planning report PDU/1284a/01 6 October 2010 Thorncliffe Hotel,

in the London Borough of planning application no.00815/A/P22

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

The proposal Demolition of part three, part four storey, 317 bedroom hotel and ancillary outbuildings to erect a four storey 317 bed room hotel with associated parking, coach and taxi bays and cycle storage area. The hotel will also have associated conference and banqueting/exhibition facilities. The applicant The applicant is Mastcraft Limited, and the architect is ADZ Architects

Strategic issues Hotel use on Green Belt land neighbouring a nature conservation site. Very special circumstances are considered to justify the inappropriate development on this Green Belt site. The proposal’s design complies with the London Plan but the recommendations suggested should be delivered. The outstanding issues with regards to accessibility (inclusive design) should be addressed. Further information is required on climate change mitigation and adaptation. There are various transport issues that will need to be addressed including pedestrian crossing facilities, cycle parking, travels plans.

Recommendation

That Hounslow Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 48 of this report; but that the possible remedies set out in paragraph 50 of this report could address these deficiencies. The application does not need to be referred back to the Mayor if Hounslow Council resolve to refuse permission, but it must be referred back if Hounslow Council resolve to grant permission.

Context

1 On 1 September 2010 the Mayor of London received documents from Hounslow 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 12 October 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

page 1 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 3D of the Schedule to the Order 2008: ”Development on land allocated as greenbelt… and which would involve the construction of a building with a floorspace of more than 1000 sq. m. or a material change in the use of such a building.”

3 Once Hounslow 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; or allow the Council to determine it itself, unless otherwise advised. In this instance if Hounslow Council resolves to refuse permission it need not refer the application back to the Mayor.

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 Thorncliffe Hotel is located towards the eastern half of a 3.1 hectare site within the Metropolitan Green Belt, with access off North Hyde Lane. The site is bounded to the north by the , to the east by North Hyde Lane and to the south by the rear gardens of residential properties off The Vale. There is an area of open land to the west of the site, which is separated by a post and wire fence and is referred to as the Thorncliffe Nature Conservation Area, (also called Thorncliffe Rough). This site is also located in one of the Borough’s green chains.

6 The existing building dates from the late 1960s and was initially used as a hostel from British Airways staff and subsequently used as temporary accommodation for the homeless and asylum seekers. This use has now ceased and the building is vacant

7 This area of Green Belt is identified within the Council’s UDP as part of Comprehensive Project Area (CPA 6). This seeks ‘comprehensive treatment for this area is required to protect and enhance land which is of ecological significance, and to encourage appropriate redevelopment of the Thorncliffe Hotel in a manner which enhances this important Green Belt site’.

8 The development site is located directly to the south of the M4 but has no direct access from the M4. The site is located to the west of, and also accessed from, North Hyde Road, which in turn connects to the A4, Great West Road approximately 1km to the south which is part of the Transport for London Road Network (TLRN). There are no roads on the Strategic Road Network (SRN) within close proximity of the site.

9 Three bus services operate on North Hyde Lane with a 10 minute morning peak time average frequency. There are no London Underground or rail stations within walking distance of the site. The public transport accessibility level (PTAL) of the site is 2 (where 1 is low and 6 is high), this equates to a poor public transport accessibility level.

Details of the proposal

10 The application seeks permission for the redevelopment of the hostel to provide a 317 bedroom 4* hotel, with associated conference and restaurant facilities. The building will be four storeys, and comprise four linked blocks, broadly occupying the same developed area as the existing buildings.

page 2 Case history

11 Planning permission was granted in 2006 for extension and refurbishment of the existing building for use as a 317-bedroom hotel. This application was referred to the Mayor, but was considered not to raise any strategic issues as the extension involved infilling within the existing blocks. Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

 Urban design London Plan; PPS1  Mix of uses London Plan  Transport London Plan; the Mayor’s Transport Strategy; PPG13;  Parking London Plan; the Mayor’s Transport Strategy; PPG13  Retail/town centre uses London Plan; PPG13, PPS4  Open land London Plan; PPG17; draft PPS Planning for a Natural and Healthy Environment;  Green Belt/MOL London Plan; PPG2  Employment London Plan; PPS4; Industrial Capacity SPG  Biodiversity London Plan; the Mayor’s Biodiversity Strategy; PPS9; draft PPS Planning for a Natural and Healthy Environment  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the spatial needs of London’s diverse communities SPG; Diversity and Equality in Planning: A good practice guide (ODPM)  Sustainable development 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  Urban fringe London Plan; PPG2; PPS7

13 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 2003 Hounslow Unitary Development Plan, the 2008 Hounslow Employment DPD and the London Plan (Consolidated with Alterations since 2004).

