planning report D&P/3268/01 5-6 Stanhope Gate and 18A Curzon Street 5 March 2014 in the planning application no. 14/00139/FULL

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

The proposal Full planning application for a change of use from office to residential use that incorporates demolition and redevelopment, retaining listed front facades of 5-6 Stanhope Gate, to provide a building comprising 12 residential units on the Curzon Street frontage; excavation to provide part sub-basement and three basement levels (in addition to lower ground floor) for ancillary uses, car and cycle parking and mechanical plant; alterations to existing access on Curzon Street and associated works. The applicant The applicant is Four Leaf Limited and the architect is PLP/Architecture.

Strategic issues Principle of land use, heritage/urban design, housing, inclusive access, sustainable development/energy, and transport are the relevant strategic planning issues which are dealt within this report.

Recommendation That City of Westminster Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 50 of this report; but that the possible remedies set out in that paragraph of the report could address these deficiencies.

Context 1 On 27January 2014 the Mayor of London received documents from City of Westminster 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 7 March 2014 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. This report sets out information for the Mayor’s use in deciding what decision to make. 2 The application is referable under Category 1C of the Schedule to the Order 2008: ”Development which comprises or includes the erection of a building of one or more of the following descriptions – (c) more than 30 metres high and is outside the City of London.”

page 1 3 Once City of Westminster 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 occupies a mid-terrace, rectangular plot with primary frontages onto both Stanhope Gate and Curzon Street. The site extends to 0.08 hectares in size. 6 The site is situated in central London, close to Hyde Park, Green Park and within the Conservation Area. It comprises two listed buildings, No. 5 and No.6 Stanhope Gate, both in freehold ownership of the Client, Clivedale Ventures Limited. The site is also located within the Central Activities Zone (CAZ).

7 The two buildings occupy ground plus five levels on Stanhope Gate side and extending to Curzon Street on ground plus four levels. The existing buildings contain office space (2,138sqm) accessed through the entrance of No. 5 Stanhope Gate. On the Curzon Street, the ground floor frontage is occupied by HSBC (498sqm) with an office entrance from No.6 Stanhope Gate. The top two floors provide two residential units (323sqm). 8 Frequent bus services are available in close proximity of the site running along . The nearest London Underground stations are Hyde Park Corner and Green Park, both within 5-10 minutes walking distance. As a result, the site has a public transport accessibility level of 6a, on the scale 1 to 6, where 6 is the highest level. Details of the proposal 9 This application seeks a full planning permission for a change of use which incorporates demolition and redevelopment, retaining front facades of 5-6 Stanhope Gate, to provide a building comprising 12 residential units, on lower ground, ground and first to fifth floors on the Stanhope Gate frontage and lower ground, ground and first to part seventh/part eighth floors on the Curzon Street frontage (including plant at part 8th floor level, and roof terraces at 6th/7th/8th floor levels). 10 The application also includes excavation to provide part sub-basement and three basement levels (in addition to lower ground floor) for ancillary uses: gym, spa & cafe, car and cycle parking and mechanical plant; alterations to existing access on Curzon Street and associated works. [Site includes 6 Stanhope Gate and 18A Curzon Street]. Vehicular access will be from Curzon Street where a car lift provides access to the basement. There will be a northern residential entrance on Stanhope Gate and a southern entrance on Curzon Street. Case history 11 A pre-application meeting that included the applicant/agent and GLA officers was held on 4 November 2013 at City Hall. The proposal was broadly supported and the applicant was advised to address concerns in case of future planning application. A follow-up meeting was held on 28 February 2014 to discuss few changes to the scheme that was presented at the pre-app meeting. 12 There is no recent planning history related to the current application. Strategic planning issues and relevant policies and guidance

