Vaughan Road Car Park, West Harrow, HA1 3XD

Dandi Nine Ltd September 2020

Planning Statement

savills.co.uk

Executive Summary

The application seeks to deliver a local landmark building of exemplary architectural quality, providing affordable luxury aparthotel accommodation and an enhanced public offering within the London Borough of Harrow (LBH). The application scheme comprises the re-development of the disused car park site and the erection of a part 5-storey and part 12-storey building, comprising a 129-room aparthotel (Class C1). The scheme includes a 5th floor publicly accessible restaurant and external amenity space and features ground floor commercial space (which includes a cafe/juice bar, bakery, florist kiosk, concierge service including complimentary tea/coffee/ summer bar). The proposal features associated public realm and highways works to activate the frontage of the aparthotel, which in turn brings a natural surveillance and a vibrancy to the area. The proposal also features hard and soft landscaping; refuse storage; car parking and cycle parking; and associated works. The site is immediately adjacent to Harrow town centre and benefits from a 6a PTAL rating. The proposal features cycle parking provision, three car parking spaces at the rear of the site (two blue badge spaces and one servicing space), but is otherwise a car- free development for future guests and visitors. The application seeks to deliver a design-led solution to an opportunity site, which is highly sustainable and contextual.

The principle of development is considered to be acceptable and appropriate within its gateway town centre location, which is evidenced in the supporting Hotel Need Assessment and Sequential Test (produced by Savills). The scheme has also been designed to the highest quality in terms of both accommodation and materiality. Furthermore, as outlined within the various technical documents submitted in support of the application, it is clear that the delivery of a local landmark aparthotel will significantly improve footfall and attraction to this part of Harrow, whilst also providing key valuable social and economic benefits to the local community, including public access to amenities and the creation of jobs.

A virtual (due to Covid-19) community engagement process (including the distribution of newsletters; Zoom meetings; and the creation of a project website) was undertaken during the design phase of the scheme to ensure that comments from the public could be captured and suitably considered. Nearly 1,000 people engaged with the virtual consultation process, highlighting the key interest in the development of the site. In addition, an extensive pre-application process has been undertaken with LBH, the GLA, and both LBH’s Design Review Panel and Major Development Panel. Consequently, the resulting scheme is the product of a collaborative process which has suitably considered all the resultant feedback and comments to deliver what is in our opinion an exceptional and high-quality scheme which has an acceptable impact on the character of the surrounding area and on the amenities of neighbouring occupiers. This is further reinforced through a Heritage and Townscape Visual Impact Assessment (HTVIA) (produced by Turley) which concludes that the proposal is acceptable in terms of scale, height and impacts on heritage assets and key identified protected and locally significant views.

The scheme proposals embrace more detailed elements of design to ensure that the proposals are deliverable, accessible and sustainable in the long-term. The scheme proposals have been informed by technical input in respect of daylight, sunlight and overshadowing; energy and sustainability; ecology and biodiversity; drainage; air quality; wind and micro-climate; and hard and soft landscaping. These technical considerations, together with the architects’ careful design, have informed the proposals to ensure there is no detrimental amenity impacts to neighbouring properties.

The scheme proposals have been developed through a careful and rigorous assessment of planning policy and material considerations to ensure the delivery of an acceptable scheme, of the highest quality and design, which can be supported to deliver much-need hotel accommodation in Harrow Town Centre, whilst also delivering key social and economic benefits for the Borough as a whole.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

Contents 1. Introduction 4 2. Proposed Development 8 3. Application Site Overview and Context 12 4. Planning History 18 5. Pre- Application Consultation Process 19 6. Planning Policy Context 23 7. Planning Assessment 26 8. Planning Conditions and S. 106 Obligations 45 9. Planning Balance and Conclusions 48

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

1. Introduction

This Planning Statement has been prepared on behalf of Dandi Nine Limited (the Applicant) in respect of a development proposal at Vaughan Road Car Park, West Harrow, HA1 3XD (the Site).

Planning permission is sought from LBH (or ‘the Council’) for:

Erection of part 5-storey and part 12-storey building comprising of 129 aparthotel suites (Use Class: C1), including ground floor commercial space; fifth floor restaurant; associated external amenity space; associated public realm and highways improvements; hard and soft landscaping; refuse; car parking and cycle parking; and associated works.

This Planning Statement provides an overview of the proposed development, describes the context of the site and its surroundings, and highlights the relevant planning history. A summary is provided of the various pre-application meetings that were held during the design process and the key comments and feedback received, in addition to detailing the virtual community engagement consultation that was also undertaken as part of the pre-application process.

The key relevant planning policies are identified against which a robust planning assessment is made, with detailed consideration given to the principle of development and the associated impact on the surrounding locality and on the amenities of neighbouring occupiers. Suggested appropriate planning conditions and S.106 obligations required in the event of the grant of planning permission are provided.

This Planning Statement is structured as follows:

Section 2 – Proposed Development Section 3 – Application Site Overview and Surrounding Context Section 4 – Planning History Section 5 – Pre-Application Consultation Process Section 6 – Planning Policy Context Section 7 – Planning Assessment Section 8 – Planning Conditions and S.106 Obligations Section 9 – Planning Balance and Conclusions

1.1. Dandi’s Aparthotel Offer

Dandi’s approach to providing aparthotel accommodation aims to address a gap in the local market and key challenges in today’s hotel and hospitality market. Aparthotels are a growing part of the hospitality market. The sector comprises approximately 25,000 units in the UK, making it about 3% the size of the conventional hotel market. With approximately 6,000 new units scheduled to open by 2021 (13% of the total active pipeline), the sector is one of the fastest-growing parts of the UK’s overall accommodation market.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

Aparthotels are self-catering, but serviced, establishments offering autonomy along with a broad range of hotel services such as restaurants, gyms and a 24-hour reception. Aparthotels seek to deliver an experience that integrates the best of the lifestyle hotel experience with the best of Airbnb / serviced apartment living and creative co-working spaces to forge a unique destination that can serve as a social and cultural anchor for the locality. While aparthotels remain very attractive to business travellers, spacious suites with basic kitchenette facilities and the customer service provided have made them increasingly popular with travellers looking for a more home-from-home experience.

The design of Dandi schemes aims to encourage social cohesion and a sense of community and will benefit from an extensive range of innovative amenity spaces, facilities and the Dandi Concierge & Community app. Dandi’s Aparthotel aims to provide a new, more accessible solution for travellers and urban professionals who want to stay close to Harrow and central London but would otherwise not be able to do so. Their vision is “Making Dandi’s Magical Living Experience Accessible”. Guests will benefit from fully furnished suites, best in class amenity spaces, an all-inclusive rate and 24/7 security and management. Communal spaces include fitness facilities, and a 5th floor external amenity roof terrace. In addition, guests will be offered the opportunity to participate in a regular series of curated social events ranging from talks, to networking events, to cooking demonstrations and wellbeing classes.

As part of Dandi’s commitment to encourage guests to use the amenity spaces to entertain their friends and guests, a number of the spaces will be available for private hire. Dandi is one of the few aparthotel providers who have a guest maintenance technician at all sites, and who offers round the clock site- based security which guests truly value.

1.2. Application Submission Content

The supporting material which accompanies the planning application is set out below:

. Cover Letter . Application Form . Certificate of Ownership . CIL Form . Location Plan (Adam Khan Architects) . Site Plan (Adam Khan Architects) . Architectural Drawings (Adam Khan Architects) . Design & Access Statement (Adam Khan Architects) . Planning Statement (Savills) . Statement of Community Involvement (Terrapin) . Air Quality Assessment (Air Quality Consultants) . Daylight, Sunlight and Overshadowing report (internal and external analysis) (Point 2) . Economic Benefits Assessment and Social Value (Savills) . Health Impact Assessment (Savills) . Noise Impact Assessment for Planning (Anderson Acoustics) . Surface Water Drainage Strategy (MLM) . Landscaping and Public Realm D&A Statement (Adams & Sutherland)

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

. Sustainability Statement (Inclusive of energy report): Whole Life Carbon Assessment and Circular Economy Statement (Verte Ltd) . Images and Visual Impact Study (Miller Hare and Wire Collective) . External Lighting Package (Michael Grubb Associates) . Transport Assessment (Velocity Transport Planning) . Travel Plan (Velocity Transport Planning) . Delivery and Servicing Plan (Velocity Transport Planning) . Road Safety Audit (Velocity Transport Planning) . Waste Management Plan (Velocity Transport Planning) . Site Waste Management Plan (Velocity Transport Planning) . Preliminary Construction Logistics Plan (Velocity Transport Planning) . Heritage and Townscape Visual Impact Assessment (HTVIA) (Turley) . Stage 2: Fire Strategy (BB7) . Biodiversity Metric (Phlorum) . Preliminary Ecological Appraisal (Phlorum) . Hotel Need Assessment and Sequential Test (Savills) . Wind & Micro Climate Assessment (RWDI) . Airport Safe Guarding Zone Details . Aparthotel Operation and Management Strategy Plan (Dandi Nine Ltd) . Response to COVID-19 Statement (Dandi Nine Ltd)

1.3. List of Plans and Drawings

The application submission includes the following Landscaping and Public Realm plans and drawings produced by Adams & Sutherland:

Drawing Reference Drawing Title Scale & Size 312_001 Rev A Location Plan 1:1250@A3 312_002 Rev A Existing Site Plan 1:200@A1 312_003 Rev A Existing Services Plan 1:250@A3 312_004 Existing Public Realm Section AA 1:200@A3 312_005 Existing Public Realm Section CC 1:100@A3 312_010 Rev B Proposed Site Plan 1:200@A1 312_011 Rev A Proposed Public Realm with Ground Floor 1:200@A3 Plan 312_012 Rev A Proposed Public Realm Levels Plan 1:200@A3 312_013 Proposed Hard Works Ground Plan 1:200@A1 312_014 Planting Ground Plan 312_020 Rev A Proposed Terrace Plan (Level 4 & 5) 1:200 @ A3 312_021 Rev C Proposed Terrace Plan (Level 8 & Level 11) and Proposed Roof Plan (Level 6 & Level 12) 312_022 Proposed Hardworks Roof Plan 1:200 @ A3 312_023 Planting Plan Roof 312_030 Rev A Proposed Public Realm Section AA 1:200 @ A3 312_031 Rev A Proposed Public Realm Section BB 1:200 @ A3 312_032 Rev A Proposed Public Realm Section CC 1:100 @ A3 312_033 Rev A Proposed Public Realm Section DD 1:100 @ A3 312_034 Proposed Underpass Sections EE & FF 1:100 @ A3 6

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

312_035 Proposed Underpass Section GG 1:100 @ A3 312_036 Rev A Proposed Elevation of Undercroft Wall HH 1:100 @ A3 312_140 Rev A Proposed Roof Terrace Sections (Levels 4 1:200 @ A1 & 5) II and JJ 312_141 Rev A Proposed Roof Terrace (Levels 4 & 5) II and 1:200 @ A1 JJ 312_142 Proposed Roof Terrace (Levels 4 & 5) 1:200 @ A1 Sections KK 312_143 Proposed Roof Terrace (Levels 4 & 5) 1:200 @ A1 Detail Sections KK

