hammersmith and Kensington High Street. However, the northern side of Hammersmith Road accommodates medium to large scale office development along its length stretching east from Hammersmith and forms a cluster of office space. The site has very good public transport accessibility as set out in paragraph 8 above. Kensington Olympia is recognised in the Council’s Local Plan as a positive asset in contributing to economic development (Hammersmith & Fulham Local Plan Policy E1). Given the nature of the proposed exhibition complex and its ancillary retail, leisure and food and drink uses, the site would function as a mixed use attraction, and this could support the level of office development proposed, subject to appropriate provision of transport capacity and mitigation of impacts as explained in the transport section below. Provided such mitigation measures are secured, the provision of a significant amount of office development is supported in principle.
24 In accordance with draft London Plan Policy E2 (C), the applicant should show how a proportion of low cost and flexible business space would be incorporated into the proposals to provide workspace suitable for small and medium sized enterprises.
Principle of development conclusion
25 The proposals would reinvigorate Olympia Exhibition Centre as a major business, leisure and cultural quarter, and would consolidate the complex as an iconic, world class visitor attraction for London, enhancing its world city status. The proposals are thus strongly supported in principle by London Plan and draft London Plan policies. Given the accessibility of the area to public transport, the introduction of significant new development can be supported in principle, subject to appropriate transport mitigation measures being secured, as discussed further in paragraphs 63- 89 below. Urban design and heritage
26 The design principles in chapter seven of the London Plan and Chapter 3 of the draft London Plan place expectations on all developments to achieve a high standard of design which responds to local character, enhances the public realm and includes architecture of the highest quality that defines the area and makes a positive contribution to the streetscape and cityscape.
27 London Plan Policy 7.8. and Policy HC1 of the draft London Plan states that development should conserve heritage assets and avoid harm. The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the statutory duties for dealing with heritage assets in planning decisions. In relation to listed buildings, all planning decisions should “have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses” and in relation to conservation areas, special attention must be paid to ‘the desirability of preserving or enhancing the character or appearance of that area’. The NPPF states that when considering the impact of the proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation and the more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting.
28 Where a proposed development will lead to ‘substantial harm’ to or total loss of the significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss. Where a development will lead to ‘less than substantial harm’, the harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.
page 6 29 The application is accompanied by a detailed heritage impact assessment that sets out the heritage significance of the various buildings on the site, the retention, demolition and refurbishment strategy, and the impact of the proposed new build elements on the setting of heritage assets.
30 Unlike previous applications at this site which have sought incremental alterations and piecemeal new build proposals on individual sites around the complex, a masterplan approach has been adopted to cover the entire site. This has followed the design rationale of retaining and refurbishing the most significant parts of Olympia, alongside the introduction of new build interventions which have an individual, but unified architectural style. Key drivers for the masterplan, other than an increase in the useable commercial and cultural floorspace, are to reduce the clutter and unwelcome accoutrements to the listed buildings, increase public routes through the site, and reduce congestion in surrounding streets caused by exhibition traffic. The masterplan- led approach to the redevelopment of this important venue is strongly supported in accordance with London Plan Policy 7.8 and 7.9, and draft London Plan Policy HC1.
Layout, routes and public realm
31 London Plan Policy 7.5, and draft London Plan Policy D7, seek to embed high quality and inclusive public realm at the heart of new development proposals. One of the most significant new interventions to the Olympia complex will be to create a decked area of public realm at roof level between the arched roofs of the exhibition halls. A new subservient domed roof would unify the two Victorian barrel vaulted roofs and would provide legibility to this route on the approach from Hammersmith Road. The applicant has provided further clarity and visuals of the roof level public realm, which show that a generous, well-lit arrival space would be created at this level. It must be ensured that the space feels genuinely public, open and welcoming to encourage visitors to access this route. For instance, public seating (separate from the commercial units) should be provided and secured in any planning permission, and 24 hour access should be secured.
