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Heritage Statement the Dilly, 21 Piccadilly, City of Westminster, London, W1J 0BH

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Heritage Statement the Dilly, 21 Piccadilly, City of Westminster, London, W1J 0BH Heritage Statement The Dilly, 21 Piccadilly, City of Westminster, London, W1J 0BH January 2021 Contents 1. Introduction 3 2. Review of Application Scheme 5 Appendix: Baseline Heritage Appraisal 10 Our Reference RODH3004 Date January 2021 1. Introduction 1.1 This Heritage Statement report has been prepared by Turley Heritage to provide relevant and proportionate information to the local planning authority, the City of Westminster, with regard to heritage impacts, and to accompany an application for listed building consent in relation to upgrade of doors, doorframes and door surrounds at the former Piccadilly Hotel (currently known as The Dilly), Piccadilly (‘the Site’). The Site is a Grade II* listed building, which is located within the Regent Street Conservation Area. 1.2 The requirement for this report stems from Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990, which places a duty upon the local planning authority in determining applications for development or works that affect a listed building to 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. It is also a duty, with regard to applications within conservation areas, to pay special attention to the desirability of preserving or enhancing the character or appearance of that area. 1.3 The National Planning Policy Framework (NPPF) 2019, which provides the Government’s national planning policy for the conservation of the historic environment, also directs local planning authorities to take account of the desirability of sustaining and enhancing the significance of all heritage assets1 and outlines that local planning authorities should give great weight to the assets’ conservation when considering the impact of a proposed development on the significance of a designated heritage asset.2 Designated heritage assets include listed buildings, conservation areas and registered parks and gardens.3 1.4 In respect of information requirements, the NPPF sets out that ‘In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance.’ 4 1.5 Paragraph 190 then sets out that local planning authorities should also identify and assess the particular significance of heritage assets that may be affected by proposals. They should take this assessment into account when considering the impact of proposals in order to avoid or minimise conflict between the heritage asset’s conservation and any aspect of the proposal. 1.6 This report should be read in conjunction with the Baseline Heritage Appraisal, prepared by Turley Heritage and appended to this Heritage Statement, which provides statements of significance for the heritage assets that have the potential to be affected by these proposals – namely, the Grade II* listed building of the former Piccadilly Hotel and the 1 MHCLG, National Planning Policy Framework (NPPF) 2019 – para. 192. 2 MHCLG, National Planning Policy Framework (NPPF) 2019 – para. 193. 3 MHCLG, National Planning Policy Framework (NPPF) 2019 - Annex 2: Glossary. 4 MHCLG, National Planning Policy Framework (NPPF) 2019 – para. 189. 3 Regent Street Conservation. Read together, both reports are intended to act as a shared resource to better inform the decision-making process. 1.7 This Heritage Statement should also be read in conjunction with the full package of drawings and accompanying documentation prepared by Rodić Davidson Architects. 1.8 The purpose of these proposals is to ensure compliance with the Regulatory Reform (Fire Safety) Order 2005 and The Building Regulations 2010 Approved Document B: Fire Safety, while minimising impacts on the special interest of the listed building. 1.9 The following section of this report undertakes a review of the application proposals, and describes their likely impacts on the significance of the identified designated heritage assets, as informed by the assessments of significance contained within the Baseline Heritage Appraisal, and also in light of the relevant heritage legislative, planning policy and guidance context for such change. 4 2. Review of Application Scheme 2.1 The purpose of these proposals is to provide essential upgrades to the building to protect the health and safety of its users and thereby ensure compliance with the Regulatory Reform (Fire Safety) Order 2005 and The Building Regulations 2010 Approved Document B: Fire Safety, while minimising impacts on the special interest of the listed building. 2.2 The works comprise the replacement of 239 doors and doorframes associated with guest rooms on floors 2 to 6. The application covers the first phase of a broader scheme of door replacement covering 680 plus doors requiring upgraded fire rating. The doors and door frames to be replaced in this application are fire doors dating from the late 20th century (refer to Door Schedule prepared by Rodić Davidson Architects, accompanying this application) and, most likely, they are the fire doors shown on the 1984 Cobban & Lironi plans (see Figures 2.1 and 2.2). 