The application submission includes the following architectural plans and drawings produced by Adam Khan Architects:

Drawing Reference Drawing Title Scale & Size AKA_085_P_L_000 Location Plan 1:1250@A3 AKA_085_P_L_010 Existing Site Plan 1:200@A3 AKA_085_P_L_020 Existing Site Sections 1:200@A3 AKA_085_P_L_030 Existing Site Elevations 1:200@A3 AKA_085_P_L_100 Level 00 Floor Plan 1:200@A3 AKA_085_P_L_101 Level 01 Floor Plan 1:200@A3 AKA_085_P_L_102 Level 02 Floor Plan 1:200@A3 AKA_085_P_L_103 Level 03 Floor Plan 1:200@A3 AKA_085_P_L_104 Level 04 Floor Plan 1:200@A3 AKA_085_P_L_105 Level 05 Floor Plan 1:200@A3 AKA_085_P_L_106 Level 06 Floor Plan 1:200@A3 AKA_085_P_L_107 Level 07 Floor Plan 1:200@A3 AKA_085_P_L_108 Level 08 Floor Plan 1:200@A3 AKA_085_P_L_109 Level 09 Floor Plan 1:200@A3 AKA_085_P_L_110 Level 10 Floor Plan 1:200@A3 AKA_085_P_L_111 Level 11 Floor Plan 1:200@A3 AKA_085_P_L_112 Level 12 Roof Plan 1:200@A3 AKA_085_P_L_113 Level 13 Roof Plan 1:200@A3 AKA_085_P_L_200 Proposed Section AA 1:200@A3 AKA_085_P_L_201 Proposed Section BB 1:200@A3 AKA_085_P_L_300 Proposed Elevation East 1:200@A3 AKA_085_P_L_301 Proposed Elevation South 1:200@A3 AKA_085_P_L_302 Proposed Elevation North 1:200@A3 AKA_085_P_L_303 Proposed Elevation West 1:200@A3 AKA_085_P_L_400 Typical Suite Layout Type 01 1:50@A3 AKA_085_P_L_401 Typical Suite Layout Type 03 1:50@A3 AKA_085_P_L_402 Typical Suite Layout Type 04 1:50@A3 AKA_085_P_L_500 Access Strategy 1:200@A3 AKA_085_P_L_501 Fire Strategy 1:200@A3 AKA_085_P_L_502 Refuse Strategy 1:200@A3 AKA_085_P_L_503 Maintenance Strategy 1:200@A3

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

2. Proposed Development

This section outlines the application proposals and summarises the key features. Further consideration of these issues is given with the Planning Assessment section of this statement (Section 7).

2.1. Description of Proposals

The application seeks permission for:

Erection of part 5-storey and part 12-storey building comprising of 129 aparthotel suites (Use Class: C1), including ground floor commercial space; 5th floor restaurant; associated external amenity space; associated public realm and highways improvements; hard and soft landscaping; refuse; car parking and cycle parking; and associated works.

2.1.1. Land Use

The proposal comprises the re-development of the site to provide an aparthotel featuring 129 suites (feature four different suite types – standard and twin; deluxe; larger deluxe; and family). The proposed ground floor contains commercial space, featuring a cafe/juice bar, bakery, florist kiosk, and concierge service including complimentary tea/coffee/ summer bar. The proposed fifth floor features a public accessible restaurant and external amenity space, with associated function rooms. The fifth floor also features a gym available to aparthotel guests. Further details are available in the supporting Design & Access Statement (produced by Adam Khan Architects).

For ease of reference, the key uses and areas schedule includes:

. Commercial space – 410.4sqm . Aparthotel units (GIA) – 3,045.8sqm . Aparthotel ancillary – 29.1sqm . Circulation – 1,182sqm . Total GEA – 6,297sqm . Total GIA – 5,613sqm

According to the adopted policy proposal map, there are no policy designations or allocations affecting the development of the site. The site is no longer considered to be necessary in its former use as a car-park, and it has subsequently been sold as a development opportunity. The Council confirmed in the initial pre-application meeting that there is in-principle agreement to the loss of the car park / development of the site and confirmed that there is an identified hotel need in the borough. A hotel was considered to be an acceptable use for the site, subject to satisfying the town centre sequential test. The site is located in a highly sustainable location (PTAL 6a) and on the Harrow Town Centre and Intensification Area boundary, serving as a gateway to the town centre mediating between the residential dwellings to the west and south and taller buildings in the town centre to the north and east. Dandi have prepared an Aparthotel Operation and Management Plan which is provided with the application and sets out how the building will be operated and managed.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

2.1.2. Design

The design and form of the scheme has evolved as a result of the extensive pre-application process and feedback received, and features stepped massing (5-storeys adjacent to the residential dwellings on Vaughan Road and 12-storeys at the north-west of the site closest to the railway and Morrisons building) and a scalloped building form. Through the pre-application process the proposed building form has evolved to be more sensitive to potential impacts on neighbouring amenity, to avoid overshadowing, to reduce the mass and bulk of the building, and to provide greater variety and multiple aspects to the aparthotel suites. This all serves to meet the needs of the scheme whilst also delivering a viable development.

The main focus of the pre-application discussions (see Section 5) centred around the maximum height of the proposal, and its relationship with the surrounding context. Whilst the extant planning permission on the site (P/3468/17; Granted 25.10.17) relates to a residential scheme ranging from 5-storeys to 8- storeys, in seeking to deliver an aparthotel the project architects (Adam Khan Architects) have adopted a fresh approach to the site to respond to the different proposed use and role of the site. Through the pre-application process, they have reduced the overall scale (originally a maximum 15-storeys in height and subsequently reduced to a maximum of 12-storeys; reduction in the lower massing element from 8-storeys to 5-storeys) and developed a more respectful design form for the building with various set-backs and faceted elevations in order to ensure it has a positive impact on the visual amenity of the locality. The 5-storey element mirrors the previously consented height and form along Vaughan Road as the site transitions from a lower scale towards the town centre. The 12-storey element responds to the height and scale of building appropriate at this gateway location and highways junction at a major entrance to the town centre. Furthermore, the height and scale of this part of the building responds to the adjacent Morrison’s development. Further detail is provided in the Design section of the Planning Assessment (Section 7) below.

Whilst the maximum height was a key matter in the design development of the building, a number of other considerations have influenced the design. The layout and access has been designed to ensure that the building can function as an aparthotel, with key public realm and highways improvements proposed to facilitate the successful operation of the development. Furthermore, the detailed design and aesthetic has been progressed to create a local landmark building which is architecturally significant and unique that will respond positively to the character and appearance of the surrounding area. The building will replace an existing unused car park which does little to contribute to the character and attractiveness of this edge to the town centre.

Through the pre-application process, the ground floor layout has also been revised to incorporate Secured by Design feedback. It has been advised by the Design Out Crime officer that if the correct tested and certified security products are installed, this design would likely secure an SBD award.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

2.1.3. Amenity

The scheme has been carefully designed to maintain the principles established by the extant permission. Technical reports assessing Daylight and Sunlight, Air Quality, Noise, and Wind & Microclimate impacts have all been prepared and are submitted to support the application, demonstrating the acceptable impact of the scheme on these respective matters. The external areas and terraces of the proposed building will be well-screened in sensitive locations, with public areas and all terraces managed by Dandi to ensure that they are effectively used for the benefit of guests and visitors and that there are no adverse amenity impacts to surrounding properties.

2.1.4. Landscaping and Public Realm

A key justification of the proposal is the significant landscaping and public realm benefits which will be delivered by the scheme. An enlarged and generous pedestrian and cycle shared use precinct creates an entrance to the aparthotel whilst also improving the approach to the underpass, delivering active frontages, passive surveillance and urban greening. A new stairway, along with the enclosure of a currently open undercroft, creates a high quality urban environment, defining this precinct to the north. New lighting and a unified level surface serve to link the space to both an extended footway on Vaughan Road, and a refreshed underpass network. The rotunda, a central light well within the network, is given a new identity through new planting, surfacing and lighting.

At ground level the landscape proposals include a series of new trees, each with a variety of understorey planting, climbing plants to both the front and rear of the building and a belt of native hedging and planting to the railway boundary.

2.1.5. Car & Cycle Parking

In keeping with relevant planning policy, and the highly sustainable location of the site (PTAL rating 6a), the proposed development will be car-free for future guests and visitors. The rear of the site features two blue badge spaces and one space for servicing vehicles – a provision of three spaces in total. Infrastructure supporting electric or Ultra-Low Emission Vehicles will be provided in line with Intend to Publish London Plan Policy T6 requirements and the provision of a fast charging point for both blue badge spaces. The neighbouring property to the west has a vehicular right of access to the rear of the property through the site; this right of access will be maintained.

Cycle parking and storage is provided internally at ground floor level for staff, and eight Sheffield bike stands are located at the front of the aparthotel for use by future guests and residents. The proposal includes the delivery of 10 long-stay and 16 short-stay cycle parking spaces, in accordance with the required emerging London Plan standards (Table 3.1).

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

2.1.6. Highways

It is proposed to use Vaughan Road for taxi pick up/drop off via the double yellow lines as agreed with LB Harrow. The proposed development will deliver new wayfinding signage in the area to improve pedestrian and cyclist legibility of the area surrounding the site. Improvements to the conditions on Vaughan Road include the provision of a new raised pedestrian “Copenhagen” crossing on Vaughan Road at the junction with Bessborough Road (A312); increased footpath width on the north side of Vaughan Road; and revised carriageway narrowing to prevent westbound traffic beyond the hotel entrance (while maintaining westbound cycle access).

2.1.7. Refuse & Servicing

The site will be serviced on-site to avoid any impacts of servicing vehicles parking on-street. The servicing and refuse arrangements have been carefully designed and informed by Velocity Transport Planning, and through pre-application discussions. A 25.7sqm refuse store is provided on the ground floor (south-west of the building), which is located adjacent to the access route from Vaughan Road. The refuse store will be naturally ventilated. Refuse collection vehicles will reverse onto the site for collections within 10m of the store.

The site form has been designed to ensure that the largest vehicles (refuse vehicles) can stop entirely within the site ownership boundary and will not block the highway or footway.

The site will generate 12 daily delivery and servicing trips which will occur on-site. The impact of the development on the highway network is expected to be minimal and accommodated without perceptible impact to other road users. LGVs will access and egress the site in forwards gear, with all turning movements taking place within the car park area.

On the on-site loading bay will be managed through the implementation of a Delivery & Servicing Plan.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

3. Application Site Overview and Context

This section of the statement seeks to identify, describe and outline the application site and the immediate and wider surrounding context relevant to the application scheme proposals.

3.1. Application Site Description

The application site comprises a 1,254sqm parcel of land located on the corner of Vaughan Road and Bessborough Road. The site comprises a disused Council owned car park which features 48 car parking spaces - three of which are dedicated disabled bays. The car park historically served the Town Centre and, therefore, has always played a supportive role in the function and accessibility of the Town Centre.