14 The following are also relevant material consideration:  The draft replacement London Plan, published in October 2009 for consultation.  The Hounslow Core Strategy (issues and options) 2007.  The Green Belt Management Plan, April 1992.

Green Belt

15 The application site is located within the Green Belt. Although it is not designated as a Major Developed Site, the UDP Proposals Schedule encourages appropriate redevelopment of the building. Policy 3D.9 of the London Plan clearly indicates that the Green Belt is to be protected

page 3 from inappropriate development, and such inappropriate development should not be approved except in very special circumstances. The London Plan also makes clear that London’s growth should be sustainable and not encroach on London’s own precious green spaces (paragraph xi). The reference to “inappropriate development” flows directly from PPG2, which sets out the Government’s policy towards Green Belt.

16 PPG2 identifies the purposes of Green Belt, which are: to check the unrestricted sprawl of large built up areas; to prevent neighbouring towns from merging; to assist in safeguarding the countryside from encroachment; and to assist in urban regeneration by encouraging the recycling of derelict land. Government guidance states that development is inappropriate unless it is for the following purposes:

 Agriculture and forestry;

 Essential facilities for outdoor sport and recreation; for cemeteries; and for other uses of land, which preserve the openness of the Green Belt;

 Limited extension, alteration or replacement of existing dwellings;

 Limited infilling or redevelopment of major existing developed sites identified in adopted development plans, which meet the criteria in Annex C of PPG2.

17 The application is not for any of these purposes and is therefore inappropriate. Although not clearly articulated by the applicant the implied very special circumstances in this case are that there is an extant permission for a hotel of a slightly larger size (albeit refurbishment/extension rather than new build), the new building will have a far better environmental performance than the extant permission and will result in a significant improvement to the Green Belt.

18 Given that the UDP allows for redevelopment of this site and that development of a similar scale has previously been granted, the very special circumstances can be accepted in this instance. In addition the proposal will bring forward a viable use, which will have a broadly similar impact to the existing use and result in the redevelopment of a derelict site.

19 The development should contribute to the implementation of the Green Belt Management Plan, in compliance with PPG2. The plan seeks public/educational use of the nature conservation area to the west of the application site and forecourt landscaping fronting North Hyde Lane. Further discussions are required with the applicant and the Council to understand whether public access to the nature conservation site is still an achievable aspiration or whether an alternative proposal would be more suitable. The application includes landscaping proposals for the forecourt area, however, the Council should satisfy itself that these are sufficiently robust to deliver the Green Belt objectives for the site.

Land use/sequential test

20 The application proposes a town centre use in an out of centre location. PPS4, which is the most up to date policy statement on this matter is particularly relevant. Policy EC14.3 of PPS4 states that, ‘A sequential assessment (under EC15) is required for planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up to date development plan. The requirement applies to extensions to retail or leisure uses only where the gross floor space of the extension exceeds 200sq. m.

21 Discussions between the applicant and the Council have suggested that a sequential assessment is not required as the site is identified in the UDP for redevelopment. However, the

page 4 UDP did not specify any particular use and therefore it could be argued that the site is not allocated for a hotel use and therefore a sequential test is required. Having said that the proposal results in a slight decrease in floorpsace compared to the extant permission and therefore if the extant permission is accepted as the baseline then a sequential test would not be required. Further discussion between the applicant and the Council is required on this issue.

Design and impact of existing development

22 The proposed development occupies a smaller developed area than that existing. In comparison to the extant planning permission for the hotel has a new length of 112.5 m (a reduction of 20m) from the 132.5m extant planning permission and a new reduced width of 66.5m from the originally proposed 76.5m, creating a reduction of 19.9m. The width of the hotel excluding the staircase elements is also 56.6m.

23 From the information provided it is difficult to appreciate the elevations of the building at this stage. More information is required with regards to the building materials. The success of the building and particularly the northern and eastern elevations, will be highly dependent on the materials and final design detail as it will be visible from the M4 motorway. It is recommended that the Council impose robust planning conditions to ensure these elevations are of the necessary quality. The final design should ensure that the stairwells and glazing are interesting and durable.

24 This new proposal offers a more coherent and rationalised development proposal compared to the current hotel development which is irregular and confusing in its design due to the breaks in building footprint and courtyards. The new proposal also pulls the development away from the southern boundary, hence contributing to the minimal disruption and visual impacts to the residents at the Vale.