32 Whilst the new area of roof level public realm is welcomed as a significant benefit of the proposals, pedestrians would access this space via stairs and/or escalators at either end of the route, and this limits the potential for a genuinely accessible and permeable route through the site. As discussed at the pre-application stage, opportunities for promoting an additional ground-level route running east-west should be fully exploited. However, the potential pedestrian route to the north of Pillar Hall has not yet been proposed on the submitted plans which is disappointing, and in general, the proposals for the L-Yard are the least resolved part of the masterplan. Further discussion is necessary to understand how more comprehensive development of this part of the site (including the building in separate ownership which has been left out of the application site boundary) will help deliver ground level public realm, a pedestrian route, and an improved frontage on to Blythe Road.
33 The proposed resurfacing and pedestrianisation of Olympia Way is a strongly welcomed part of the proposals, and is indeed vital to allow the site to accommodate the additional pedestrian footfall generated by the expanded exhibition space and visitor attractions. However, it is noted that these proposals form part of the outline application, with uncertain timescales for delivery due to land ownerships not being under the applicant’s control. Alternative proposals for securing the pedestrianisation of Olympia Way in the event of a delay to the grant or implementation of the outline application must be secured as part of the full masterplan application, and this should be discussed further with GLA officers prior to any Stage 2 referral.
page 7 Central Hall
34 The proposals would retain the Art Deco facade of Central Hall fronting on to Hammersmith Road, but the majority of the remaining building would be demolished and rebuilt to provide a new logistics centre at ground and basement centre and significant new office and exhibition space above. The loss of the interior of Central Hall does not raise concern from a heritage perspective given that this part of the building is utilitarian in nature and has been heavily altered in the past. It has been agreed with the Council and Historic England that the heritage value of Central Hall is confined to its distinctive facade, which would be repaired and restored to enhance its appearance and historic value.
35 The most significant area of new build in the scheme would be the proposed office development above Central Hall. This is composed of four curved, glazed building elements stepping up from 8 to 13 storeys above ground level. This part of the proposal has been significantly revised and scaled back through pre-application discussions. It is noted that the development is not within a town centre or Opportunity Area where London Plan Policy 7.7 generally directs tall buildings. The buildings would also not come forward as part of a plan-led approach as advocated by draft London Plan Policy D8, as this area is not identified in the Hammersmith & Fulham Local Plan as suitable for tall buildings. The site is within a conservation area, is close to other conservation areas, and will affect the setting of listed buildings. Further analysis of the impact of the proposed tall buildings is therefore necessary.
36 The applicant has modelled the proposals in key views as agreed with the Council, and has presented this analysis in a Heritage, Townscape and Visual Effect Assessment (HTVEA) submitted with the application. The site does not sit within any strategic London View Management Framework views. The views analysis shows that there would be significant impact on certain views from the surrounding conservation areas, particularly from Avonmore Road, Blythe Road and Sinclair Road (within the Lakeside, Blythe Road and Sinclair Road Conservation Area) where the buildings would alter the skyline above the historic development in the foreground. In these views, however, the high quality of the architecture would be apparent, and the new development would form a backdrop to the historic streetscapes without competing with the architectural features in the foreground. The impact of the proposals on local townscape views is acceptable in GLA officers’ opinion.
37 In terms of wider views, the office buildings would be visible above the tree line from the playing fields in Holland Park. The view towards the western boundary of Holland Park is defined by other visible buildings as well as trees, and the development would be a distant feature which would not appear incongruous in this view.
38 In GLA officers’ opinion, having had regard to the impact of the buildings in key townscape views, the principle of the tall buildings is acceptable. The buildings would be of high quality architecture which would mark and define this regenerated and important cultural venue of London-wide and national significance. The simple form and massing profile of the proposed buildings would create a distinctive and iconic landmark.