The site is bounded by 2-3 storey residential development to the west, a rail line to the north, the intersection of the A312 and Lowlands Roads with major raised junctions and pedestrian underpasses and a staircase to the east, and the A312 Road to the south with finer grain residential development to the south. The site is surrounded by high hedges and fences on three sides and a low wall with a wide entrance towards Vaughan Road. A single mature tree (not protected) is located along the site’s frontage with Vaughan Road, with shrub planting extending along the eastern boundary.

The site is constrained by a 3.0m deep no-build zone from the railway boundary at the rear of the site and a Thames Water trunk surface drain which traverses the south-eastern corner of the site. A vehicular right of access also extends across the site from the crossover on Vaughan Road to the rear garden of the adjoining property at No. 2b Vaughan Road.

Figure 1 - Aerial View of the site edged in Red (Source: Google Maps, 2020)

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

To the north and east of the site, across the rail line and road junction, lies Harrow Town Centre where the townscape is of a larger grain and greater scale and height. Located to the north of the site is a recently completed Morrisons/residential development extending up to 11-storeys. The site is on the edge of, but outside of, the designated Harrow Town Centre and the Harrow and Wealdstone Area Action Plan Intensification Area (see Figure 2 below), however it displays a number of characteristics of central / urban locations. There is a single vehicular access to the application site, at the eastern end of the Vaughan Road frontage. Pedestrian access to the site is also via Vaughan Road.

Figure 2: Application Site in Relation to Town Centre Boundary and Intensification Area Boundary (Source: Harrow and Wealdstone Area Action Plan)

The site has a PTAL of 6a reflecting its highly sustainable location. It is located within 400m of Harrow- on-the-Hill Station, which is served by National Rail and London Underground trains (Metropolitan line). The National Rail service at Harrow-on-the-Hill is provided by Chiltern Railways with services between Marylebone station and Aylesbury. West Harrow station is located within 800m of the site and is served by the Metropolitan underground line. Adjacent to Harrow-on-the-Hill station is Harrow bus station. There are bus stops within 200m of the site which is a result of the proximity to Harrow bus station despite the presence of a north bound bus lane on Bessborough Road. The roads surrounding the site are included within a Controlled Parking Zone (CPZ).

According to the Government flooding map, the site is located in Flood Zone 1 ensuring it has a low probability of flooding.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

3.2. Surrounding Area

The site is located 300 metres north-west of the Roxborough Park Conservation Area and there are a number of designated heritage assets within the wider surrounding area, including:

. Church of Our Lady and St Thomas of Canterbury and Presbytery (both Grade II listed buildings) to the south east; . Lowlands Sixth Form College (grade II listed building) to the east; and . Roxborough Park and The Grove Conservation Area to the south east.

The application site is located on an important, and currently underwhelming, corner where there is a transition between three areas with different architectural and urban characters. To the north of the site, across the rail line and road, lies Harrow Town Centre where the townscape is of a larger grain and greater height of buildings. Land uses include both commercial and residential. The architecture is predominantly contemporary but otherwise diverse in materiality, scale and appearance. Building heights range from 5-10+ storeys.

The residential character area located to the south/west of the site is referred to as West Harrow Village. As the majority of the buildings are Victorian or Edwardian terraces built in red brick, this area has a very homogeneous architectural appearance and residential atmosphere.

The area west of Bessborough Road has a very diverse architectural character composed of larger modern, postmodern and contemporary buildings mixed with historic terraces and villas in between. There are also various community uses in the area, including places of worship, libraries and a school.

The wider context of the site is one where there is a mix of building styles, forms and heights. The context is characterised of buildings that range from medium-rise buildings of 20-storeys to low rise 2- storey residential dwellings. Some of the key taller buildings are identified at Figure 3. The streets that border and surround Harrow Town Centre have a varied character which creates the transition from suburban residential streets to those with active frontages and greater public accessibility, which naturally are more varied in their scale and form.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

Figure 3: Existing Site in Surrounding Context

Figure 4: Proposed Aerial View of Surrounding Context

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

Figure 5: Existing View from Lowlands Road

Figure 6: Surrounding Tall Buildings in Harrow Town Centre

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

Listed below are the consented tall-building schemes within Harrow Town Centre, highlighting their distance from the application site. There are no approved developments in excess of 20-storeys.

. 51 College Road, HA1 1AA (former Post Office site); P/0737/15; Granted; 05.01.16; Up to 20- storeys; 0.4 miles from proposed development site (by car) . Sonia Court, Gayton Road Car Park, (Former Library Site), Gayton Road, Harrow, HA1 2HH (355 units); P/0291/16; Granted; 06.07.16; Up to 11-storeys; 1 mile from proposed development site (by car) . Former Cumberland Hotel (Harrow One), 1-3 St John's Road, Harrow, HA1 2EF; (204 units); P/4332/17; Granted; 05.07.18; Up to 16-storeys; 0.8 miles from proposed development site (by car) . Lyon House and Equitable House, Lyon Road, Harrow, HA1 2EW (287 units) ; P/3118/11; Granted; 31.10.12; Up to 14-storeys; 1.0 miles from proposed development site (by car)

Listed below are the consented tall-building schemes inside, and immediately outside, Wealdstone Town Centre (edge-of-centre locations). There are no approved developments in excess of 20-storeys.

. 55-59 Palmerston Road; P/2555/18; Awaiting legal agreement; Up to 9-storeys . 5-11 and 37-41 Palmerston Road and 27-33 Masons Avenue and Land Adjacent to 47 Masons Avenue, Harrow; P/1619/16; Granted; 29.08.19; Up to 17-storeys

There is currently a planning application under consideration by LB Harrow (validated on 18th May 2020) at 33-35 Lowlands Road (P/1656/20) for: Re-development to provide 9 -storey building with basement level comprising of 104 co-living units (use class sui generis) with communal living area; co- working space and cafe (use class a3) to ground floor level; proposed vehicle access; hard and soft landscaping.

An application has recently been submitted to LB Harrow (currently awaiting validation) for a Premier Inn hotel in the Town Centre. The site is Garden House, 5 St John’s Road, Harrow, HA1 2EE. The proposal is for a building of 10-14 storeys. The application is for 160 rooms and features a ground floor restaurant (facing onto Lyon Square).

The above description of the site and surrounding area and examples of consented tall building projects serves to indicate that the urban grain and visual landscape surrounding the site features several tall buildings, with other tall buildings in the pipeline. In this context the proposal (on the boundary of the town centre and at a prominent gateway to the town centre) would in our opinion be very much in keeping with the existing surrounding character and site context. Furthermore, the pipeline of tall buildings further highlights how the context of Harrow Town Centre will continue to evolve as it accommodates an increasing number of tall buildings (consistent with the town centre intensification strategy).

The urban grain surrounding the proposed development site is mixed in use and scale. The site presents a significant opportunity to deliver a statement building and transition in townscape at the gateway to the town centre, whilst also delivering improved public realm and linkages to the town centre. 17

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

4. Planning History

This section of the statement seeks to summarise the relevant planning history for the application site.

4.1. Extant Planning Permission

Figure 7: Visual of extant planning permission P/3468/17 (Adam Khan Architects)

The application site benefits from an extant planning permission (P/3468/17; Granted 25.10.17) for the re-development of the existing car park to provide a part-five part-eight storey building comprising 242sqm of workshop/commercial/community (Class A2/A3/B1/D1) space on the ground floor and 33 residential flats on the upper floors; amenity areas; landscaping with associated surface parking; bin and cycle storage; substation; and re-location of vehicle access off Vaughan Road.

The extant permission has not been implemented. There are a number of onerous obligations and planning conditions which apply to the planning permission which make implementation of the permission challenging and indeed now impossible within the remaining life of the permission as originally drafted. Under section 93A of the Town and Country Planning Act 1990, however, unimplemented planning permissions with time limits for implementation which were due to lapse between 19 August 2020 (when the Business and Planning Act 2020 provisions came into force) and 31 December 2020 are extended to 1 May 2021. Consequently, the time period to implement this extant planning permission (P/3468/17) is extended from 25 October 2020 until 1 May 2021.

The extant planning permission provides context to assess this latest application scheme for the site. As noted above, the different use now proposed has meant that a new approach to the height, scale, design and layout has been adopted albeit referencing clear established principles from the extant permission that are recognised and accepted.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

5. Pre- Application Consultation Process

This section sets out the comprehensive pre-application consultation process (as per the signed Planning Performance Agreement with LB Harrow – 21 May 2020) and community engagement consultation process that has been undertaken with regard to the development / design evolvement of the site. The consultation process has been undertaken with a wide range of stakeholders and interested parties in order to ensure a robust scheme has been designed.

Consultation has been carried out in accordance with the principles set out in legislation, including the Planning and Compulsory Purchase Act 2004 and the Localism Act 2011. Paragraph 39 of the NPPF (2019) also advocates pre-application engagement and community consultation:

“Early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties. Good quality pre-application discussion enables better coordination between public and private resources and improved outcomes for the community.”

5.1. LB Harrow Pre-application Meetings and Presentations

5.1.1. Concept Pre-Application Meeting

An initial high-level pre-application meeting was held with LBH on 15th October 2019, at which the opportunity that the site presents was discussed. No specific proposals were tabled at the meeting, but discussion focussed on the principle of hotel use and the need by the applicant to secure an increase to the height of the proposed building (compared to the extant residential permission) to achieve a hotel of c.180-200 rooms. The desire by LBH for any scheme to deliver highways and public realm improvements was discussed.

5.1.2. Pre-Application Meeting 1

Immediately on signing a planning Performance Agreement, the first formal pre-application meeting took place on 21 May 2020 and a scheme ranging from 8-storeys to a maximum 15-storeys featuring a roof top restaurant was presented to LBH officers. The key issues discussed related to the principle of the proposed use, immediate issues regarding the proposed height and scale of the building and its impact on townscape and protected viewing corridors, access and servicing, the potential for public realm improvements and proposed public consultation arrangements.

5.1.3. LB Harrow Design Review Panel (DRP)

These preliminary proposals were presented for independent review by the Harrow Design Review Panel on 8 June 2020. Written feedback was provided by the Panel following the presentation, in particular criticising the proposed scale, massing and height of the proposal, and highlighting the need for more developed design on access and servicing arrangements, room configuration and building services and sustainability.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

5.1.4. Pre-Application Meeting 2

A second pre-application meeting was held on 11 June 2020 at which a revised and more developed design for a building ranging from 7-storeys to a maximum 12-storeys was tabled. Discussion and feedback focussed on the appropriateness of the location for a tall building and justification for the proposed massing / height, the public realm complexities surrounding the site, access and servicing and agreed viewpoints for assessment purposes.

5.1.5. Major Development Panel (MDP)

The proposals were presented to the MDP on 8 July 2020, with the MDP providing generally positive feedback to the quality of the emerging scheme.

5.1.6. Design Review Panel Chair Review

A further Design Review Panel Chair Review was held on 20 July 2020 at which a more advanced design showing a building massing ranging from 7-storeys to 12-storeys was presented. Verbal feedback was provided following the presentation, in particular maintaining concern about the suitability of the site to accommodate the proposed scale, massing and height of the proposal, and its impact on the character of Vaughan Road.