13 The relevant issues and corresponding policies are as follows:

 Historic Environment London Plan;

page 2  Housing London Plan; Housing SPG; Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context, draft SPG  Affordable housing London Plan; Housing SPG; Housing Strategy; draft Revised Housing Strategy  Urban design London Plan; Shaping Neighbourhoods: Character and Context, draft SPG; Housing SPG; London Housing Design Guide; Shaping Neighbourhoods: Play and Informal Recreation SPG  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  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; 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 2011 Westminster City Council Core Strategy and the 2011 London Plan (with Alterations - November 2013). 15 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework.  The draft Further Alterations to the London Plan (January 2014). Principle of land use: Change of use from Office to Residential 16 The applicant has stated that the proposed change of use from office space to residential development involves a land use swap, to compensate for the loss of office, and has submitted a planning application for a change of use from residential to office use, on a site located at 73 Brook Street, owned by the applicant (approximately 600 metres north of the current application site, near Grosvenor Garden Square). It incorporates an 820sqm office building, 380sqm retail and 200sqm of residential floor space. This application is not referable to the Mayor.

17 The proposed change of use in the current application does not raise any significant strategic issues. Heritage and urban design 18 Policy 7.8 of the London Plan states that development affecting heritage assets should conserve their significance, by being sympathetic to their form, scale, material and architectural detail.

19 The applicant outlined the latest iteration of the proposed scheme which had been revised to address concerns of both English Heritage (EH) and the Westminster City Council (WCC) regarding the impact of the development upon the Grade II listed facades at 5 & 6 Stanhope Gate and the character of this part of the Mayfair Conservation Area. The applicant acknowledged that it had yet to receive feedback from WCC or EH regarding these revisions.

page 3 20 The two listed buildings in question comprise solely of facades – the remainder of these mid Georgian houses were demolished in 1969-71 to make way for a new office development. The four storey facades (plus basement and attic storey) were listed in 1987, some 15 years later. Both facades date from c1760, though both were remodelled in the Victorian and Edwardian eras when a classical porch was added to No.6 by Decimus Burton in 1854 and No. 5 was totally re-fronted in elegant Louis XVI stone in c1910, so this is essentially an Edwardian facade. Both have somewhat poorly proportioned single storey mansards dating from the 1971 redevelopment. The early 1970s office building, which has an L-shaped frontage above a podium ground floor (a branch of the HSBC) onto Curzon Street, is of an indifferent architectural quality.

21 The context of the pair of listed facades has been compromised by the construction of what was formerly the Playboy Club, built in 1963 - a much taller 8 storey edifice recently remodelled to become No.45 Park Lane hotel. To the east are mid to late 20th Century office buildings of varying quality, all of which run through to Curzon Street behind, as does 45 Park Lane, so this frontage has the same immediate context of mid-late 20th Century neighbours. Opposite this frontage is Curzon Square by Sir Michael Hopkins of 2005 which is of a similar scale to No.45 Park Lane.

22 The applicant has submitted very detailed statements explaining the design approach and its evolution following dialogue with WCC and EH, and a townscape and heritage assessment. Both of the listed facades are to be retained and restored which is welcomed - the controversial element to the proposals is the addition of a new fourth floor (with a new fifth floor within a single storey mansard above). GLA’s heritage assessment has considered the following factors:

 the major remodelling of both Georgian facades by Decimus Burton in the 1850s (No.6) and the c1910 refronting of No.5, followed by the redevelopment of this site behind the retained facades in 1971 with open plan office accommodation (which the consequential deleterious effect upon the facades particularly at night when the offices within are illuminated) which would be replaced by a modular layout far more complementary to the character of the facades,  the major impact of the construction of the Playboy Club at No.45 over 50 years ago and the argument that raising the height of this pair of frontages would help mitigate the bulk of No.45 and in the applicant’s words ‘give the listed buildings greater stature’,  the replacement of the unsatisfactory existing mansard roofs with a more authentic 70 and 30 degree pitched design,  the scholarly replication of the architectural detailing of the additional floor,  the revisions to the design which include the reduction of the overall height of the top storey, the smaller dormers to the mansards, and the insertion of an additional cornice line to No.6, 23 Given the above factors it is considered that the applicant has submitted a convincing case with sufficient justification to recommend this aspect of the scheme for approval by virtue of it preserving the character of the Mayfair Conservation Area and representing a significant but sympathetic addition to the two listed facades.