L-Yard
39 The proposals would introduce a new energy centre into this part of the site, which currently houses “back of house” and plant facilities. Whilst this is a logical position for this utilitarian building, the proposed large new flue site appears incongruously in views, especially from Sinclair Road, and is visible above the Grand Hall arch in views from Hammersmith Road. Further work is necessary to refine and reduce the impact of this element, in addition to revisiting the development strategy for L-Yard, as referred to in paragraph 32 above.
page 8 G-Gate and West Hall
40 A large new theatre is proposed on the currently vacant G-Gate site, on the corner of Lyons Walk and Hammersmith Road. Following pre-application discussions, refinements have been made to articulate the facades of the theatre box, which would be constructed from concrete and would have no window openings on the upper levels due to the nature of the use. Whilst this design development is appreciated, the building would be a large and prominent new feature in the local townscape and would appear particularly dominant in the view terminating North End Road. Further articulation to the upper levels should be discussed with officers and secured in any planning permission, including artwork and/or the potential to incorporate lettering to enhance the legibility of the building as a theatre. However, the proposals for this building at ground level, which would introduce double height windows framing a grand new staircase and civic space, are strongly welcomed as a significant improvement to the streetscape of Hammersmith Road.
41 On Blythe Road, major extensions to West Hall are proposed, creating a music venue and additional exhibition space in two new levels above the existing brick buildings. These extensions can be accessed from either Blythe Road or the proposed Central Walkway at Level 2. The extensions would be clad with bronze-coloured patterned rainscreen in a serrated design addressing the curve of the building, and would form a distinctive and high-quality feature in this part of the site.
Maclise Road Car Park proposals
42 The 1930s former Maclise Road Car Park has recently been listed Grade II in its own right. The proposals will involve substantial demolition of the building behind its retained northern facade. The applicant’s heritage impact assessment notes that the original use of the building as a car park is now redundant, that there are significant structural defects in the building and that any conversion of the building to bring it back into long term sustainable use will necessarily involve substantial demolition and rebuild. The loss of the original fabric of the building will necessarily cause harm to its significance, however, such harm would be less than substantial given that the development would retain and enhance the elevations of primary significance, and will secure the long-term future of the building by repairing its fabric and introducing a viable use. The justification for the loss of historic fabric is accepted by GLA officers.
43 It is proposed to demolish the southern part of the building which contains the stair core and foyer, which is of least architectural and historic significance, and will replace this with a curved brick elevational treatment which expresses the design and character of the retained elevations. It is also proposed to extend the building with three additional floors at roof level, set back from the retained brick structure and treated with contrasting lightweight glazing with serrated curved bays, reflecting the treatment of the new building element to the north.
44 The proposed alterations would form an attractive and distinctive corner building that draws from the form, proportions and architectural expression of the original car park building. The new build elements would also interface more successfully with the Grade II* listed Grand Hall and Pillar Halls compared to the stair core of the existing building, enhancing the setting of these important buildings. For these reasons, the proposed harm arising from the demolition of historic fabric is considered less than substantial, and would be outweighed by the benefits of the proposals.
page 9 National Hall, Grand Hall and Pillar Hall
45 The original Victorian exhibition halls (Grand Hall and the smaller National Hall) will be retained and enhanced with the removal of unwelcome additions which detract from the historic significance of these buildings. One of the major benefits will be the removal of the exterior ticket/security buildings and external steps in front of Grand Hall and the replacement with a civic square, restoring the facade and allowing full appreciation of the primary elevation of the most iconic building within the Olympia complex.
46 The interior of the halls would be subject to significant change with the introduction of two storey mezzanine decks at the far end of each hall, which would provide additional exhibition space on the first level and food and drink uses on the upper level. These decks are an important aspect of the rationale for the redevelopment of the site, which is to increase the quantum and flexibility of the exhibition space offered at Olympia and thus its competitivity on an international level. Whilst the mezzanine decks would alter the appreciation of the grandeur of the space within the halls, they have been sensitively designed to cause minimal structural intervention to the buildings, and would be supported on decorative steel supports which reflect the detailing of the original balcony and roof supports. The mezzanine would still allow the end window of the halls to be perceived from ground level and, by introducing visitor access to an upper level, would allow the historic significance of the roof and windows to be appreciated from a new, closer perspective. The rationale, design and impact of the proposed decks are therefore supported.