5.1.7. Pre-application meeting 3 and Follow-Up Technical Workshops

Pre-application meeting 3 was held on 23 July 2020. The key discussion points included the developing architectural form and reference to local palettes, potential overshadowing and overlooking, noise, wind and air quality impacts. Concerns were repeated regarding the height of building in the context of neighbouring properties and its presence in townscape views.

A series of technical workshops were subsequently held to agree relevant outstanding matters relating to highways and drainage (27 July 2020) and landscaping and public realm (18 August 2020).

5.1.8. Pre-application meeting 4

The final pre-application meeting was held on 14 September 2020 at which a further revised building massing ranging from 5-storeys to a maximum 12-storeys featuring 129 suites, with the restaurant re- located from the top floor to the 5th floor with an associated external amenity space was presented. Positive feedback on detailing, public realm, materiality and reduction of the lower volume from 7- storeys to 5-storeys creating an improved relationship to the neighbouring residential buildings to the west. However, remaining concerns expressed on the 12-storey element, justification for this height and overlooking of neighbouring properties from the western elevation.

5.2. Greater London Authority (GLA)

Pre-application meetings were held with GLA officers on 30 July 2020 and 6 August 2020. The key comments provided (as per the GLA formal pre-application advice note – see: Appendix 1) included:

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

. Principle of Development - The proposal would contribute toward a demonstrated need for additional hotel bedrooms within London and could be supported in strategic planning terms, subject to meeting the sequential test. . Height, Layout and Massing - The height and massing arrangement of the proposed scheme does not raise any particular strategic issues given the site’s location on the edge of the town centre and opportunity area. . The proposed servicing yard is likely to impact on the amenity of neighbouring properties in terms of noise and air quality. Mitigation measures should be defined. . Architecture - The architectural approach is well considered. . Inclusive Access - Wheelchair accessible suites should be set out in accordance with the Intend to Publish London Plan (10%) . Transport - Pedestrian desire lines should be step free wherever possible, including travel from the north of the site towards the town centre and transport hub. . Cycle Parking - End of journey facilities including showers, lockers, dryer and cycle repair equipment should be provided for employees who commute to/from the site in accordance with Intend to Publish London Plan Policy T5. . Car Parking – Strongly supports the delivery of a car-free development. Provision of two blue badge parking spaces on-site within the rear servicing yard is considered acceptable in principle.

5.3. RAF Northolt

The Design Team has engaged with the Ministry of Defence (MoD) - RAF Northolt during the development of the proposals in order to ensure their acceptance of the proposed height (as the proposed development site lies within the statutory aerodrome height, bird strike and technical safeguarding zones surrounding RAF Northolt. RAF Northolt provided safeguarding feedback for both the 15-storey and subsequently amended 12-storey scheme, both of which they deemed to be acceptable and do not cause any safeguarding concerns. The MoD advised that if planning permission is sought and granted, it will be necessary for the developer to liaise with the MOD prior to the erection of any cranes or temporary tall structures.

5.4. Public Consultation

A Statement of Community Involvement (SCI) has been prepared by Terrapin Group to support this application submission consistent with the advice at paragraph 40 of the NPPF (2019) which states that local planning authorities should “encourage any applicants who are not already required to do so by law to engage with the local community” . NPPF paragraph 128 states that “Applications that can demonstrate early, proactive and effective engagement with the community should be looked on more favourably than those that cannot.”

It was agreed with Officers in an early pre-application meeting that community engagement with local stakeholders and amenity groups would be carried out. This was in order to inform residents and other stakeholders about the proposals, and to understand their views about the proposal and to take these views into consideration throughout the design development process.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

The Applicant sought to consult local stakeholders, including Ward Councillors at LB Harrow, local residents, and community groups. However, due to the ongoing COVID-19 crisis it was not possible to directly meet with local people or hold a public exhibition. In its place, a virtual consultation was conducted in which some 1,000 people engaged with the process.

Online public consultation was held between 30 July 2020 and 20 August 2020 using a dedicated website created by the Applicant’s project team. The consultation process for the application consisted of the following actions:

. A briefing meeting was held with Cllrs Marikar and Swersky of West Harrow Ward (4 August 2020) . Residents and businesses in the immediate vicinity of the site were sent a newsletter which outlined details of the scheme. The newsletter directed them to a dedicated consultation website to view the proposals and make comments . Paper versions of the website and survey form were made available to all those without access to the website

Further details on the public consultation feedback is set out in the submitted SCI.

The feedback provided through this public consultation exercise has been considered by the Applicant and been used by the design team to inform the iteration of the proposed scheme.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

6. Planning Policy Context

6.1. National Planning Policy Framework (NPPF) (2019)

Planning law requires that where regard is to be had to the development plan for the purpose of any determination made under the Planning Acts, the determination must be made in accordance with the plan unless material considerations indicate otherwise1.

In assessing and determining development proposals, the National Planning Policy Framework 2019 (‘NPPF’) states that local planning authorities should apply a presumption in favour of sustainable development. Where the development proposals accord with up-to-date development plan policies they should be approved without delay or where the development plan is absent, silent or out-of-date, planning permission should be granted unless:

. the application of policies in this Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed; or . any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

Paragraph 17 states decisions should ensure that developments:

a) “will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development; b) are visually attractive as a result of good architecture, layout and appropriate and effective landscaping; c) are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities); d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit; e) optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks; and f) create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.”

Paragraph 91 (criterion a) states planning decisions should “promote social interaction, including opportunities for meetings between people who might not otherwise come into contact with each other – for example through mixed-use developments, strong neighbourhood centres, street layouts that allow for easy pedestrian and cycle connections within and between neighbourhoods, and active street frontages”.

1 Section 38(6) of the Planning & Compulsory Purchase Act and Section 70(2) of the Town and Country Planning Act 1990 23

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

Paragraph 92 states planning decisions should plan positively for the provision of shared spaces, community facilities and local services to enhance the sustainability of communities and residential environments.

Paragraph 117 states, “Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.”

Paragraph 118 (Criterion d) seeks to, “promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained...”.

Paragraph 128 states “Design quality should be considered throughout the evolution and assessment of individual proposals. Early discussion between applicants, the local planning authority and local community about the design and style of emerging schemes is important for clarifying expectations and reconciling local and commercial interests. Applicants should work closely with those affected by their proposals to evolve designs that take account of the views of the community. Applications that can demonstrate early, proactive and effective engagement with the community should be looked on more favourably than those that cannot.”

6.2. The Development Plan

Section 38(6) of the Planning and Compulsory Purchase Act (2004) requires that applications for planning permission must be determined in accordance with the Development Plan unless material considerations indicate otherwise.

The statutory Development Plan against which the scheme is to be assessed comprises the following:

. The London Plan (2016); . The Intend to Publish draft London Plan (2019); . Secretary of State Directions on the Intend to Publish London Plan issued 13 March 2020 under Section 337 of the Greater London Authority Act 1999 (as amended) . L B Harrow - Core Strategy (2012); . L B Harrow - Development Management Policies (2013); . L B Harrow - Site Allocations (2013); . L B Harrow - Joint West London Waste Plan (2015); . L B Harrow - Harrow and Wealdstone Area Action Plan (2013)

The Supplementary Planning Documents (SPDs) against which the scheme also falls to be assessed include the following:

. Mayor of London - Sustainable Design and Construction SPG (2014); . Mayor of London - Environment Strategy (2018); . Accessible London: Achieving an Inclusive Environment SPG (2011); 24

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

. Mayor of London - Transport Strategy (2018); . Harrow Play and Informal Recreation SPG (2012); . Harrow Character and Context SPG (2014); . Harrow Access for All SPD (2006); . Harrow Planning Obligations SPD (2013); . Harrow Views Assessment (2012);

6.2.1. Draft New London Plan

A draft ‘Intend to Publish’ version of the new London Plan was published in 2020. Following ‘Examination in Public’ between Jan-May 2019, the Panel of Inspectors appointed by the Secretary of State issued their report and 55 recommendations. In response, on 9 December 2020, the Mayor issued the revised ‘Intend to Publish’ version of the London Plan to the Secretary of State, reducing the plan’s ten-year housing target by almost 20% from 649,350 to 522,850, and more than halving the Plan’s target for small sites, from 245,730 to 119,250.

In a letter dated 13 March 2020, the Secretary of State directed the Mayor to work constructively with London boroughs to encourage more housing delivery and to make several modifications to the new London Plan to bring it in line with the NPPF.

Under the GLA Act 1999, the Plan has to be approved by the Secretary of State before it can be adopted. At present, pending the Mayor’s response, it is unclear when/if the plan will be adopted. However, given the advanced stage of its preparation, the draft new London Plan is treated as holding significant weight in the determination of planning applications.

All of the relevant polices are thoroughly assessed within the Planning Assessment section of this report.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

7. Planning Assessment

This section of the statement seeks to set out the applicant’s assessment of the application proposals, considering the relevant development plan and policy context, as well as the relevant material considerations. The proposal seeks to deliver the key aims of national, regional and local planning policies by making effective and efficient use of highly sustainable brownfield land in London. The proposal has been design-led with a focus on delivering an exceptionally high-quality development to contribute towards a clear need for visitor accommodation in London and the immediate area, as well as supporting the vitality and character of Harrow Town Centre and its surrounding environs.

7.1. Land Use

7.1.1. Principle of Development – Aparthotel Need

Following a rigorous site selection process of the Council’s portfolio sites in 2014, the Vaughan Road car park site was identified by the Council as a suitable site for redevelopment. Under the consideration of the extant residential planning permission on the site (P/3468/17), the Council stated in its Committee Report that given the low intensity of the use of the car park, combined with the remaining capacity of the town centre car parks and the availability of car parking spaces on the surrounding street, that proposed development would not have adverse impacts on the vitality of the town centre or the convenience of parking on the surrounding streets. A proposed aparthotel use on the site is considered to have an equally acceptable impact. As there is no relevant policy relating to the loss of car parking within the borough, the application should be considered on its merits within the current policy context. As confirmed by pre-application engagement with LBH, the loss of a former car park to allow redevelopment for an alternative use to meet an identified need in the Borough is considered to be acceptable.

The proposed development site is located adjacent to Harrow Town Centre and Harrow and Wealdstone Intensification Area. Within this area the Area Action Plan (AAP) aims to deliver substantial employment growth through an uplift in retail and hotel development and office renewal in the town centres.

LB Harrow’s Core Strategy targets the development of circa 220 net additional hotel bedrooms in the 2011-2026 period for the Town Centre. The review of historic delivery undertaken by Savills in the accompanying Hotel Needs Assessment concludes that until now only 102 net additional bedrooms have been delivered within Harrow Town Centre. This results in a minimum need for 118 net additional bedrooms in the Town Centre by 2026, assuming no future loss of existing stock. However this estimated need is based on currently outdated evidence. Demand drivers for the hotel sector have continued to strengthen in recent times meaning hotel need figures have also increased.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

The London Plan (2016) and the Intend to Publish draft London Plan (2019) seek to support the visitor economy as well as the needs of businesses and leisure visitors to the capital, and highlight a strategic demand for new visitor bedrooms in London. Policy 4.5 of the current adopted London Plan (2016) identifies a need for a further 40,000 additional hotel bedrooms by 2036 while Policy E10 of the Intend to Publish draft London Plan (2019) identifies a need for an additional 58,000 additional bedrooms of serviced accommodation by 2041 (out of which 238 bedrooms are in LB Harrow). It is therefore evident that local and regional policies aim for a net increase in the number of hotel bedrooms in LB Harrow.