25 There is an increase in the building height proposed compared to the extant permission, of which 0.5m will be the sedum green roof. It is considered that the overall proposal taking account of the reduced footprint and the increased distance from the southern boundary compensates for the increase in height. Elevational treatment and the intensification of soft landscaping will also compensate for this increase.

26 Subject to confirmation of the quality of the materials, the proposed design and layout arrangement appears to be an improvement to the existing hotel and is likely to be an enhancement to the Green Belt.

Access

27 Policy 4B.5 of the London Plan and 7.2 of the draft replacement 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 of achieving an accessible and inclusive environment consistently across London.

28 Policy 3D.7 of the London Plan seeks to increase the quantity and quality of wheelchair accessible accommodation in London. Policy 4.5 of the draft replacement London Plan relates to the provision of visitor accommodation and facilities and it supports an increase in the quality and quantity of fully wheelchair accessible accommodation. The draft policy asks for at least 10% of new hotel bedrooms to be wheelchair accessible and for applicants to submit an Accessibility Management Plan which sets out how the continuing management of the hotel will ensure the accessible rooms are maintained and managed, helping inclusive access to become part of the overall operation and business of the hotel (in a similar way that travel plans can ensure a commitment to sustainable travel patterns after occupation). A research study undertaken by

page 5 Grant Thornton on behalf of the GLA and the LDA has looked at how inclusive design principles can be applied to London's hotel accommodation and has assessed that less than 2% of existing stock is accessible to disabled people which makes it difficult for disabled people to find an accessible hotel, particularly when linked to other access barriers such as location near accessible public transport facilities or the availability of blue badge parking provision. This is particularly pertinent given the likely number of disabled visitors to London in 2012 for the Olympic and Paralympic Games.

29 From studying the plans it appears that the applicant will be providing 16 wheelchair accessible rooms. Of the 10% draft policy requirement, stated above, the applicant appears to have met 5%, by providing 16 disability friendly suites of the 317 bedrooms. The applicant should provide large scale plans showing the wheelchair accessible rooms for assessment. The applicant should also increase the provision of wheelchair accessible rooms to 10% by either providing additional fitted out rooms or those that are easily adaptable to wheelchair use and demonstrate how this is to be achieved.

Climate change mitigation and adaptation

30 The climate change policies as set out in chapter 4A of the London Plan and chapter 5 of the draft replacement London Plan collectively require developments to make the fullest contribution to the mitigation and adaptation to climate change and to minimise carbon dioxide emissions (policy 4A.1).

Climate change mitigation

31 The applicant has not submitted an energy assessment, as required by policy 4A.4 of the London Plan, setting out how the scheme will reduce carbon dioxide emissions through efficiency measures, efficient supply and renewables. The applicant has committed to produce a detailed energy statement and is proposing the use of renewable technologies, including measures such as ground sourced heating and cooling and efficient cladding, along with movement sensing lights in corridors as energy saving measures. This will need to be assessed before the scheme can be said to comply with strategic planning policy.

Mitigation measures

32 Green roofs will be incorporated on the entire building along with permeable paving within the access roads to the hotel. Rainwater harvesting is proposed with rainwater butts with a view to providing irrigation to the landscaped areas on the grounds. It is also proposed that water saving sanitary fittings will be incorporated in the design of the building. The new development proposes to decrease surface run off through the implementation of SUDs and landscaping.

33 As such the proposal complies with London Plan policy in this regard. However, the measures should be secured by condition.

Biodiversity

34 Thorncliffe Nature Conservation Area, called Thorncliffe Rough is designated as non- statutory area of ‘local nature conservation importance’ (SLNCI). This site is located to the west of the development site and development is not proposed for this area. The applicant proposes to retain the open field to the west of the site as a wild flower meadow, which requires gentle treatment. The applicant has also undertaken an ecological appraisal, which ensures that no disturbance is predicted to this site or others within two kilometres of the building works at the site.

page 6 35 The applicant has proposed to implement green biomembrane walls and green roofs to complement the Green Belt setting and this also enhances the biodiversity of the site, together with the landscaping proposals for the forecourt. As stated above the green walls/roofs should be secured by condition. Similarly the sympathetic management of the nature conservation area should also be secured by condition or agreement.

Transport for London’s comments

36 TfL has noted that there are insufficient pedestrian crossing facilities to cater for the bus trips generated by the hotel. TfL therefore requests that, subject to discussion with Hounslow Council, a pedestrian crossing is provided on North Hyde Lane improving access to southbound bus services. This will ensure general conformity with London Plan policy 3C.21 Improving conditions for walking and draft replacement London Plan policy 6.10 Walking.