47 Above the Hammersmith Road frontage of National Hall, three additional storeys are proposed, and this part of the building would be converted to hotel use. The bronze-clad roof extension would be a distinctive design which is recognisably part of the same group of modern interventions to the Olympia complex but would retain a character of its own. The contrasting materials and the set-back from the facade of the retained listed building would ensure that the modern element would not compete with the architectural features or historic significance of the building.
48 The Grade II* listed Pillar Hall would be converted to restaurant use with minimal interventions. The restoration of this important building in the complex is strongly welcomed.
Olympia Way proposals
49 Outline proposals have been submitted for two and four storey buildings on the opposite side of Olympia Way, adjacent to the railway tracks. Other than the point raised in paragraph 33 about the need to secure appropriate public realm in the event of a delay in these proposals coming forward, there are no strategic concerns with these proposals.
Heritage assets outside the site
50 The buildings will affect the setting of the listed buildings on the site, and the listed buildings and other heritage receptors within 750 metres of the site, which are set out in detail in the applicant’s HTVEA.
51 With regard to the heritage assets surrounding the site, the proposals would be visible within the setting of 6,22 and 22a Avonmore Road (Grade II*), the K2 Telephone Kiosks on Olympia Way (Grade II), Blythe House (Grade II), the West Kensington Post Office and Delivery Office (Grade II); 6-9 Addison Bridge Place (Grade II); the West London County Court (Grade II), and 99-119 Hammersmith Road (Grade II). The development would not be visible within the setting of the other listed buildings identified within 750 metres of the site according to the applicant’s
page 10 assessment. Whilst the proposals would in some cases alter the background setting of these listed buildings, in no case would they compromise the viewer’s appreciation of the primary elevations of these buildings, or the architectural features that lend historic value.
52 There is one instance where the proposed development above Central Hall will cause some harm by altering the clear-sky backdrop to the east of the entrance towers above Blythe House. However, the view from the west along Blythe Road is not the principle viewpoint of importance to the setting of this building. The view is kinetic, and the viewer’s ability to appreciate the profile of the towers changes as the viewpoint moves along the street. The backdrop of the glazed buildings above Central Hall would reflect the sky and would still enable the profile of the entrance towers to be appreciated. For these reasons, the harm caused to the setting of this building is considered to be less than substantial, and outweighed by the benefits of the proposals as set out below. The development is not considered to cause harm to the setting of the other listed buildings outside of the site.
53 The development would impact on the setting of the Lakeside, Sinclair and Blythe Road Conservation Area, the Brook Green Conservation Area, the Dorcas Estate Conservation Area, the FitzGeorge and FitzJames Conservation Area, the Gunter Estate Conservation Area and the Holland Park Conservation Area. As addressed in paragraph 36 above, the new development proposed above Central Hall would have the most impact on the Lakeside, Blythe Road and Sinclair Road Conservation Area by appearing above residential terraces in some views. Whilst this impact is considered acceptable in general as it forms the backdrop to views and allows appreciation of the special architectural and historical interest of the Conservation Area, the proposed new flue on the L-Yard site should be rethought to reduce its dominant impact. The impact of the proposals on the other surrounding conservation areas is acceptable as the ability to appreciate the special interest of the conservation areas is unaffected.
Heritage assets within the site
54 As set out in the paragraphs above, having regard to the listed buildings on the site, it is acknowledged that some harm is caused by the loss of historic fabric, and the scale and massing of new development which would appear as new elements in the setting of historic assets. To some extent the new development could draw attention from significant architectural features such as the domed roofs of the exhibition halls. Such harm is considered, however, to be less than substantial, and Historic England has confirmed it shares this opinion on the degree of harm caused by the revised proposals. The harm is considered by GLA officers to be outweighed by the benefits of the scheme, which include the restoration, reuse and enhancement of the most significant heritage assets on the site, and the revitalisation of Olympia as a major arts and cultural venue and visitor attraction of London-wide and national importance.