The need for additional hotel bedrooms is also supported by market evidence showing occupancy rates in LB Harrow and London overall being above 70%. This is the accepted industry benchmark for when hotel demand out-strips supply demonstrating the immediate need for additional supply. The supporting Hotel Need Assessment (produced by Savills) to support the application estimates that in order for occupancy rates in Harrow to fall to 70%, 120 net additional bedrooms are required. This additional requirement balances supply and demand in 2019 and does not take into account any future growth.

By taking the current need of 120 bedrooms and the GLA projected need of 238 bedrooms in Harrow for the period 2019-41 into account, a total need for 358 net additional hotel bedrooms in Harrow by 2041 is estimated. Under the most conservative approach, the hotel development pipeline consented or subject to current planning applications (even if approved) are not sufficient to cover this need as they result in a shortfall of 155 bedrooms. The proposal is therefore considered to contribute towards meeting this identified need.

The serviced accommodation sector has proven more resilient than traditional hotel sector in response to the market challenges presented by Coronavirus. This makes investments in the serviced accommodation sector such as aparthotels more attractive and resilient than traditional hotels in the current climate.

The proposed development also aspires to make Harrow a more popular destination by opening the aparthotel’s ancillary uses to the public, such as the fifth floor restaurant and external amenity space.

Harrow has one aparthotel with a capacity of only 25 bedrooms. This equates to only 3.6% of the total hotel supply in Harrow, clearly demonstrating that this part of the accommodation sector is underrepresented. Harrow is currently underprovided in terms of hotel bedrooms generally against London averages and the number of hotel bedrooms per Airbnb listing. Consequently, the proposal is contributing to meeting an identified shortfall.

In our opinion, supported by the submitted Hotel Need Assessment, the proposed development will directly seek to meet a clear, tangible and identified need for visitor accommodation within a highly sustainable and accessible location in the Borough. The principle of seeking to optimise and make efficient use of land complies with key national and local planning policies, including Intend to Publish London Plan Policy D3.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

7.1.2. Sequential Test

NPPF paragraph 86 states that local planning authorities should apply a sequential test to planning applications for main town centre uses which are neither in an existing centre nor in accordance with an up-to-date plan. As hotels are defined as a main town centre use in the NPPF and the site is located outside of Harrow Town Centre, a sequential test is required. Furthermore, LB Harrow Local Plan Policy DM34 ‘Hotel and Tourism Development’ states that:

Proposals for new hotel development outside of the Harrow & Wealdstone Intensification Area will be directed to sites in accordance with the following sequential order of preference: . town centres; . edge of centre; . areas with a high public transport accessibility level.

In accordance with these policies, a sequential test has therefore been undertaken (produced by Savills) and submitted in support of the planning application which demonstrates the suitability of this ‘edge of centre’ location and that it is a sequentially preferable location for the proposed use.

The Savills sequential test concludes that the application site is the most sequentially preferable location for the proposal, being located immediately adjacent to Harrow Town Centre and its transport hubs, and the development accords with the sequential approach to site selection set out in paragraph 86 of the NPPF and Policy DM34 of Harrow Council’s Development Management Policies Local Plan.

Policy DM34 further states that the Council will encourage the development and improvement of tourist related attractions and facilities, provided there is no unacceptable impact on the environment or residential amenity. This is highlighted through the production of various relevant supporting sub- consultant reports which are referenced through the Planning Assessment section.

Policy SD7 of the Intend to Publish London Plan states that consideration for town centre uses should be given to sites on the edge of centres that are, or can be, well integrated with the existing centre, local walking and cycle networks, and public transport only after a sequential test has demonstrated that no suitable town centre sites are available or expected to become available within a reasonable period. The proposed development site, with a PTAL rating of 6a, is in a highly sustainable location and is exceptionally well integrated with the existing town centre.

The sequential test undertaken confirms that there are no sequentially preferable sites in the town centre. Therefore, the required policy test has been satisfied and the application scheme proposals are considered to be acceptable in accordance with Policy DM34 and Policy SD7.

7.1.3. Occupancy & Management

An Operations and Management Plan prepared by the Applicant has been submitted to support the application highlighting the key day to day operations and how the aparthotel and associated supporting amenities and facilities will be managed. This can be further controlled and updated, if necessary, through a suitably worded planning condition. The Operations and Management Plan seeks to ensure that the aparthotel offers high quality accommodation that is well-managed and 28

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

serviced, whilst equally ensuring activities such as servicing, security, car parking, and guest services are well-managed to ensure there are no adverse impacts on the amenity of neighbouring properties.

7.1.4. Tall Building

Local Plan Policy DM1 provides details on the key elements of good design, layout and amenity that need to be considered for all scales of development. Under Policy DM3, the Local Plan recognises that whilst poorly located and designed buildings, and those of inappropriate height, could significantly detract from protected views, “visibility should not be conflated with harm. A truly outstanding design that is well located and designed to inspire, excite and delight the viewer may enhance a protected view even if it would exceed the threshold height of one or more landmark viewing corridors”. The Local Plan recognises that “new development may provide opportunities to open up new local views and vistas, or to create new landmarks in the townscape; where such opportunities exist they should be fully exploited through the design and layout of buildings and spaces” (paragraph 2.26).

Paragraph 5.15 of the Core Strategy recognises that the Intensification Area, which the site sits adjacent to, is suitable for locating tall buildings. There is no specific adopted Local Plan policy relating to tall buildings outside the Intensification Area. Whilst the application site is outside of the Area Action Plan boundary to which Policy AAP6 of the Harrow and Wealdstone AAP specifically applies, the policy states that building heights are to be of a scale consistent with the site’s surroundings having regard to context and the quality of the development. Parts C and D of Policy AAP6 set out criteria and requirements for taller buildings above the prevailing context. As recognised by the assessment of the extant permission, whilst the site falls outside the Intensification Area and AAP area, the site has a clear relationship with the town centre and has a similar central and urban character to this area.

Adopted London Plan Policy 7.7 relates to tall buildings and states that amongst other matters, they should have ground floor activities that provide a positive relationship to the surrounding streets and make a significant contribution to local regeneration and contribute to improving the permeability of the site and wider area, where possible.

The Intend to Publish London Plan (paragraph 3.91.) recognises that tall buildings can contribute to economic growth and make optimal use of sites that are well-connected by public transport and have good access to services and amenities. Furthermore, tall buildings can help people navigate through the city by providing reference points and emphasising the hierarchy of a place such as its main centres of activity, and important street junctions and transport interchanges. Tall buildings that are of exemplary architectural quality, in the right place, can make a positive contribution to London’s cityscape, and many tall buildings have become a valued part of London’s identity. The application proposals deliver and respond to all of these aims and objectives.

Intend to Publish London Plan Policy D9 states that development proposals should address visual impacts and consider the views of buildings from different distances and that proposals should take account of, and avoid harm to, the significance of London’s heritage assets and their settings. The supporting Heritage and Townscape Visual Impact Assessment (produced by: Turley) (discussed in more detail in the relevant section below) indicates that the proposal features an acceptable impact on surrounding heritage assets.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

In contrast to the concerns raised by LBH officers during the pre-application process, the GLA’s pre- application advice states that the proposed height and massing arrangement of the proposed scheme does not raise any particular strategic issues given the site’s location on the edge of the town centre and opportunity area. However, the GLA notes that the site falls outside the area defined as being suitable for tall buildings by Harrow Council and advises that any tall building on this site would therefore need to demonstrate exemplary standards of place making, contextual design, and architecture.

The GLA pre-application advice (see: Appendix 1) also noted that the original proposed seven-storey lower-massing element of the proposed aparthotel building appeared overbearing and inappropriate in relation to the two-storey houses along Vaughan Road. The Applicant was advised to consider a lower-rise option for this element to help mediate the discrepancy in scale more effectively. Consequently, the lower massing element was reduced from 7-storeys to 5-storeys to ensure a more acceptable relationship with the neighbouring residential dwellings on Vaughan Road and a more acceptable visual impact on the surrounding locality.

Our assessment of the proposed development against relevant policy relating to tall buildings is that the development is acceptable on the following bases:

. The building is of an exemplary quality design and architectural merit which is creative, innovative and contextual to the local townscape and incorporates the highest quality of materials and design . It will make a positive contribution to the existing and emerging skyline of Harrow . It will make a positive contribution to the local townscape, particularly in terms of legibility entering the Town Centre, and providing a gateway function in townscape terms . The scheme will deliver a more attractive and legible route from Vaughan Road and the surrounding area into Harrow Town Centre, thus providing for greater connectivity within the wider area . The scheme will deliver significant improvements and enhancements to the surrounding public realm and interface with the subway and adjacent underpass areas . The scheme sustains or enhances the significance of heritage assets and important views or vistas with only limited harm identified that is outweighed by the public benefits (see Heritage and Townscape Visual Impact Assessment by Turley Heritage) . The building will provide much-needed visitor accommodation to support the needs of London and the Borough . The restaurant and aparthotel use will encourage and support public access to afford views across Harrow and the local area . The scheme will contribute to the ongoing regeneration of this surrounding area.

The application proposal’s height and form transitions and responds to the site’s context, with a stepped form, whilst also embracing an exemplary design. The tallest element responds to the adjacent Morrison’s building and context of current and emerging taller buildings north and south of the railway line. Whilst the site is not specifically identified to accommodate a tall building, the site is located on a key intersection and gateway location to Harrow Town Centre. By capitalising on the site’s location with commercial activity at ground floor level, a focal point of activity can be created. This together with place-making principles and provision of public realm adopted in the design, will create 30

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

a new node for the local area. It is therefore considered that site is suitable for a development of this nature.

Given the above, and the comprehensive submission documents, the proposals are considered to be compliant with London Plan Policies 7.7 and D9, as well as meeting the aims and objectives of local policies relating to tall buildings, including Policy AAP6, Policy DM1 and Policy DM3.

7.2. Design

The proposed development will introduce a built form of high quality architectural design onto a site which is currently a disused surface car park. It will result in a new focal presence at a key nodal point and also gateway into Harrow town centre. The proposed façade treatments of the building with a fine window grid and recessed elements will create texture and visual interest. The stepped levels and scalloped form will also help to reduce the perceived massing of the building and the use of brick and stone in combination with terracotta take reference from the material palettes used in local residential terraces.

The full supporting material to this application submission shows how the design of this scheme would employ high quality facing materials and elevational detailing that responds to the existing palette of the local area, and also how the form and massing of the building has been modelled – stepped and sculpted - to reflect its landmark new use, location at a key transition point or gateway into the town centre from the southern suburbs, as well as to add interest to its silhouette and crown in longer distance views. An integral part of the scheme is also the proposed new hard and soft landscape and planting; to contribute to much needed local public realm improvements, both at the base of the new building and further greening to the upper terraces of the building itself.