2.3 These doors fall under one single typology and the methodology for of removal and replacement will be consistent throughout (as detailed in the methodology for door upgrades contained in the accompanying Design and Access Statement prepared by Rodić Davidson Architects). The proposed methodology will involve the careful removal of architraves from only one side of the doorway to enable to replacement of the doorframe. The architrave will then be re-instated into the original position. Where re- instatement is not possible (due to existent damage, or splitting on removal), then the existing architrave will be digitally scanned to gain an exact match to the original timber profile, and a new architrave machined to match like for like. Figure 2.1: 1984 3rd floor plan from refurbishment scheme carried out by Cobban & Lironi (LMA) 5 Figure 2.2: Detail from 1984 3rd floor plan from refurbishment scheme carried out by Cobban & Lironi, indicating fire doors (abbreviated ‘FD’) (LMA) 2.4 The doors and door frames of the guest rooms are identified as of late-20th-century origin. However, a number of sympathetic door surrounds survive throughout the building, particularly at second floor (Figure 2.3). Figure 2.3: Historic door surround, with sympathetic late-20th-century door and doorframe at second floor 6 2.5 The proposals would see the late-20th-century doors and doorframes replaced, in order to ensure compliance with Building Regulations. These alterations would support the building’s original hotel use, which would be a heritage benefit. 2.6 It is proposed to retain historic or sympathetic door surrounds, where possible. However, because of the construction of the door surround and door frame, it is acknowledged that there is the potential for irreversible damage to occur to the door surround during removal of the door frame. If this occurs, it is proposed to replace the door surround like-for-like. In this way, removal of historic fabric will be minimised. 2.7 The significance of the former Piccadilly Hotel is principally derived from its mostly intact external fabric and appearance, presenting grand frontages in particular to Regent Street but also to Piccadilly, as a key part of the wider townscape composition and where R. Norman Shaw’s original design intent is most readily appreciated. The interiors of the listed building make a comparatively lesser contribution to the significance of the listed building, as they are not attributed to Norman Shaw and have undergone a higher degree of alteration. In the case of the doors and door frames of the guest rooms proposed for replacement, these are identified as of late-20th-century origin and contribute very little to the significance of the listed building as a whole. 2.8 Accordingly, and notwithstanding the limited removal of historic fabric that may eventuate from the proposed works, the significance of the listed building would, overall, be sustained. Were such works to be perceived as resulting in a degree of harm to the heritage significance of the listed building by Council officers, such harm could reasonably be considered to be at the lower end of the scale of ‘less-than-substantial’ harm, as detailed by the NPPF and the NPPG. Such harm should be considered in the round, alongside the considerable public benefit that would be provided as a result of the essential upgrade of the door furniture to ensure compliance with building regulations. Review of Legislation and Policy Statutory Duties The Planning (Listed Buildings and Conservation Areas) Act 1990 2.9 The Planning (Listed Building and Conservation Areas) Act 1990 requires special regard to be had to the desirability of preserving the listed building and special attention to be paid to the desirability of preserving or enhancing the character or appearance of the conservation area. The meaning of preservation in this context, and as informed by case law, is taken to be the avoidance of harm. Accordingly, it is demonstrated in this report that the application proposals will accord with these statutory duties, and will, overall, preserve the special interest of the listed building. The works are confined to the interior of the building, and would have no impact on the character or appearance of the surrounding conservation area, which would, accordingly, be preserved. National Policy and Guidance NPPF 2019 and NPPG 2.10 In accordance with the requirements of paragraphs 189 and 190 of the NPPF 2019, the significance of the affected designated heritage assets of the Grade II* listed former 7 Piccadilly Hotel and the Regent Street Conservation Area, which have the potential to be affected by these application proposals, have been described in a proportionate manner in the Baseline Heritage Appraisal accompanying this report.
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