Design and heritage conclusion
55 The comprehensive, masterplanned approach to restoring and redeveloping the Olympia site is strongly welcomed. The proposals would introduce new build elements with significant scale and townscape impact, however the quality of the proposals is high, and the new build elements would contribute to enhancing the status and architectural significance of the Olympia complex. The proposals would cause less than substantial harm to heritage assets within and outside the site, and such harm is outweighed by the benefits of the proposals. The proposals thus comply with London Plan and draft London Plan policies on design, heritage and heritage- led regeneration. As the quality of the architecture decisively weighs in favour of the proposals in an assessment of harm, the Council should secure an architect-retention clause within the s106 agreement, in accordance with draft London Plan Policy D2.
page 11 Inclusive design
56 Policy 7.2 of the London Plan and Policy D3 of the draft London Plan require developments to achieve the highest standards of accessible and inclusive design, and seek to ensure that new development can be used safely, conveniently and with dignity by all, and are welcoming with no disabling barriers to independent access or undue separation. The scheme has been designed to improve and integrate step-free access throughout the complex. Whilst the majority of the proposals do not raise inclusive design concerns in principle, there is some concern that step-free access to the proposed public realm at Level 2, which is proposed via lifts inside the buildings, would not be clearly legible or integral to the design of the general access arrangements. It must be shown how disabled people will be able to conveniently access this public realm via clear and unseparated routes.
57 It has been confirmed that 10% of the hotel rooms would be wheelchair accessible in accordance with the requirements of draft London Plan policy E10. This must be secured as part of any planning permission. The music venue and theatre will include suitable provisions for disabled visitors and performers.
58 A full inclusive design strategy, which will include details of access, wheelchair accessible provision for exhibition spaces, hotel, restaurant, offices and entertainment venues, and facilities to accommodate hearing and sight impairments at entertainment venues, must be secured and implemented as part of any planning permission.
Climate change
59 Based on the energy assessment submitted, an on-site reduction in CO2 emissions of 36% beyond 2013 Building Regulations compliant development, which exceeds the target within London Plan Policy 5.2.
60 These savings in CO2 emissions would be achieved through a range of passive design features and demand reduction measures, a CHP-powered energy facility on site and air source heat pumps. 850sq.m. of photovoltaic (PV) panels are also proposed. Further information has been requested in relation to technical aspects of the energy strategy, full details of which has provided to the applicant and the Council. The applicant should consider further passive and energy efficiency measures and outline the measures to future proof the site to allow for a future connection to a district heating network. In addition, further information is required on the heat pump technology and its performance, as well as analysis for the size of the 1MWth CHP proposed. The applicant is required to confirm that the NOx emission standards set out in the Mayor’s SPG on Sustainable Design and Construction will be met. The applicant should also outline any mitigation measures required to meet the NOx emission standards and demonstrate that the additional spatial requirements can be accommodated on site.
Flood risk and sustainable drainage
61 The site is located in Flood Zone 2, partly within an area benefiting from flood defences. The approach to flood risk management for the proposed development generally complies with London Plan policy 5.12 (and draft London Plan policy SI.12). The applicant should submit a further assessment of sewer flood risk at the site and additional information about proposed measures to mitigate sewer flooding where necessary. These measures should be secured by condition or as part of the Reserved Matters on the outline application.
page 12 62 The surface water drainage strategy for the proposed development does not comply with London Plan policy 5.13 (and draft policy SI.13), as it does not give appropriate regard to the drainage hierarchy and greenfield runoff rate. Further details on how SuDS measures at the top of the drainage hierarchy will be included in the development, and how greenfield runoff rate will be achieved should be provided. Full details of the further information requested has been provided direct to the applicant.
