planning report D&P/3257a/01 28 September 2017 Morley House and City Temple, 26-30 Viaduct in the City of planning application no. 17/00165/FULMAJ

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

The proposal Redevelopment of the site including change of use of listed building to provide a seven and nine storey building comprising a 191-bedroom hotel and 1,646 sq.m. of flexible office workspace use.

The applicant The applicant is Morley GPCO Ltd and the architect is Eric Parry Architects.

Strategic issues summary Principle of development: The provision of a hotel and flexible workspace within the CAZ is strongly supported (paragraphs 13-17). Sustainable development: The carbon dioxide savings fall short of the target set within Policy 5.2 of the London Plan, and as such additional energy efficiency measures should be considered. (paragraphs 23-24). Transport: A contribution to cycle hire and a taxi rank should be secured. Cycle access, construction and servicing arrangements should also be clarified (paragraphs 25-30).

Recommendation That the be advised that while the principle of development is strongly supported in strategic planning terms, the application does not yet comply with the London Plan for the reasons set out in paragraph 34 of this report; but that the possible remedies set out in that paragraph could address these deficiencies.

page 1 Context

1 On 10 May 2017, the Mayor of London received documents from the City of London 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 Category 3E of the Schedule to the Mayor of London Order 2008:

• Category 3E: Development — (a) which does not accord with one or more provisions of the development plan in force in the area in which the application site is situated; and (b) comprises or includes the provision of more than 2,500 square metres of floorspace for a use falling within the following class in the Use Classes Order— (ix) class C1 (hotels).

3 Once the City of London has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal or allow the Council to determine it itself.

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 0.2-hectare application site is bounded to the north by Holborn Viaduct, to the east by Farringdon Street, to the south by Plumtree Court and to the west by Shoe Lane. The site is currently occupied by a 1980s-mixed use building referred to as Morley House and the Grade II listed City Temple Church. Morley House is vacant, apart from a charity organisation on a peppercorn lease. The building was predominantly in office use with some retail and temporary education uses. The City Temple church is currently used as a place of worship and has a suite of meeting rooms for hire.

6 The site is located within the Central Activities Zone. It is bound by several listed buildings, notably the viaduct’s Southwest Stair Pavilion (Grade II) immediately adjacent to Morley House and the Church of St Andrew Holborn (Grade I) that lies to the west of the site. The site is not located in a conservation area. The building also falls within the Protected Vistas from Assessment Points 4A.1 (Primrose Hill to St Paul’s Cathedral), 2A.1 (Parliament Hill to St Paul’s), 5A.2 (Greenwich Park to St Paul’s) and 6A.1 (Blackheath Point to St Paul’s).

7 Regarding transport, Holborn Viaduct is part of the Strategic Road Network (SRN) and Farringdon Street is part of the Transport for London Road Network (TLRN). It is also the route of the North-South Cycle Superhighway (CS6), which extends from Elephant and Castle to Stonecutter Street, approximately 150 metres to the south of the site. National rail (NR) services on Thameslink services are accessible from City Thameslink station 180 metres away. Chancery Lane London Underground (LU) station and Farringdon and Blackfriars LU and NR stations are also within reasonable walking distance. From 2018, will be served by the Elizabeth Line. Eight bus services stop adjacent or close to the site, and a further 10 are within walking distance. As such, the site records a public transport access level (PTAL) of 6b, representing excellent access to public transport. There are three cycle hire docking stations within 150 metres of the site.

page 2 Details of the proposal

8 Full planning and listed building consent is sought for the redevelopment of the site to deliver a part ground plus 9-storey and part ground plus 7-storey building for a hotel with 191 bedrooms to be operated by Shiva Hotels; and the change of use of the City Temple lower ground and mezzanine floors from non-residential institution to create additional floorspace at mezzanine level and provide 1,646 sq.m. of flexible office workspace, with associated new entrances, doors, canopies, plant and alterations to windows. The City Temple will continue to be used as a place of worship. Case history

9 A planning application for the demolition of 26-30 Holborn Viaduct (Morley House) and the erection of a part 9 and part 14-storey building for hotel (Class C1) use at levels 0-13 (226 bedrooms) (10,180 sq.m.) and retail/private leisure (Classes A3/D2) use (437 sq.m.) at levels 0-2 (GLA reference D&P/3257 and LPA reference.13/00747/FULMAJ) was submitted to the Council on 13 August 2013 and subsequently referred to the previous Mayor. Whilst the application was broadly acceptable in strategic planning terms, the application did not fully comply with some policies of the London Plan and the previous Mayor raised concerns over the relationship between the proposed development and the neighbouring listed buildings and the Goldman Sachs Headquarter building. This application was withdrawn on 16 December 2014 at the Corporation’s request following the sale of the building to enable the appointment of a new internationally renowned architect to address the earlier design issues. Strategic planning issues and relevant policies and guidance

10 The relevant issues and corresponding policies are as follows:

• Central Activities Zone London Plan; CAZ SPG; • Offices London Plan; • Social infrastructure London Plan; Social Infrastructure SPG; • Urban design and heritage London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG; Character and Context SPG; • 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; Mayor’s Transport Strategy.

