Horse Guards Parade

planning report PDU/2673/02 2 March 2011 Horse Guards Parade

in the London Borough of Westminster planning application no. 10/09157/FULL

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

The proposal Temporary use of Horse Guards Parade, St James Park and the Mall for the Olympic and Paralympic beach volleyball and road events. Comprising a temporary 15,000 seat beach volley ball arena, 2 warm up courts, 6 practice courts, a second spectator stand for 3,000 people with associated front and back of house services. The applicant The applicant is the London Organising Committee for the Olympic and Paralympic Games. The architects are Populous, Allies and Morrison and Lifschutz Davidson Sandilands.

Strategic issues The principle of the development to provide sporting facilities for the Olympic and Paralympic Games is in the interest of good strategic planning in London. The application is consistent with London Plan policy.

The Council’s decision

In this instance Westminster City Council has resolved to grant permission. Recommendation That Westminster City Council be advised that the Deputy Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal.

Context

1 On 8 November 2010 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. This was referred to the Mayor under Category 3D of the Schedule to the Order 2008: ”Development on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or

page 1 replacement of such a plan and which would involve the construction of a building with a floorspace of more than 1,000 square metres or a material change in the use of such a building.” .

2 On 15 December 2010 the Deputy Mayor considered planning report PDU/2673/01, and subsequently advised Westminster City Council that whilst the application is broadly acceptable in strategic planning terms, further information and discussion is required on transport.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. On 13 January 2011 Westminster City Council decided that it was minded to grant planning permission, and on 17 February 2011 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged or direct Westminster City Council under Article 6 to refuse the application. The Mayor has until 2 March 2011 to notify the Council of his decision and to issue any direction.

4 For this application the Mayor has delegated his planning function to Sir Simon Milton, Deputy Mayor for Policy and Planning. This report sets out information for the Deputy Mayor’s considration in deciding what decision to make.

5 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

6 At the consultation stage Westminster City Council was advised that whilst the application is broadly acceptable in strategic planning terms, further information and discussion is required on transport. Transport for London’s comments

7 TfL is satisfied that the proposed temporary use of Horse Guards Parade, St James’s Park and The Mall for the Olympic Beach Volleyball and Road Events does not present any transport issues of strategic importance but will require continuing discussions to take place between TfL, LOCOG, the ODA and Westminster City Council in relation to the necessary transport management issues such as crowd management and safe access to and from the local Underground Stations and bus services. TfL note that permission does not discharge the requirements under the Traffic Management Act 2004 and formal notifications and approval may be needed for any associated temporary highway works required. Other comments

8 English Heritage has no objection to the granting of planning permission subject to conditions being imposed upon any planning permission granted relating to the safeguarding of listed structures.

9 The Royal Parks supports LOCOG’s planning application to host the events in St James Park and will continue to work with LOCOG in it preparations to stage world-class events in 2012.

10 CABE offers a warm welcome to the proposals for the 2012 Olympic beach volleyball events. The design for temporary facilities show evidence of thorough work by LOCOG, in partnership with a wide range of organisations, including the Royal Parks.

11 St James Conservation Trust supports the Olympics and takes pride in the fact they will take place in its area. However, it requests adequate measures to safeguard listed buildings,

page 2 statues and items, measures to reduce the hot spot of noise nuisance at Marlborough House. It also requests that St James Park, The Mall and Marlborough House be re-opened to the public as soon as it is feasible. Measures are adequately taken to police the area and effective road and footway cleaning and toilets are provided.

12 The Thorney Island Society’s overall concern is that the holding and accommodating of the games should cause the minimum of damage and disturbance to all aspects of the environment and local residents, and that the Park and adjoining areas will be retuned to the agreed status, and at no cost to the residents of Westminster.

13 The Westminster Society is disappointed at the extent to which the venue will intrude into St James Park and the inclusion of Marlborough Road, which will increase potential traffic issues over a wide area. At 19 metres in height the stands will be dominant in relation to existing buildings.

14 Westminster City Council also received eight letters of objection and one letter of support for the proposal. Objections relate to:

 Parking.  Access to and across St James Park during the Games.  The walkway on Marlborough Road is too small.  Impact on wildlife.  St James Park should be restored to its original condition.  Location of operation compound in the south east corner of the park.  Residents should have access to their homes at all times with no security checks.  Clarification of media and seating locations in relation to private dwelling homes.

15 The letter of support states that it is an excellent plan and that St James Park and the surrounding roads and buildings will provide a splendid London backdrop to these events. Response to consultation

16 Issues relating to design, access, transport, biodiversity and the reinstatement of the park have been addressed in this and the previous report.