The scheme has been designed to a high architectural standard in line with Policy DM1: Achieving a High Standard of Development. The architectural design and materials, selected to respond to the architectural context of the site, are of high quality. The proportions, elevational treatment and overall architecture achieves a quality and distinction appropriate for the new use and wider townscape role of this building.

The proposal accords with Local Plan Policy DM1 and Policy DM12: Sustainable Design and Layout by ensuring the design and layout of the building incorporates measures to mitigate any significant noise or air pollution arising from the future use of the development. The design delivers a sculpted massing of three interlocking blocks with a variation in height.

The GLA’s pre-application response (see: Appendix 1) stated that the architectural approach is well considered and demonstrates a strong contextual design response.

7.3. Heritage and Townscape

7.3.1. Heritage

The Site is not designated as a heritage asset nor has it been locally identified as a heritage asset and there are no heritage assets in the immediate vicinity. There are, however, a number of designated

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

and also non-designated heritage assets (comprising listed buildings, a conservation area, and LBH locally listed buildings) within the wider surrounding area. A Heritage and Townscape Visual Assessment (HTVIA) has been produced by Turley in order to assesses the likely effects of the proposed development on the built heritage, townscape and visual receptors of the site and its surroundings.

Turley’s assessment identifies that the proposed development will have no direct impact on either designated or non-designated heritage assets. Indirect effects (through change within the shared townscape settings and some shared views of the identified designated and non-designated heritage assets within the wider surrounding area) would in all cases save one (the parish church of St Mary, Harrow-on-the-Hill) be nil / neutral, i.e. the indirect impacts would sustain rather than harm the significance of those heritage assets.

Turley’s assessment identifies that the proposed development - and in particular the physical presence of a taller and more prominent building - within the wider setting of, and also some longer distance views towards, the landmark listed church on Harrow Hill would result in a degree of harm to its heritage significance. Their assessment, however, is that any such harm to the significance of this listed building as a result of these indirect effects would be minor, and at the lower end of the scale of ‘less than substantial’ as defined by the NPPF.

NPPF paragraph 196 specifically concerns proposals which would lead to ‘less than substantial’ harm to the significance of a designated heritage asset. It states that under these circumstances any such harm should be weighed against the ‘public benefits’ of the proposals overall, including where appropriate securing the optimum viable use of the asset. The term ‘public benefit’ is defined in NPPG as anything that delivers economic, social and environmental progress as described in the NPPF. The public benefits that would flow from the proposed development are manifold as described in this Statement.

In our opinion, therefore, any minor and less than substantial harm caused to the significance (and setting) of the designated heritage asset and listed building St Mary’s Church as a result of the proposed development would be outweighed by the significant public benefits that this scheme would deliver overall, in the terms of the NPPF as read as a whole (and also in light of the overarching statutory duty of the Planning Act 1990 where relevant).

7.3.2. Townscape

The site is located within the outer areas of the following protected viewing corridors identified in the Harrow Views Assessment:

. 06 Harrow Recreation Ground . 10 Old Redding . 11 Proposed Country Park at Wood Farm

Local Plan Policy DM3: Protected Views and Vistas states that protected views will be safeguarded in accordance with the Harrow Views Assessment (2012) and the London Views Management Framework (LVMF). Specifically, development within the wider setting consultation area should form 32

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

an attractive element in its own right and preserve or enhance the viewer’s ability to recognise and to appreciate the landmark. The proposed scheme has been designed to avoid any impact on these identified views.

Consistent with the requirements of Policy DM3, Turley’s HTVIA assessment explains, evaluates and justifies the visual impact of the proposed development on the protected views identified by testing thirteen representative viewpoints agreed with LB Harrow officers. This assessment represents a key tool to help appreciate the likely impacts of the scheme.

This testing confirms that the proposed development does not fall within a landmark viewing corridor in any of the identified protected views. The site does, however, fall within the wider setting consultation area for two of the identified protected views (RV8 and 9). Under such circumstances Local Plan Policy DM3 (criterion b) requires that new development should form an attractive element in its own right, and also preserve or enhance the viewers’ ability to recognise and to appreciate the landmark church / hill and its existing visual prominence.

From the protected view at Harrow Recreation Ground (RV8), the character of this view would change as a result of the proposed development. However, Turley conclude that such change would overall accord with the relevant objectives of Policy DM3 (criteria b, c and e). The new building would form an attractive element in its own right within this view, and would also preserve the viewers’ ability to recognise and to appreciate the landmark church on the hill. The proposed development would also accord with criterion g of this local policy, which encourages opportunities to create new local views and vistas through the design and layout of new development.

From the protected views at Old Redding (RV9) and at Wood Farm (RV10), the overall character and composition of the views would remain intact, and the viewing corridor to the steeple of St Mary’s would be unhindered. This would accord with the objectives of Policy DM3.

Save in respect of the adverse impact on residents of immediately adjacent residential properties on Vaughan Road and on the representative view from Harrow Recreation Ground (RV8), all impacts are assessed as neutral or beneficial.

7.4. Landscaping, Public Realm & External Lighting

7.4.1. Landscaping and Public Realm

Landscape and public realm design are significant components of the proposals. The Applicant is committed to making significant improvements to the immediate public realm around the aparthotel, whilst also improving connectivity, security and safety on this key route into the Town Centre. These improvements are described in detail in the supporting Landscape & Public Realm Design & Access Statement produced by Adams & Sutherland.

The immediate adjacency of the site to a complex and well used public realm network of underpasses and bridges is a defining characteristic of the project and presents a tremendous opportunity for proposals to deliver, and animate, integrated improvements to a space that has proved (and is

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

recognised in the AAP to be) problematic. The architectural strategy embodies these opportunities, and an enhanced wider public realm is an integral part of the development proposals.

The public realm strategy optimises external spaces created around the building and also includes proposals for improvements to the adjacent underpass network delivering a positive transformative impact on its immediate surroundings and enhancing the pedestrian environment.

An enlarged and generous pedestrian and cycle shared use precinct creates an entrance to the aparthotel whilst also improving the approach to the underpass, delivering active frontages, passive surveillance and urban greening. A new stairway, along with the enclosure of a currently open undercroft, creates a high quality urban environment, defining this precinct to the north. New lighting and a unified level surface serve to link the space to both an extended footway on Vaughan Road, and a refreshed underpass network. The rotunda, a central light well within the network, is given a new identity through new planting, surfacing and lighting.

On upper floors the priority is to inhabit roof spaces and maximise greenery on the site. Extensive planting, including small trees and shrubs, defines the character of the 5th floor terrace, which will be used by both the public restaurant and by aparthotel residents. A balance of native and other species has been used to enhance the significantly improved biodiversity. The flat roofs of the restaurant and top floor plant room are biodiverse green roofs while dense planting characterises intermediate terraces around the building. The green roof on the plant room is also a biosolar roof accommodating PV panels at no loss to the green amenity. An Urban Greening Factor value of 0.313 is achieved.

Blue roofs form the basis of the roof terrace construction with planting and surfacing placed over them. A rain-water collection tank and associated irrigation system is provided. Paving at ground floor both within and without the site boundary is permeable.

Detail design of the wider public realm will be developed in close partnership with LBH and it is proposed that the project will subsequently deliver these improvements on behalf of LBH through a s.278 Agreement.

7.4.2 External Lighting Strategy

An external lighting strategy has been produced by Michael Grubb Studio to support the application and to be read in association with the proposed Landscaping and Public Realm strategy (as set out in the DAS prepared by: Adams & Sutherland). Working with the landscape design features and structure of the building, a unique approach to the courtyard lighting for the Aparthotel has been designed which avoids the necessity to add column lighting, an approach otherwise commonly chosen. Integrated linear LED lighting, of the ground floor Aparthotel archways, creates a decorative aesthetic and enhances the architecture. These luminaires will create sufficient light for the courtyard, when used in conjunction with the other lighting, providing a focus that gives light to the people and place, rather

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

than an approach that opts for the downward lighting of columns that features the structure and form of the building only.

Other items in the landscape provide attractive opportunities for lighting, therefore we have used integrated lighting within the planters, uplighting to the trees and the use of handrails for lighting those specific items. Wall lights, near the entrance to the courtyard, connect adjacent spaces linking the public realm and courtyard. Additionally, the wall lights increase the overall light levels from the opposite side of the Aparthotel facade. This will assist people in gaining better human recognition of others and reduce harsh shadows, overall resulting in an improved sense of security and providing better image definition for CCTV.

The approach for the dining and planting terraces is to providing lighting that only points down at a low level. This will create warm and inviting spaces for the aparthotel users, but avoid light pollution beyond the extent of the building. Warm white light is used to create a sense of calm for those environments, providing the reassurance of a safe, welcoming environment and without obstructing views to the surrounding spaces.

The public realm enhancements to the underpass system lead from the Vaughan Road aparthotel to Harrow-on-the-Hill station, town centre and further areas of interest. Many visitors to the aparthotel arriving by foot, or using the underground or town centre, will experience these spaces and therefore these areas need some remedial works. This is to bring those spaces up to an acceptable standard that shows Harrow in a positive light, as well as enhances the experience and sense of safety and security experienced by visitors to the aparthotel. Michael Grubb Studios' site visit, during the day, alongside firsthand experience of the town and surrounding area have provided a balanced overview to assess how lighting improvements could benefit the space at night.

Although lighting is one item, there is a lot of redundant and outdated equipment which enhances the impression of a lack of safety throughout the underpass system. Broken and large screens with real time video from each exit are likely to have been out of service for some time.

7.5. Economic Benefits and Social Value

As identified in Savills’ Economic Benefits Assessment of the proposed scheme will provide direct and indirect job opportunities. The aparthotel and its ancillary uses are expected to create 50 permanent direct operational (FTE) jobs – 24 on-site hotel jobs, 17 on-site restaurant jobs and 9 on-site retail and café jobs, 45 indirect jobs and 94 on- and off-site construction jobs per year (for the estimated 1.5 year construction period) resulting in £1.9 million in net additional gross value added (GVA) to the Harrow economy.

The aparthotel will also bring an additional £9.8 million per annum of tourist spending in the local area and benefit LB Harrow to the tune of £2.6 million over 20 years through additional local government revenues including business rates and CIL.

The construction of the proposed development would also have a positive social value impact delivering multiple benefits to the local community. The benefits from returning to work, apprenticeship

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

opportunities and NHS savings, local procurement and greening of the neighbourhood are estimated by Savills to provide a total social value in monetary terms amounting to £2.5 million.

7.6. Transport & Highways

The following reports have been produced by Velocity Transport Planning to support the application, consistent with Local Plan Policies DM43 and DM44:

. Transport Assessment . Travel Plan . Delivery and Servicing Plan . Construction Logistics Plan . Road Safety Audit . Waste Management Plan . Site Waste Management Plan

7.6.1. Transport Assessment

In accordance with relevant planning policy, and the highly sustainable location of the site (PTAL rating 6a), the proposed development will be car-free for future guests and visitors. The rear of the site features two blued badge spaces and one space for servicing vehicles – a provision of three spaces in total. Infrastructure supporting electric or Ultra-Low Emission Vehicles will be provided in line with Intend to Publish London Plan Policy T6 requirements and the provision of a fast charging point for both blue badge spaces. A vehicular right of access to the neighbouring property to the west will be maintained.