11 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 City of London Local Plan (January 2015), and the 2016 London Plan (Consolidated with Alterations since 2011).

12 The National Planning Policy Framework (NPPF) and the National Planning Policy Guidance; the draft Mayor’s Transport Strategy; the draft City of London Corporation Local Plan Issues and Options: City Plan 2036 (September 2016); and, the City’s supplementary planning documents on Office Use (2015) and Protected Views (2012) are also material considerations.

page 3 Principle of development

13 London Plan Policies 2.10 and 2.11 aim to sustain and enhance the City of London as the iconic core of a strategically important, globally-oriented financial and business centre. The policies look to sustain and manage the Central Activities Zone’s varied strategic functions, especially its attraction as one of the world’s leading visitor destinations. Policy 2.11 further affirms the Mayor’s commitment and stakeholders’ obligation to seek solutions to the constraints on office provision and other commercial development imposed by heritage designations, without compromising local environmental quality. Moreover, 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. Locally, Policies CS1 and DM 11.3 of the City Core Strategy promote inward investment by encouraging developers and businesses to invest and locate in the City. The scheme will deliver 191 hotel bedrooms and 1,646 sq.m. of flexible workspace, and is therefore strongly supported.

14 The proposal will result in a net loss of 2,374 sq.m. of office space and 2,262 sq.m. of community use, comprised of 783 sq.m. of educational use from Morley House and 1,479 sq.m. of church use from City Temple. Whilst the London Plan does not specifically protect office uses, Policy 4.2 ‘Offices’ supports the rejuvenation of office stock within the Central Activities Zone (CAZ), and states that any losses of office space in the CAZ should be considered in the context of local policies and evidence. Regarding the loss of educational and church use, the objective of London Plan Policy 3.16 is to protect social infrastructure and it makes clear that the loss of such facilities should be resisted.

15 The applicant has submitted an Office Viability and Market Report, prepared by BNP Paribas, which shows that the building was actively marketed during the period 2012-2014 as a whole and in floors and suites for office, educational, retail and other alternative uses with little success. The report concludes that the building’s condition, specification, configuration and external appearance makes the building unattractive for potential tenants; and given the current uncertainty and projected market conditions, neither the refurbishment nor an office-led redevelopment of Morley House would be viable. The City of London’s independent assessment also concludes that it is not viable to use the site for office use. Given the above, the loss of office and education space is considered acceptable in this instance.

16 In terms of the church, the change of use at the lower ground and mezzanine floors will result in the loss of ancillary floorspace, which has been used periodically by the church to generate revenue. This floorspace, however, is of poor quality and its refurbishment and change of use to flexible workspace is aimed at providing income for the church to continue its ministry, as well as finance the proposed upgrades. In addition, refurbishment of the upper floors of City Temple is being considered under a parallel Ecclesiastical Exemption application for the provision of modern ancillary floorspace for use by the church and the public. It should be noted that the church will be temporarily relocated during construction; but all works within City Temple will be given priority over the hotel to ensure that disruption is minimal. This will be secured by a Grampian condition. In view of the existing poor quality of the floorspace, the need for the church to generate income to support its ministry and the expected improved church/community space to be provided on the upper floors under the parallel application, the proposed loss of church use is considered acceptable.

17 In summary, the provision of a hotel and flexible workspace on this site within the CAZ is strongly supported in strategic planning terms.

page 4 Urban, heritage and inclusive design

Site layout

18 The creation of a strong active frontage on the Holborn Viaduct is supported. Whilst Plumtree Court has a reduced level of active frontage, the need to provide essential services with direct street access is acknowledged and the degree of inactivity has been reduced as much as possible. Given that the new Goldman Sachs building opposite the site will provide active frontage to this stretch of Plumtree Court, the ground floor layout is considered acceptable.

Height, massing and architecture

19 The proposed scheme is below the threshold planes set for the Protected Vistas from Assessment Points 4A.1 (Primrose Hill to St Paul’s Cathedral), 2A.1 (Parliament Hill to St Paul’s), 5A.2 (Greenwich Park to St Paul’s) and 6A.1 (Blackheath Point to St Paul’s). The height and massing of the building acknowledges the existing context. The simplified facade treatment to Holborn Viaduct is supported; and the proposed choice of glazed materials reflects the adjoining and emerging character of the local area, which is welcomed. The City of London planning officers should seek to secure a high quality of design through conditions linked to facade details and material specification.

Heritage

20 The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the tests 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”. 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. Significance can be harm or loss through alteration or destruction of the heritage asset or development within its setting. In relation to non- designated heritage assets, the NPPF states that in weighing applications that affect non- designated heritage assets, a balanced judgement will be required.