17 Localised parking and residential amenity issues have been assessed by Westminster City Council. Legal considerations

18 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. The Mayor must also have regard to the guidance set out in GOL circular 1/2008 when deciding whether or not to issue a direction under Articles 6. Financial considerations

page 3 19 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

20 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy. Conclusion

21 The principle of the development to provide sporting facilities for the Olympic and Paralympic Games is in the interest of good strategic planning in London. The application is consistent with London Plan policy.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager – Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Kim Hoffman, Case Officer 020 7983 6589 email [email protected]

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planning report PDU/2673/01 15 December 2010 Horse Guard Parade

in the London Borough of Westminster planning application no. 10/09157/FULL

Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008 The proposal Temporary use of Horse Guards Parade, St James Park and the Mall for the Olympic and Paralympic beach volleyball and road events. Comprising a temporary 15,000 seat beach volley ball arena, 2 warm up courts, 6 practice courts, a second spectator stand for 3,000 people with associated front and back of house services. The applicant The applicant is the London Organising Committee for the Olympic and Paralympic Games. The architects are Populous, Allies and Morrison and Lifschuntz Davidson Sandilands.

Strategic issues The principle of the development to provide sporting facilities for the Olympic and Paralympic Games are in the interest of good strategic planning in London. The application is broadly consistent with London Plan policy on Metropolitan Open Land, views, urban design, access, biodiversity and sustainability. Discussions regarding transport are ongoing between TfL, the borough and the ODA to address the outstanding issues.

Recommendation

That Westminster City Council be advised that whilst the application is broadly acceptable in strategic planning terms, further information and discussion is required on transport.

Context

1 On the 8 November 2010 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 17 December 2010 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. For this application the Mayor has delegated his planning function to Sir Simon Milton, Deputy Mayor

page 5 for Policy and Planning. This report sets out information for the Deputy Mayor’s use in deciding what decision to make.

2 The application is referable under Category 3D of the Schedule to the Order 2008: ”Development on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan and which would involve the construction of a building with a floorspace of more than 1,000 square metres or a material change in the use of such a building.”

3 Once 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 comprises parts of St James’s Park including Horse Guards Parade, The Mall, Marlborough House and gardens, and Admiralty House. It extends to 13 hectares and is bounded by Pall Mall and St James’s Palace to the north, Memorial Gardens and Buckingham Palace to the west, Birdcage Walk to the south and Whitehall and its associated buildings to the east.

Figure one – site plan from the applicant’s DAS

page 6 Details of the proposal

6 Permission is sought for the use of the site for the Olympic and Paralympic Games beach volleyball and road events. Development proposal for each element will comprise the following: -

 Horse Guards Parade - The beach volleyball seating bowl is located centrally in the parade ground. Between the bowl and the Horse Guard buildings there will be two temporary beach volleyball courts, both will be used for warm up and one will be used for contingency competition with stadium seating for 3,000 people.

 The Mall is the start and finish of the road events. It includes seating stands on both sides with spectators on the south side and press, broadcasters and Olympic family on the north side. The north side also includes tents for the athletes and cyclists.

 St James Park - Approximately half of the park will be used during the Games. The spectator entrance and concessions will be in the northeastern part of the park. The six beach volleyball training courts, workforce and technology area and broadcast compound will be to the west of the park. There will also be a logistic compound in the southeastern section of the park.

 Marlborough House will be used as the Games Family lounge and the gardens will accommodate tents for broadcaster and media staff. Case history

7 No relevant planning history, Strategic planning issues and relevant policies and guidance

8 The relevant issues and corresponding policies are as follows:

 Principle of development London Plan; PPS1; PPG2, the Mayor’s Cultural strategy  Tall buildings/views London Plan; RPG3A, Revised View Management Framework SPG  Urban design London Plan; PPS1  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9; draft PPS Planning for a Natural and Healthy Environment  Sustainability London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Transport London Plan; the Mayor’s Transport Strategy; PPG13

9 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 Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004).

page 7 10 The Westminster Council Core Strategy submission draft and the draft replacement London Plan 2009 are also material considerations.

Principle of development

11 Policy 3D.10 of the London Plan and 7.17 of the draft replacement London Plan seeks to protect Metropolitan Open Land from inappropriate development. Essential facilities for appropriate uses will only be acceptable where they do not have an adverse impact on the openness of the Metropolitan Open Land.

12 Policy 3D.8 of the London Plan and policy 2.18 of the draft replacement London Plan seeks to protect, promote and improve access to London’s network of open spaces, to realise the current and potential value of open space to communities, and to protect the many benefits of open space including those associated with sport and recreation, children’s play, regeneration, the economy, culture, biodiversity and the environment.