Transport
Trip generation and allocation
63 Following discussions between TfL and the applicant, the trip generation has been updated to include a public transport sensitivity test for the ‘worst case’. The trip allocation has also been updated to reflect recent survey data and the overall approach is now acceptable.
Public transport impact assessment
64 The public transport impact assessment has been undertaken for network and development peak hours in the AM and PM. These have been assessed by TfL and the following key outputs identified.
Kensington Olympia (Overground) station
65 Kensington Olympia (Overground) station will experience the biggest uplift in passenger trips (more than 1,500 additional trips in some peak hour scenarios) and will require the following mitigation: additional gates and all associated infrastructure, customer improvements to support passenger circulation and safety. Based on the updated trip information it is estimated that an additional eight gates will be required, the precise number of gates and the delivery costs are being developed through a pre-feasibility study currently being undertaken by TfL.
66 West Brompton station will also serve as a major interchange between the District line and London Overground for those travelling to and from Olympia. To support these additional trips a S106 contribution will be required towards delivering customer improvements. Again, the final figure will come out of pre-feasibility work currently being undertaken by TfL.
67 All costs for pre-feasibility and feasibility studies, design and delivery of the above works must be met by the developer and secured in the S106 agreement.
Buses
68 In addition to the impact on stations, the development proposals will generate a significant number of bus trips. A total of 516 and 848 two-way bus passenger trips are predicted in the AM and PM network peaks respectively. This equates to seven and eleven double deck buses in each peak. These are all ‘new’ trips on the network and cannot been catered for with existing capacity on the network. As such TfL requires developer funding for these trips for five years, the cost of which is £1.8m.
69 The above public transport mitigation is needed to mitigate the site-specific impacts of the development proposals and will need to be secured in the S106 agreement in line with London Plan policy 6.3 and draft London Plan policies T1 and T4.
page 13 Restoration of the District line
70 It is noted that the planning application calls for restoration of an all day service on the District Line to Kensington Olympia (District Line) station. However, the applicant’s Transport Assessment concludes that there is negligible impact of the proposal on existing tube services, and the District Line shuttle is not identified as mitigation for any impacts. Olympia is already well connected by rail (Overground and National Rail) with up to seven trains per hour in the peak. The area also has two LU stations within a ten minute walk of the venue: West Kensington (District line), and Barons Court (Piccadilly line). It is not considered that the restoration of the District Line is necessary as mitigation for the impact of the proposals.
Highway impact assessment
71 The highway impact has been assessed, taking account of the proposed changes to vehicular access including amended servicing arrangements; pedestrianisation of Olympia Way during core hours of the day; and additional journeys generated by the development. VISSIM modelling has been undertaken for six different scenarios. The modelling was undertaken in the context of CS9 proposals along Hammersmith Road and therefore ‘with CS9’ and ‘without CS9’ scenarios were tested.
72 CS9 is a strategic cycle route planned to run from Kensington Olympia to Brentford, along Hammersmith Road, directly past the Olympia site. Delivery is planned for Spring/Summer 2021, this would coincide with the construction of these proposals. The draft London Plan and Mayor’s Transport Strategy clearly emphasise the importance of delivering healthy streets and reducing vehicle dominance in London, including through cycle routes such as CS9. As such, any temporary and permanent changes to the highway on Hammersmith Road that impact the ability for it to deliver against Healthy Streets objectives need to be fully justified to show that the best access solution, minimising adverse impacts on the transport network has been identified.
73 The VISSIM models are currently being reviewed and audited by TfL. Once the models have been signed off, TfL and LBHF highway officers will review the outcomes on a multi-modal basis and provide comments on the acceptability of the proposals, including the applicant’s preferred option to signalise the Hammersmith Road / Blythe Road junction, on the highway network.
74 As set out above, further discussion is needed to reach agreement on a highway solution that will deliver across a range of policy objectives including network performance, Healthy Streets and Vision Zero. Following this, interim (construction phase) and permanent highway schemes for Hammersmith Road, supporting delivery of CS9, will need to be secured and delivered via a S278 agreement with the Council in accordance with London Plan policy 6.3 and draft London Plan policies T1, T2, T3, T4 and T5.