21 As identified in paragraph 6 of this report, there are several designated heritage assets within the vicinity of the site. Having regard to the statutory duties in respect of listed buildings in the Planning (Listed Buildings and Conservation Areas) Act 1990, and the relevant paragraphs in the NPPF in relation to listed buildings, conservation areas and non-designated heritage assets, GLA officers consider that the building certainly exerts a greater impact than the c1980s stone and mansard office block by virtue of its greater height but not to a degree that significantly harms the settings of these listed buildings given that their towers/rooflines maintain their dominance. Additionally, the elevational quality and medium-rise scale of the proposed development should enhance the townscape of this stretch of Holborn Viaduct and have very limited impact upon the four conservation areas some distance away to the east, west and north. Regarding the change of use at lower ground and mezzanine floors within City Temple, it is considered that the proposed changes do not harm the significance of the building. The proposal therefore accords with London Plan Policy 7.8.

Inclusive design

22 In accordance with London Plan Policy 4.5, 10% of the hotel bedrooms will be designed to meet the need of wheelchair users, and accessible access to the hotel entrances will also be provided. This is welcomed.

page 5 Sustainable development

Energy

23 An on-site reduction of 125 tonnes of CO2 per year in regulated emissions is expected, compared to a 2013 Building Regulations compliant development, equivalent to an overall saving of 19%. The carbon dioxide savings fall short of the target within Policy 5.2 of the London Plan, as such the applicant should consider the scope for additional energy efficiency measures to achieve further carbon reductions. More information on overheating and the proposed CHP should also be provided. Full details of the outstanding issues relating to energy have been provided directly to the applicant and Council.

Flood Risk and surface water run-off

24 The site is within Flood Zone 1 and therefore the risk of tidal and fluvial flooding is low. There are, however, surface water flooding risks on and near the site, and a sustainable drainage strategy utilising an attenuation tank has been proposed. This approach is acceptable in accordance with London Plan Policy 5.13 and is welcomed. Transport

Access and servicing

25 An off-street servicing bay to be accessed from Plumtree Court is proposed. Given the proposed access controls on Plumtree Court, it will be important to manage servicing activity via a delivery and servicing plan with the off-street bay prioritised. A condition preventing coach bookings at the site should be secured, and a formal taxi rank should also be provided.

Car and cycle parking

26 Apart from one Blue Badge space, the development will be car free, which is welcomed. Long stay cycle parking is proposed in accordance with London Plan standards, with showers and lockers also provided. However, four short stay spaces should also be provided for each of the hotel and office uses. Finally, access to the cycle parking should be reviewed as the proposed route via steps would be inconvenient and unattractive.

Trip generation and cycle hire

27 To mitigate the impact of additional cycle demand arising from this development in accordance with London Plan Policy 6.9, a contribution of £187,000 for a 30-space docking station should be secured through the Section 106 agreement.

Construction

28 A construction management plan should be provided, and appropriate infrastructure protection conditions should be secured given the site’s proximity to Central line tunnels.

Other transport mitigation

29 The City of London is strongly encouraged to secure a contribution towards improved wayfinding facilities such as Legible London, particularly as the site would have entrances on different levels.

page 6 Community Infrastructure Levy and MCIL

30 In accordance with London Plan Policy 8.3, the Mayor has agreed a CIL Charging Schedule which came into operation on 1 April 2012. The Mayoral CIL rate for the City of London is £50 per sq.m. In these situations, the Mayoral CIL will be treated as a credit towards the section 106 Crossrail liability and this should be reflected in the wording of the section 106 agreement. The charge under the SPG that should be secured is therefore at least £706,929 based on 11,589 sq. m of net additional hotel floorspace charged at rate of £61 per sq. m. All other land use floorspace amounts would decrease due to the development. Local planning authority’s position

31 City of London planning officers are assessing the application and officers are likely to recommend approval. It is likely that the case will go to committee on the 24 October 2017. Legal considerations

32 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged or direct the Council under Article 6 of the Order to refuse the application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

33 There are no financial considerations at this stage. Conclusion

34 London Plan policies on the Central Activities Zone, offices, social infrastructure, visitor infrastructure, heritage, urban design, inclusive access, sustainable development and transport are relevant to this application. The principle of providing a hotel and flexible office workspace on this site is supported; however, the application does not fully comply with the London Plan and the following matters should be addressed:

• Principle of development: The provision of a hotel and flexible office workspace within the CAZ is strongly supported in strategic planning terms. • Sustainable development: Additional energy efficiency measures should be considered to address the shortfall in carbon savings. Further information on overheating and the proposed CHP should also be provided to confirm compliance with London Plan climate change policy. • Transport: A contribution to cycle hire and a taxi rank should be secured. Cycle access, construction and servicing arrangements should also be clarified.

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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] Shelley Gould, Strategic Planning Manager – Development Decisions 020 7983 4803 email [email protected] Andrew Payne, Case Officer 020 7983 4650 email [email protected]

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