It is proposed to use Vaughan Road for taxi pick up/drop off via the double yellow lines as agreed with LBH. Proposals include delivery of new wayfinding signage in the area to improve pedestrian and cyclist legibility of the area surrounding the site. As part of the development improvements to the conditions on Vaughan Road, the proposals include the provision of a new raised pedestrian “Copenhagen” crossing on Vaughan Road at the junction with Bessborough Road (A312); increase footpath width on the north side of Vaughan Road; revised carriageway narrowing to prevent westbound traffic beyond the hotel entrance (while maintaining westbound cycle access).

7.6.2. Parking

The loss of the car parking area was not opposed by LBH as part of the extant residential planning permission considerations (P/3468/17).

The proposed development has been designed following Healthy Streets principles and follows the transport principles of Good Growth (set out in the Mayor’s Transport Strategy). The site location

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

provides excellent access to public transport; encourages people to choose to walk and cycle; is inclusive and accessible; encourages carbon-free travel; and has a strategy for efficient on-site delivery and servicing.

The proposed development trip generation has been forecast and the proposed development is expected to generate a net increase of 20 and 86 person trips in the AM and PM peak hours, respectively. A total of 979 additional new trips are forecast to occur across an operational day. Most trips to and from the proposed development, 51% of arrivals and 55.9% of departures, will be undertaken by foot, 42.5% of arrivals and 37.8% of the departures will be undertaken by public transport. The site is expected to generate a total of thirty taxi trips and two two-way car trips on a daily basis.

The site will generate 12 daily delivery and servicing trips which will occur on-site. The development the impact on the highway network is expected to be minimal and accommodated without perceptible impact to other road users.

The proposed development is suitably located and designed to maximise the potential for sustainable travel and minimise impacts on the local transport networks through appropriate access, public realm, parking and servicing strategies. The proposed development is therefore sustainable and considered to be appropriate in principle.

The proposed development will have a negligible transport impact and will contribute significantly to the improved permeability of the site resulting in wider transport benefits. The development delivers local and strategic transport planning policy and provides safe and suitable access, parking and servicing arrangements.

The Transport Assessment has also thoroughly considered the proposals in the context of current and emerging planning policy and demonstrates compliance of policy requirements has been met and appropriate in principle.

7.6.3. Servicing

The site will be serviced on-site to avoid any impacts of servicing on-street. Substation will be located via Vaughan Road in front of the Hotel gate for 24hr access. The rear court provides access to the plant rooms. Plant space is located in the north and west of the building with access via dedicated doors which are sized for replacement of plant equipment. All windows from first floor are inward opening to be cleaned from the inside. Permanent, robust low maintenance materials are proposed for all building facades and external landscaping. All roofs are flat with access to main amenity terrace via both cores. Plant will be located on the 12th floor roof with managed access for plant equipment & roof maintenance via the north staircase and access hatch. Terraces without 1100mm balustrades will be maintained with the use of clip-on fall arrest systems.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

that the largest vehicles (refuse vehicles) can stop entirely within the site ownership boundary and will not block the footway. Service vehicles will access and egress the site in forward gear.

7.6.4. Refuse

Refuse collection vehicles will reverse onto the site for collections within 10m of the store. The site form has been designed to ensure that the largest vehicles (refuse vehicles) can stop entirely within the site ownership boundary and will not block the footway. A ventilated refuse store is provided at ground floor adjacent to the access route from Vaughan road. Due to the depth of the site and only the southern boundary being adjacent to the public highway accessible to refuse vehicles, the distance from the northern core to the refuse area is approximately 25m. Scheme proposes commercial waste contractor collection 5x a week and accommodates 2 days storage in accordance with the weekly volume arising rates set out in BS59 06:2005. Refuse storage accommodates:

. 3 x 1100 litre Eurobins . 3 x 1280 litre Eurobins . 3 x 240 litre wheeled bins

A Draft Delivery and Servicing Plan has been prepared to support the planning application as a standalone document in order to manage refuse, delivery and service vehicle arrangements and overall site accessibility, in keeping with Intend to Publish London Plan Policies T4 and T7.

7.7. Drainage

A Drainage Strategy has been prepared by MLM Group the schemes proposed foul and surface water drainage strategy detailed within the report identifies the intended means of connection and discharge of estimated peak flows. The design team have liaised with Harrow Highways / Infrastructure team and Thames Water throughout the pre-planning stage and have received confirmation in principle that both the surface water and foul water strategies are acceptable.

7.7.1. Foul Water

. The developments foul water connection is based on a peak flow rate of 8.2 l/s discharging into the existing Thames Water manhole EXFW A to the West of the development in Vaughan Road. . Thames Water have confirmed that the proposed peak flow rate and connection into their foul sewer in . Vaughan Road is acceptable in principle and will not have a detrimental effect on their network. . Connection details of the proposed Section 104 gravity sewer within Vaughan Road into the existing Thames Water foul manhole will be subject to confirmation of the invert level.

7.7.2. Surface Water

The development’s surface water will discharge at a maximum of 5l/s for all storms up to and including the 1 in 100 year storm event, plus 40% allowance for climate change. The development will discharge via the existing car parks outfall lateral outfall.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

Thames Water have confirmed that the proposed surface water discharge rate, adoption of the 150dia. lateral and ultimate connection into their trunk sewer below site is acceptable in principle and will not have a detrimental effect on their network.

An approved Thames Water pre-planning enquiry has been received for the developments foul and surface water discharge. Refer to Appendix B for details.

Both connections will be subject to Thames Water full technical approval at detail design.

7.8. Amenity

The building has been designed to reduce direct overlooking and ensure an acceptable impact on the residential amenities of neighbouring occupiers, such as through the use of angled facades. It also has been designed to reduce a sense of enclosure for future guests of the aparthotel, in keeping with Local Plan Policy DM1. The stepped height and sculpted form seeks to minimise impacts on the immediate neighbouring properties. In particular, the 5-storey element seeks to maintain a scale and form similar to that approved under the extant permission. The 12-storey element is stepped closer to the railway line and further away from neighbouring properties. It is considered that the extent of change between the extant permission and the proposed development, in respect of impact on neighbouring properties, is acceptable.

The provision of biodiverse terraces and planting create a visual buffer between some hotel suites and users of the terrace and the neighbouring Vaughan Road properties on the south and west facades. Furthermore, a transient hotel population creates less overlooking concern than with a residential building.

Other aspects relating to amenity are covered in the technical reports on Daylight and Sunlight, Air Quality, Noise and Wind & Microclimate submitted as part of this planning application.

7.8.1. Daylight, Sunlight and Overshadowing

A Daylight, Sunlight and Overshadowing Assessment has been prepared by Point 2 Surveyors. This report assesses the daylight, sunlight and overshadowing effects of the proposed development on the surrounding residential properties as well as the availability of daylight and sun on ground internally within the scheme. This analysis has been undertaken in accordance with the advice and recommendations set out in the BRE Guidelines ‘Site Layout Planning for Daylight and Sunlight: A Guide to Good Practice’ (2011).

The calculations within the report are based upon a 3D contextual model created from ZMap, alongside the submitted 3D model, plans, elevations and sections that have been prepared by Adam Khan Architects. The technical analysis demonstrates that the majority of surrounding residential properties will fully adhere to the BRE Guidelines for daylight (VSC and NSL) and sunlight (APSH) following the implementation of the proposed development. The report highlights how 24 Bessborough Road, Harrow Spiritualist Church and 2-2a Vaughan Road will experience minor isolated breaches in guidance. These properties retain good levels of daylight and sunlight for an urban environment and, in Point 2 Surveyors’ opinion, the overall effect of the development is considered minor. 39

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

In terms of overshadowing, three of the four areas assessed in the report will adhere to the BRE Guidelines for Sun on Ground. The remaining rear garden serving 2b Vaughan Road will experience a change in direct sunlight beyond guidance, however the change is almost identical to the 2017 extant planning permission. In terms of the internal levels of daylight within the new accommodation, 100% of the rooms tested will meet the 1% ADF value suggested within the BRE Guidelines for bedrooms. , Point 2 Surveyors conclude that the application scheme is considered to be acceptable in respect of daylight, sunlight and overshadowing considerations.

7.8.2. Air Quality

An Air Quality Assessment has been prepared by Air Quality Consultants Ltd. The assessment demonstrates that future occupants of the Vaughan Road aparthotel will experience acceptable air quality, with pollutant concentrations below the air quality objectives. Additional traffic associated with the proposed development will have an insignificant effect on existing receptors.

During the construction works, a range of best practice mitigation measures will be implemented to reduce dust emissions and the overall effect will be ‘not significant’. Appropriate measures have been set out in Air Quality Assessment report and included in the Construction Environmental Management Plan for the works. Overall, the construction and operational air quality effects of the Vaughan Road aparthotel are judged to be ‘not significant’. The proposed development has also been shown to meet the London Plan’s requirement that new developments are at least ‘air quality neutral’.

7.9. Sustainability and Energy

In keeping with GLA Energy Assessment Guidance and Intend to Publish London Plan (2019) Policies GG6, SI 1, SI 2, SI 3, SI 4, SI 5, SI 7, SI 12 and SI 13, London Plan (2016) Policy G5, 5.2, 5.3, 5.4, 5.6, 5.7, 5.9, 5.10, 5.11, 5.12, 5.13, 5.15 and 5.17, Verte Ltd have produced the following documents to support the application:

. Sustainability Statement (inclusive of Energy Report) . Whole Life Carbon Assessment . Circular Economy Statement

London Plan (2016) Policies 2.18, 5.10 and 5.11 and London Plan Intend to Publish Version (2019) Policies G1 and G5 embed urban greening as a fundamental aspect of site and building design.

The proposed development currently achieves a 73% carbon dioxide emissions onsite reduction relative to the current Building Regulations Part L2A Baseline. Of this, a 16% reduction results from measures within the Be Lean tier of the energy hierarchy alone, demonstrating a very positive result in minimising energy demand through passive design measures. The proposed development benefits from a water waste heat recovery system and the application of high efficiency heat pump technology, which significantly reduces the carbon dioxide emissions associated with the operation of the development. The current carbon reduction figures also account for the inclusion of a photovoltaic (PV) array, with the Be Green stage achieving 61% carbon dioxide emissions reduction. 40

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

The development team is adopting a Circular Economy strategy to maximise resource use, including material reuse, designing out waste, embodied carbon reduction, zero waste to landfill during construction and operation, onsite waste treatment and processing, and onsite renewable energy generation. The strategy has been developed by the design team into a Circular Economy Statement (Verte, 2020), including considerations for designing for assembly and disassembly, increased recycled content and responsible sourcing.

The scheme achieves compliance with all the stated GLA London Plan policies.

7.10. Noise

A Noise Impact Assessment has been prepared by Anderson Acoustics and is submitted as part of this planning application. This report is concerned with the impact of existing sources of noise that would affect the proposed aparthotel bedrooms, and also the noise from any plant associated with the development affecting existing residential receptors, for which noise emission limits have been determined at this stage.