Healthy Streets
75 The Healthy Streets Approach is embedded in draft London plan policy T2 and the MTS. The TA should include a full review of the proposals against the Healthy Streets indicators as requested in pre-application discussions.
page 14 76 The proposed pedestrianisation of Olympia Way with two-way cycling access as set out in the TA has the potential to enhance pedestrian and cycle connectivity and support the high numbers of pedestrian movements associated with the enhanced exhibitions uses and new land uses on the site. Given the importance of Olympia Way as a gateway to the development, and as outlined above in paragraph 33, it is essential that an obligation is placed on the developer to deliver significant pedestrian, cycle and public realm improvements to cater for the predicted flows, either as part of the standalone masterplan development of the Exhibition Centre, or as part of the outline Olympia Way application.
77 The Council must secure relevant improvements to pedestrian facilities identified by the PERS (pedestrian environment review system) audit in line with London Plan policies 6.9 and 6.10 and draft London plan policy T2.
Car parking
78 Draft London Plan policy T6 requires the development to be car-free except for parking for disabled persons, essential operational and servicing spaces. This continues the policy approach set out in adopted London Plan policy 6.13.
79 There are currently 380 car parking spaces within the red line boundary. The proposal to convert the existing multi-storey car park to a hotel will reduce this to 181 spaces located within the basement of the exhibition centre to cater for blue badge holders, exhibition visitors and exhibitors. Whilst the reduction in car parking is acknowledged compared to the existing scenario, the provision of 181 car parking spaces in this highly accessible location is an over provision based on draft London Plan policy. The re-provision of spaces based on perceived demand is contrary to draft London Plan policy. Visitor car parking other than that for disabled persons is not supported and should be removed from the proposals. Vehicles accessing and egressing the basement car park as proposed via D Gate will conflict directly with movements on CS9. Draft London Plan policy T3 includes a requirement for development proposals to support Vision Zero (to reduce danger on London’s streets so that no deaths or serious injuries occur) therefore the applicant must demonstrate that the proposals appropriately minimise and manage potential conflicts with vulnerable users. This will be progressed through reviewing the highway proposals and associated modelling.
80 Electric vehicle charging points and a Car Park Design and Management Plan for the final level of parking should be secured in line with draft London Plan policy T6.
Cycle parking
81 Long and short stay cycle parking for all land uses will be provided in line with the standards contained in draft London Plan policy T5, which is welcomed. Showers, lockers and changing facilities are also proposed. This provision should be secured as part of any permission and subsequently designed and provided in accordance with the London Cycle Design Standards (LCDS).
Cycle Hire
82 Cycle hire docking stations are currently available on Olympia Way and Maclise Road. Demand for these facilities will increase as a result of these proposals and as such mitigation of £200,000 is required to deliver additional capacity in the vicinity of the site in line with London Plan policy 6.9 and draft London Plan policy T3.
page 15 Construction
83 The planned five year construction programme will have significant impacts on the transport network, with the construction access and pit lanes planned to be on Hammersmith Road. The submitted Framework Construction Logistics Plan (CLP) is welcomed and the strategies will need to be formalised through highway modelling, with caps / restrictions on vehicle movements at peak times to protect the operation and safety of the transport network implemented. The final CLP will also need to incorporate provision of the aforementioned interim cycling solution to deliver a continuous high quality cycle route in advance of the permanent scheme.
84 Similarly, Demolition Waste Management Plan will also be required to cover this element of the build. Requirements for both plans, including sign off by TfL, should be attached to any permission accordance with London plan policy 6.3 and draft London Plan policies T4 and T7.
Travel planning
85 Full travel plans for each land use should be secured as part of any permission in line with the London Plan policy 6.3 and draft London Plan policy T4. TfL recommends that this includes a full update of the existing travel plan for the exhibition space to ensure the most recent guidance and mode share targets are reflected.