page 4 24 Turning to the remainder of the scheme, the demolition of the very mediocre 1971 office block and its disjointed Curzon Street frontage and its redevelopment is welcomed. The two design-distinct facades in contrasting black sandstone and light travertine natural stone with perforated metal screens resembling copper, and the different parapet heights, following the subtle curve of Curzon Street and its 1938 extension through to Park Lane, are of a suitably high quality. Their stepping up in height between the mid-20th Century Neo Georgian facade and the consented redevelopment of its neighbour, to the 9 storey hotel at 45 Park Lane, will represent an enhancement of this part of the Conservation Area. It is a well-considered design solution and should create a much more appropriate streetscape than the existing office building which exposes the unattractive rear of No.45 to the detriment of this gateway to Mayfair.

Conclusion

25 The principle of an addition of an extra floor to a listed building, particularly of the relatively small scale and high sensitivity of a Georgian townhouse is always a controversial proposal that in most cases is unlikely to be acceptable. However in this particular case, the radical changes to the listed buildings following the facadism scheme of the 1970s and the construction of the much taller No.45 Park Lane over 50 years ago, coupled with the benefits to the townscape of both Stanhope Gate and Curzon Street afforded by the new development, and the high quality and well considered specifications of the additions to the facades and the new-build development behind, together present a convincing case which on balance leads to conclude the development complies with the London Plan Policy 7.8 (A,C & D) on heritage assets and the NPPF Chapter 12. Housing unit mix

26 London Plan Policy 3.8 and the associated supplementary planning guidance promote housing choice and seek a balanced mix of unit sizes in new developments. The proposed development comprises 12 residential units providing the following unit mix:

1-bed 2-bed 3-bed 4-bed Total

No of Units 0 5 5 2 12

Percentage (%) 0 42% 42% 16% 100%

27 As shown above in the Table, 58% of family housing is provided, which is welcomed. Housing quality/space standards 28 The space standards for the 2-bed units ranges from (216-295sqm), for the 3-bed units from (295-319sqm) and the 4-bed units are 478 & 520sqm. These exceed the Mayor’s minimum standard by some margin and are welcomed. 29 Furthermore, 8 of the units (above ground floor) benefit from balconies and roof terraces provided and the remaining 4 units have been provided with generous living space standards to compensate the amenity open space they lack due to the listed facade. It should also be noted that the site is adjacent to the Hyde Park and a short walking distance from Green Park. Affordable housing 30 All the proposed 12 residential units are for market housing. The applicant has provided financial viability in support of its housing provision proposal. The applicant noted that in considering the nature of the affordable housing obligation that may be supportable as part of the proposed development regard has been given to the London Plan and Council’s sequential approach to affordable housing delivery; in the first instance on-site provision will be sought, then off-site, then a financial payment in lieu

page 5 31 On-site provision: The applicant has argued that on-site provision cannot be considered for a number of reasons, including prohibitive service charges, physical constraints, viability and the impact on the marketability of the private units. 32 Off-site provision: To date the applicant has been unable to purchase a site within the borough to meet their affordable obligation. The applicant argues that delivering off-site affordable in Westminster is challenging due to the shortage of available sites. The difficulties in procuring sites in the borough are magnified in high value areas where the high land values and increased competition from developers (for off-site opportunities) make off-site delivery prohibitively expensive.

33 Payment in lieu: The applicant stated that given the findings outlined above it is therefore considered that a payment in lieu of £1.17M to the Affordable Housing Fund administered by the Council, instead of on-site or off-site provision, is the only practical and feasible method of delivering affordable housing.