13 Policy 3A.18 of the London Plan and policy 3.20 of the draft replacement London Plan seeks to resist the loss of, and increase provision of, social infrastructure and community facilities such as sports and leisure facilities and open space to meet future demand and existing deficiencies.

14 The applicant stresses that the use of Horse Guards, the Mall and St James Park is key to the principle of providing a compact and well-connected Games, which makes the most of London’s existing iconic and spectacular venues.

15 Whilst the use of the Metropolitan Open Land for sporting activities is supported. The intensive use of the site as proposed including the extensive back of house facilities will harm the openness of the Metropolitan Open Land and is therefore inappropriate in its scale. However, given the temporary nature of the proposal, its use for the Olympic and Paralymic Games and the applicant’s commitment to restore the land to ‘as found’ conditions the proposal is unlikely to have a lasting detrimental impact upon the openness of the Metropolitan Open Land or local residents access to open space and local community sports facilities.

16 As such the benefits to London from hosting the Olympic and Paralympic Games are considered to outweigh any interim loss of provision of existing Metropolitan Open Land. London View Management Framework

17 The proposal falls within four of the protected views identified in the London View Management Framework. View two the Parliament Hill London Panorama, view four the Primrose Hill London Panorama, view seven the Mall linear view from Admiralty Arch and view twenty six the St James’s Park townscape.

18 Policy 4B.18 of the London Plan and 7.11 of the draft replacement London Plan seeks the refusal of all development within the landmark viewing corridors above threshold heights and development within landmark background and lateral assessment areas, which fails to preserve or enhance the ability to recognise and appreciate landmark buildings. Refusal is also sought for developments in front and middle ground assessment areas that are overly intrusive, unsightly or prominent to the detriment of the view as a whole.

19 The impact of the proposal on panoramas at Parliament Hill and Primrose Hill will be negligible with the arena likely to be imperceptible in views. The view along the Mall will be partially frame and narrowed by the temporary stands and start/finish lines for the road events.

page 8 The upper elements of the main arena may also be visible. The upper parts of the arena are also likely to be visible above the tree line at the eastern end of the St James’s Park townscape. The ancillary facilities within the park are also likely to be visible through the gaps in the existing mature planting.

20 Whilst the proposal will undoubtedly have a detrimental impact upon the London panorama, Grade I listed buildings and the World Heritage Site it will also provide spectacular backdrops for the London Olympic and Paralympic Games. This combined with the temporary nature of the proposal outweigh any temporary harm to the setting of the Grade I listed buildings and World Heritage Site. Urban design

21 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London.

22 For beach volleyball spectators the main entrance will be through Admiralty Arch and along the eastern end of the Mall and they will then enter the site through St James’s Park and experience this historic landscape. The secondary entrance will be through St James’s Park over Blue Bridge. Spectators of the road event will arrive from the southwest through St James’s park and then make their way to seating set between the mature trees of the Mall allowing views of Buckingham Palace to the West. 23 The main arena will be located centrally and symmetrically facing the elevation of the Horse Guards Buildings. Designed in the style of a theatre the lower seating encloses the arena whilst the upper seating has been limited to three sides to allow views of the Horse Guard Parade buildings and London beyond.

Figure one: Artists impression of main arena and 16,000 seating stadium taken from the applicant’s DAS

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24 This is one of many temporary Olympic venues, its use is only required for the games after which all structures will be removed and the land will be returned to its existing use and made good. As such the centre is made up of a series of temporary structures which following the Games will be sold or put back into the rental market for temporary venues. 25 Whilst great care has been given to the layout, scale and appearance of the temporary structures they have not been designed to include extra aesthetical features such as cladding, fabric or roofs to give the appearance of a permanent facility. The applicant wishes the transient and sustainable nature of the centre to be apparent. The applicant wishes to “celebrate the structural elements by revealing their structural composition”. 26 Given the nature and scale of the development this approach to design is supported; it is consistent with the design approach for the Olympic Park as a whole and is supported by London Plan policy.

27 In summary, the proposals raise no strategic design concerns. Access

28 Policy 4B.5 of the London Plan expects all future development to meet the highest standard of accessibility and inclusion. This, together with the London Plan’s supplementary planning guidance ‘Accessible London: achieving an inclusive environment’, underpins the principles of inclusive design and the aim to achieve an accessible and inclusive environment consistently across London.

29 The draft replacement London Plan seeks to ensure the Olympic Games are the most inclusive and accessible Games.

30 The London Organising Committee for the Olympic Games aim to “design and construct a venue for the London 2012 Olympic and Paralympic Games that is inclusive for all regardless of age, disability, ethnicity, faith or gender, while setting standards for services, facilities and opportunities for all”.