37 TfL recommends that a bus stop access audit is carried out on the two closest bus stops on North Hyde Lane to ensure they are compliant with the current accessibility guidance. This will ensure general compliance with draft replacement London Plan policy 6.7 Buses, bus transits, trams.

38 The application is for 213 car parking spaces. TfL considers that the level of provision, taking into account the low PTAL rating and site location, is acceptable on this occasion. 20 disabled spaces have been proposed, in light of the high car parking total proposed TfL recommends that disabled parking is provided on a 1:1 ratio in line with the number of accessible rooms eventually provided.

39 20% of on-site car parking should be provided with electric vehicle charging points (EVCPs) in line with emerging draft replacement London Plan policy and a further 10% passive provision for electric vehicles in the future.

40 The proposed provision of 26 secured cycle parking spaces on site for the proposed hotel, based on 254 staff is acceptable. However, it is recommended that further provision should be made for visitors to the conference facilities. The developer must ensure that these are safe, covered and secure with good lighting and CCTV. It is also requested that shower and changing facilities on site should be provided. This will ensure general conformity with London Plan policy 3C.22 Improving conditions for cycling and draft replacement London Plan policy 6.9 Cycling.

41 The proposed provision of two coach bays is welcomed by TfL but these should be modified to accommodate coaches 15m in length.

42 Both a construction logistics plan and a delivery and servicing plan should be provided in support of the application and secured by appropriate planning conditions. This will ensure general conformity with London Plan policies 3C.17 Tackling congestion and reducing traffic and 3C.25 Freight strategy and draft replacement London Plan policy 6.14 Freight.

43 TfL requests that a travel plan be produced which should be secured, enforced, monitored, reviewed and funded through the section 106 agreement.

44 In summary, a number of items need to be addressed before the proposals can be considered to be compliant with the London Plan.

page 7 Local planning authority’s position

45 A report is being prepared for the Council’s Sustainable Development Committee on 20 October 2010. At this stage it is considered likely that the recommendation will be for approval subject to conditions and the securing of a s.106 agreement. Legal considerations

46 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

47 There are no financial considerations at this stage.

Conclusion

48 London Plan policies on Green Belt, design, accessibility, climate change and mitigation, and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Green Belt: Very special circumstances have been identified to justify the inappropriate development. However, it is unclear whether the proposal contributes towards the implementation of the Council’s Green Belt Management Plan.  Design: Further information and drawings have been requested to enable assessments to be made on the scheme’s elevations and likely views to drivers passing by on the M4 motorway.

 Access: Only 5% accessible bedrooms are proposed, conflicting with policy 4.5 of the draft London Plan.

 Climate change mitigation: Further technical information is required to assess the proposal against the energy policies contained in chapter 4A of the London Plan.

 Climate change adaptation: The proposal includes sedum green roofs to increase biodiversity and water attenuation and SUDs and water saving measures are proposed by the applicant. As such the proposal complies with policies 4.9, 4A.11 and 4A.14 of the London Plan, subject to these provisions being conditioned.

 Transport: Whilst the proposal appears to be acceptable in principle, additional information and enhancements are required, relating to a pedestrian crossing on North Hyde Lane, bus stop enhancement, cycle parking provision, coach parking, electric vehicle charging points, submission of a travel plan, construction logistics plan and delivery servicing plan.

page 8 49 Whilst the application is broadly acceptable in strategic planning terms, on balance, the application does not comply with the London Plan.

50 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Urban design: The materials proposed for use in the new scheme should be specified more clearly with coloured drawings to demonstrate interesting and durable design. The applicant should provide further clarity regarding the indicative views from the north and north east views for passers by on the M4 motorway.  Access: The applicant should increase the number of wheelchair accessible rooms to 10% and submit an accessibility management plan before the application is referred back to the Mayor. Alternatively, the applicant should demonstrate how an additional five rooms could be made to be adaptable for use by disabled people, as stated in paragraph 34 of the report.

 Climate change and mitigation: The additional information identified in this report such as the energy statement should be submitted before the application is referred back to the Mayor.

 Climate change adaptation: The green roofs/walls, biodiversity management, sustainable drainage, water recycling and water conservation measures should be secured by condition.

 Transport: Provision of pedestrian crossing to cater for the bus trips generated by the hotel, bus stop audit, provision of 20% onsite electric vehicle charging points and 10% passive provision for future needs, further provision of cycle parking for visitors to the new conference facilities, shower and changing facilities, increase size of coach bays to 15metres in length, submission of travel plan, construction logistics plan and delivery servicing plan.

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] Sukhpreet Khull, Case Officer 020 7983 4806 email [email protected]

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