Delivery and servicing
86 A framework Delivery and Servicing Plan (DSP) has been submitted in support of the application and the proposals include the creation of a new logistics hub at ground floor level to cater for the majority of delivery and servicing activity. Final DSPs for all land uses should be secured and submitted for approval by the Council and TfL prior to occupation, in line with London Plan policy 6.14 and draft London Plan policies T4 and T7. These will need to commit to reducing and managing servicing movements at peak times and protecting vulnerable road users including those on CS9 and Olympia Way.
Mayoral Community Infrastructure Levy
87 In accordance with London Plan policy 8.3, Community Infrastructure Levy, the Mayor commenced CIL charging for developments on 1st April 2012. The proposed development is within the London borough of Hammersmith & Fulham, where the Mayoral charge is £50 per square metre Gross Internal Area (GIA).
88 In June 2017, the Mayor published proposals for an MCIL2 to contribute to Crossrail 2 funding which would be levied from April 2019. The applicant should ensure they are fully aware of the regulations.
S106 agreement
89 To conclude, a series of planning obligations and conditions are required to mitigate the site-specific transport impacts of the development and make the application acceptable in strategic transport planning terms and to meet relevant adopted and emerging London Plan policies. Given the scale of the transport mitigation required, TfL will need to be a signatory to the S106 agreement and will require an undertaking that all associated costs will be covered by the applicant.
page 16 Legal considerations
90 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
91 There are no financial considerations at this stage.
Conclusion
92 London Plan and draft London Plan policies on culture, leisure, visitor and office use; heritage, urban design, climate change, flood risk and sustainable drainage and transport are relevant to this application. Whilst the principle of the application is strongly supported, the scheme does not yet fully comply with the London Plan and draft London Plan. However, the following changes might lead to the applications becoming compliant:
• Land use principle: The proposals to regenerate Olympia Exhibition Centre as a major visitor attraction, and new business, leisure and cultural quarter, enhancing London’s world city status, are strongly supported in principle by London Plan and draft London Plan policies.
• Design and heritage: The proposals would introduce significant new build elements of a high quality. The design, height and massing of the proposals are supported. The new buildings would result in less than substantial harm to heritage assets, and such harm is outweighed by the benefits of the proposals, which include the refurbishment and enhancement of historic buildings and the restoration of the venue to its original iconic status. The design should be further developed in terms of promoting a route through L- Yard, revising the design of the new flue, and introducing further articulation to the G-Gate theatre box. Additional information on inclusive design is also required.
• Climate change: Additional technical information is required in relation to the applicant’s energy strategy. Further passive and energy efficiency measures should be considered. The applicant should outline the measures to future proof the site to allow for a future connection to a district heating network. In addition, further information is required on the heat pump technology and its effect on air quality.
page 17 • Sustainable urban drainage: In line with the London Plan drainage hierarchy, further details on how SuDS measures at the top of the drainage hierarchy will be included in the development, and how greenfield runoff rate will be achieved, should be provided before the application can be considered fully compliant with London Plan Policy 5.13 and Policy SI.13 of the draft London Plan.
• Transport: The development proposals will generate a significant number of additional trips on the public transport network and these will need to be mitigated accordingly. Key requirements include additional gateline capacity and customer facility enhancements at Kensington (Olympia) station, £1.8m for bus capacity improvements and £20,000 for cycle hire. Temporary and permanent highway schemes, catering for Cycle Superhighway 9 must be secured. Planning conditions and obligations are required to protect safety and operations on the transport network; and car parking for the exhibition use should be limited to operational needs and disabled persons only.
for further information, contact GLA Planning Unit: Juliemma McLoughlin, Chief Planner 020 7983 4271 email [email protected] John Finlayson, Head of Development Management 020 7084 2632 email [email protected] Nick Ray, Team Leader 020 7983 4178 email [email protected] Katherine Wood, Team Leader (Case Officer) 020 7983 5743 email [email protected]
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