34 Whilst the above arguments and the financial viability report seem reasonable and justify the case, the proposed contribution should be verified by independent consultants. Inclusive design 35 The design and access statement states that the residential units will meet the Lifetime Homes standards will be easily adaptable to meet wheelchair accessible housing standards. The entrances and lobby will be designed to be identifiable and accessible (in accordance with BS 8300), where not affected by the listing of the Stanhope Gate facade. 36 The scheme will incorporate two passenger lifts and common stairs that make reasonable provision for disabled people and will be designed in accordance with Building Regulations Approved Document (AD) M - Section 9 (Passenger Lifts & Common Stairs in Blocks of Flats) and Lifetime Homes Criterion 5. 37 Within the basement a total of 11 parking spaces will be provided where 1 space will be dedicated to wheelchair users. Access to the parking spaces will be via the two passenger lifts with a step free access to and from the lifts. 38 All the above measures are welcomed, but should be secured through appropriate conditions. Sustainable development/energy Energy efficiency standards 39 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. The applicant is claiming a 12% in regulated CO2 emissions compared to a 2010 Building Regulations compliant development, however the figures in the report are inconsistent and should be reviewed and resubmitted. Sample SAP and BRUKL sheets accounting for energy efficiency measures alone should also be provided to support the carbon savings claimed. District heating 40 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development but that a district heating opportunity area is within 500m of the site. The applicant has provided a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available. A site heat network is proposed. However, the applicant should confirm that all apartments and non-domestic building uses will be connected to the site heat network.

page 6 41 The site heat network will be supplied from a single energy centre. This will be located in the basement. Further information should be provided clarifying the estimated floor area, and how the design will ensure that future connection with district heating will be enabled. Combined Heat and Power (CHP)

42 The applicant is proposing to install a 25 kWe gas fired CHP unit as the lead heat source for the site heat network. The CHP is sized to provide the domestic hot water load, as well as a proportion of the space heating. The applicant should review and clarify the carbon savings expected by the installation of the CHP as the figures in the submitted report are inconsistent. Given the small size of the system the applicant should also provide information on the proposed management arrangements and electricity sales strategy for the proposed CHP system. The carbon savings associated with the CHP should be provided in the format described in the GLA guidance. Renewable energy technologies 43 The applicant is proposing to install 8kWp of solar PV panels (55sqm) on the highest roof of the building. A roof plan showing the proposed location of the panels has been provided. A reduction in regulated CO2 emissions of 2.9 tonnes per annum will be achieved through this third element of the energy hierarchy. Overall carbon savings 44 The applicant should review and re-submit the carbon emissions and carbon savings at each step of the energy hierarchy in line with the table in the GLA Guidance on preparing energy assessments, i.e. in regulated tonnes of CO2/year (not per m²). 45 The comments above should be addressed before the carbon savings and compliance with energy policies of the London Plan can be verified. Transport for London’s Comments

46 Given the nature and scale of the proposed development, TfL considers that there are no strategic transport concerns. However, all the proposed transport measures should be secured. Local planning authority’s position 47 Westminster City Council planning officers have yet to confirm their position. Legal considerations 48 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 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 49 There are no financial considerations at this stage.

page 7 Conclusion 50 London Plan policies on principle of land use, heritage and urban design, housing, affordable housing, inclusive access, sustainable development/energy, and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Principle of land use: The proposal for a change of use from office to residential use is supported, provided the loss of office floor space compensated via the land use swap arrangement as detailed above.  Housing: There are no strategic concerns in terms of housing quality/space standards, unit mixes, and density.  Affordable housing: Whilst the payment in lieu proposal accompanied by the financial viability seems reasonable, the proposed contribution should be verified by independent consultants.  Heritage and urban design: The proposed scheme is welcomed, but all the proposed measures should be secured.  Inclusive access: The proposed measures should be conditioned.  Sustainable development/energy: The carbon emissions and savings for each tier of the energy hierarchy should be re-submitted in the format explained in the GLA Guidance on preparing energy assessments. Further information in regard to district heat network and the energy centre should be provided.  Transport: There are no strategic transport concerns. However, all the proposed transport measures should be secured.

For further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager (Development & Projects) 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development & Projects) 020 7983 4895 email [email protected] Tefera Tibebe, Case Officer 020 7983 4312 email [email protected]

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