31 The applicant has produced an inclusive access statement; this illustrates ways in which the proposal will create an inclusive environment. The proposals are consistent with London Plan policy and in most cases go beyond minimum requirements. Biodiversity

32 Policy 3D.14 of the London Plan and policy 7.19 of the draft replacement London Plan seek to give strong protection to Sites of Metropolitan Importance for Nature Conservation. Planning for nature from the beginning of the development process and taking opportunities for positive gains for nature through the development process.

33 The site is designated as a site of Metropolitan Importance of Nature Conservation and the applicant has submitted an ecological assessment. This details some of the environmental measures the applicant intends to build into the scheme. The applicant has committed to mitigate the potential harm from the temporary use and fully reinstate the parkland. Westminster City Council should ensure these measures are delivered through planning conditions.

34 Westminster City Council and the applicant are also encouraged to make the most of the landscaping works to make other positive gains for nature conservation, improving, where possible the site beyond the ‘as found’ conditions as part of the Legacy framework.

page 10 Sustainability and climate change

35 The London Plan climate change policies as set out in chapter 4A and chapter 5 of the London Plan Consultation Draft Replacement Plan collectively require developments to make the fullest contribution to the mitigation and adaptation to climate change and to minimise carbon dioxide emissions.

36 The applicant has submitted a sustainability statement which sets out the London Organising Committee for the Olympic Games’ wider sustainability principles and its aim to make London 2012 the most sustainable games. As such the majority of temporary structures will be leased so that that can be erected, dismantled and re-used. Existing building will also be utilised where possible. The applicant intends to reduce the demand for energy through innovative design. The venue will be constructed to maximise natural light and ventilation balancing the requirements for heating and cooling. Energy demand will be reduced and energy efficient products used where ever possible. The applicant has also committed to maximising opportunities for grey water use and low flow appliances. Given the temporary nature of these facilities these measures are acceptable. Transport

37 TfL seeks clarification on the location and amount of temporary cycle parking that will serve the events and suggests that the locations of the cycle parking be adjacent to the spectator accesses on The Mall and Birdcage Walk.

38 It is also requested that disabled parking be temporarily assigned at on street locations close to the spectator accesses on The Mall and Birdcage Walk.

39 The site is located within a 20-minute walk of St James’s Park, Westminster, Charing Cross, Embankment, Victoria, Green Park and Piccadilly Circus Underground stations. TfL is committed to working with LOCOG and the ODA in terms of the pedestrian routeing including appropriate signage and crowd management.

40 London Buses will continue to work with LOCOG, the ODA and other stakeholders regarding access arrangements during the Games. It should be noted that the bus network will not operate as it currently does and that the ODA transport strategic modelling platform is being used to assess the likely impacts on the bus network.

41 TfL requests further discussion in relation to the local area traffic management plan and integration with the ORN. Local planning authority’s position

42 The application is likely to be heard by Westminster City Council’s planning committee in January 2011. Legal considerations

43 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

page 11 direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

44 There are no financial considerations at this stage. Conclusion

45 London Plan policies on the principle of development, London View Management Framework, Urban design, access, biodiversity, sustainability and transport are relevant to this application. In general, the application complies with these policies, for the following reasons:  Principle of development: The proposal is unlikely to have a lasting detrimental impact upon the setting of the Grade I listed buildings, World Heritage Site, the openness of the Metropolitan Land or local residents access to open space. As such the proposal complies with policies 3D.8, 3D.10, 3D.18 and 3D.6 of the London Plan.  Views: The proposal is unlikely to have a lasting detrimental impact on the safeguarded London Panorama. As such it complies with policy 4B.18 of the London Plan.  Urban design: Given the nature and scale of the development this approach to design is supported; it is consistent with the design approach for the Olympic Park as a whole and is supported by London Plan policy.

 Accessibility: The proposal will achieve a high level of accessibility for all users. As such the proposal complies with London Plan policies 4B.5.

 Biodiversity: Subject to conditions securing the environmental measures suggested by the applicant to protect the biodiversity of the site the proposal complies with policy 3D.14 of the London Plan.

 Climate change mitigation and adaptation: The proposal complies with the London Plan policies on climate change adaptation.

 Transport: TfL has no objections to the proposals subject to clarification on the above issues and will continue discussions between LOCOG, the ODA and Council Officers on the necessary transport management issues. 46 Discussions regarding transport are ongoing between TfL, the borough and the ODA to address the outstanding issues; these should be completed before the application is referred back to the Deputy Mayor.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Kim Hoffman, Case Officer 020 7983 6589 email [email protected]

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