Consideration has also been given to noise from collections and deliveries and the operation of the restaurant.

In accordance with the standard requirements of LBH, at the heart of the assessments is the guidance in BS 8233 and BS 4142. Whilst the scheme is an aparthotel rather than a residential development, these standards remain applicable. One difference, however, is that LBH will not be responsible for dealing with any complaints from future occupants regarding external noise sources. Accordingly, the information in this regard is presented for interest only in terms of the planning application.

The 3D noise model of the site and surrounding area has been used to calculate the ambient and maximum sound levels around the building in keeping with the adopted noise criteria. Anderson Acoustics findings are that a range of sound insulation performances are required around the building, from that achieved by a partially open window in a few instances, to a requirement for better than standard glazing in others. This is stated in detail within the technical report and summarised in Table 6.1 and the figures in Appendix D of their report.

Whilst full details are yet to be determined at this stage, it has already been established following the assessment work to date that mechanical cooling will be provided to each hotel room. This means that there would no requirement to open windows for this purpose (though windows can still be openable for purge ventilation and/or connectivity to the outside at the occupant choice), and, therefore, there is no need to consider the overheating condition. Example glazing specifications are proposed to meet the range of required sound insulation in order to achieve the adopted internal noise targets. The sound levels in the outdoor amenity spaces (i.e. the balconies and terraces) have also been considered. This indicates that levels will generally be no more than the standard limit of 55 dB.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

7.11. Fire Safety

A Fire Strategy has been prepared by BB7 to support the submission, in accordance with Intend to Publish London Plan Policy D12.

The Vaughan Road Aparthotel has been designed for fire safety using the published guidance in Approved Document B volume 2: 2019 (ADB2).

Evacuation is based on simultaneous escape from all parts of the building, with the exception of one commercial unit at ground floor, which has completely independent means of escape and is therefore not required to evacuate at the same time.

Fire detection and alarm will be provided in accordance with BS5839: Part 1 with a link to the suppression system to raise an early warning of fire. Escape from the apartments will meet travel and capacity limits. A specialist fire engineering smoke extract system will be employed in the aparthotel corridor at levels 01 to 04. This will be designed to maintain tenable conditions for means of escape and firefighting. Effectiveness of the system will be demonstrated using CFD modelling analysis.

The premises will be protected by a water sprinkler system designed and installed to BSEN12845 and periods of fire resistance for the structure and fire compartmentation walls and floors will all meet the guidance periods in ADB2.

Materials used in the construction of the external walls will meet the latest regulation and guidance requirements with classification A2-s1, d0 or better. Separation from the site boundary will also meet guidance recommendations to limit fire spread to neighbouring properties.

Fire service access will be from Vaughan Road into a protected firefighting shaft with a firefighting lift, vented lobby and dry rising main to deliver water to each floor.

The overall fire strategy for the Vaughan Road Aparthotel will deliver a package of safety and protection measures to meet the requirements of Part B to the Building Regulations.

7.12. Wind and Micro Climate Assessment

A Wind and Micro Climate Assessment has been produced by RWDI to assess the likely wind conditions around the proposed development.

Wind conditions around the Proposed Development would be expected to range from suitable for sitting use to walking use during the windiest season. During the summer season wind conditions would be expected to range from sitting use to strolling use. Windier than suitable conditions would be expected at the entrance location at the south-east of the Proposed Development, and at the fifth-floor communal roof terrace. As such these areas have been designed to incoroprate mitigation measures.

All other areas around the proposed development are expected to have suitable wind conditions for their intended use throughout the year and as such do not require mitigation measures.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

Mitigation measures in the form of design features as well as hard and soft landscaping have been recommended and are incorporated to ensure the development is acceptable.

7.13. RAF Northolt Safeguarding

RAF Northolt provided safeguarding feedback for both the 15-storey and subsequently amended 12- storey scheme, both of which they deemed to be acceptable and not to cause any safeguarding concerns. The MoD advised that if planning permission is sought and granted, it will be necessary for the developer to liaise with the MOD prior to the erection of any cranes or temporary tall structures.

7.14. Ecology

A Preliminary Ecological Appraisal and Biodiversity Metric has been undertaken by Phlorum in order to determine whether any ecological constraints could affect the proposed works for the site. At the time of survey, the site was comprised predominantly of hardstanding, with hedgerows, ruderal vegetation and interspersed trees along the northern and eastern boundaries.

The site is not subject to any statutory or non-statutory designations. The closest statutory site is Grove Farm LNR located approximately 2.5km to the south at its closest point. The survey area does not support any features that contribute to the designation of this site.

No further protected species surveys are recommended. A precautionary approach to vegetation clearance in respect to breeding birds and stag beetles is recommended to minimise any adverse impacts on these species group.

The scheme design responds to Phlorum’s recommendation that the site is enhanced by introducing some compensatory planting and installing bat and bird boxes.

In keeping with Local Plan Policy DM20, with regard to Biodiversity Metric, the proposed development results in a total net increase of 101.36% for habitat units, and a total net increase of 2.55% for hedgerow units, based on the proposed landscape plans compared to the baseline situation. The hedge planting will comprise of a high number of native species which will enhance biodiversity. The dominant habitat type is hardstanding and the other habitats on site consisted of hedgerows running along the northern and eastern site boundaries, with trees interspersed, and ruderal vegetation was observed around the edges of the site.

7.15. Health Impact Assessment

A Health Impact Assessment has been prepared by Savills and considers the health impacts of the proposed development based on the NHS London Healthy Urban Development Unit (HUDU) Rapid Health Impact Assessment (HIA) tool. The assessment has been conducted in accordance with London Plan Policy 3.2 Improving Health and Addressing Health Inequalities, which states at Policy 3.2 C: ‘The impacts of major development proposals on the health and wellbeing of communities should be considered, for example through the use of Health Impact Assessments (HIA).

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

The assessment has also been conducted in accordance with Good Growth Objective 3 (GG3) Creating a Healthy City of The Intend to Publish London Plan (2019), which states at GG3 D that: ‘To improve Londoners’ health and reduce health inequalities, those involved in planning and development must assess the potential impacts of development proposals and Development Plans on the mental and physical health and wellbeing of communities, in order to mitigate any potential negative impacts, maximise potential positive impacts, and help reduce health inequalities, for example through the use of Health Impact Assessments’.

The report first reviews the purpose and relevant guidance for undertaking a HIA and presents a health profile of LBH residents drawing on published studies. The health of Harrow residents is generally better than the England average. Many health indicators for Harrow residents are significantly better than the England average such as life expectancy for both men and women. However, the London Borough of Harrow has a relatively high level of polarisation with notable differences in health between the least and most deprived areas of the borough.

The HIA assesses the impacts of the proposed development across eleven themes relevant to the health of visitors to the aparthotel and the local community. Overall, the proposed aparthotel development is expected to have an overall beneficial impact on the health and wellbeing of the incoming visitors and local residents. There were no responses that indicated an adverse impact could be expected and therefore no mitigation or enhancement actions are proposed.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

8. Planning Conditions and S. 106 Obligations

8.1. Planning Conditions

Paragraph 55 of the NPPF states that planning conditions should only be imposed where they are necessary, relevant to planning and to the development to be permitted, enforceable, precise and reasonable in all other respects.

The PPG notes (paragraph 007, ID 21a-007-20140306) that it is important the local planning authority limits the use of conditions that require their approval of further matters after the permission has been granted unless they are specifically justified. Such conditions should be discussed with the applicant before permission is granted to ensure that unreasonable burdens are not being imposed and that these conditions ensure that the timing of submission meets the planned sequence of developing the site. From October 2018, planning permission for the development of land may not be granted subject to pre -commencement conditions without agreement of the applicant.

Planning conditions that unnecessarily affect the ability to bring a development into use, allow a development to be occupied or otherwise impact on the proper implementation of the planning permission, should not be used. If the Council requires additional information in order to fully assess the proposal, we would welcome the opportunity to be able to provide this to the Council during the consideration of the application to avoid the need for pre-commencement conditions which would otherwise prohibit our client from meeting their programme.

In addition to the standard time limit and approved documents, it is anticipated that planning conditions may be necessary in respect of the following matters:

. Samples and details of external materials . Samples and details of hard and soft landscaping plans . Detailed plans and elevations of parts of the development (inc. windows, doors, reveals and key features) . Hard and soft landscaping details (inc. management plan) . Details of levels . Noise and vibration limits (inc. securing non-openable windows facing Whelan’s Public House) . Ventilation strategy . Flue and extract details . Secure by Design . Drainage details (inc. maintenance plan) . Compliance in respect of: . Ecology and biodiversity features . Cycle parking . Refuse storage . Travel Plan . Construction Logistics Plan, Waste Management Plan and Delivery and Servicing Plan . SUDs . Sustainability features 45

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

8.2. S106 – Heads of Terms

Planning obligations can assist in mitigating the actual or potential impacts of development. They can only constitute a reason for planning permission if they meet the tests set out in paragraph 56 of the NPPF. This states that the obligation must be:

. Necessary to make the development acceptable in planning terms . Directly related to the development . Fairly and reasonably related in scale and kind to the development

At this stage, the following matters are identified as suitable to cover in the s106 planning obligation, which will be subject to ongoing discussions with the Council:

. Car-free development (restriction on parking permits) . S278 Highways agreement covering the proposed public realm works (and maintenance plans) . Requirement to occupy in accordance with the Operational & Management Plan . Restriction on length of stay

In respect of length of stay, the Applicant requests that a permitted length of stay not exceeding 6 months is agreed. The offering, albeit much shorter, aligns with the restrictions on occupancy applied by The Collective on their aparthotel scheme in Canary Wharf. The suggest form of wording for tan undertaking would be as follows:

“The Owner shall from first Occupation by any Guest and on an ongoing basis ensure that any point in time: a) No Guest is in Continuous Occupation for a period of longer than 6 calendar months; b) Not more than 50% of the Guests in Occupation at any one point have at that point been in continuous occupation for a period of 3 calendar months or more.

Provided that the percentage in (b) above shall be calculated by taking the number of relevant Guests in Occupation at the relevant point as a percentage of the Single Point Guest Average.”

‘Single Point Guest Average’ definition: in respect of any single point in time, the average number of Guests per night that have been in Occupation during the 12 months preceding that point in time Provided that for any point at which such average number is less than 129, the Single Guest Average shall be held to be equal to 129.

Monitoring:  Within 10 working days of receiving a written request from the Council the Owner shall provide a report setting out: a) An anonymized list of each of the Guests that have been in Occupation for a relevant period (up to 24months preceding the date of such request) b) In respect of each such Guest, a list of the periods of Continuous Occupation of such Guest during the relevant period  The Council may not make any such request within 12months of a previous such request.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

Restrictions:  Any suite that is occupied is to be occupied under a form of licence  No suite to be occupied under a lease  Owner to take all reasonable steps to ensure that no Guest at any time has or obtains exclusive possession of any Suite such that it may exercise the right of landowner and exclude third parties from the Suite

Building Management:  The Owner must from first Occupation of the Development ensure at all times that: a) The Concierge is provided; b) The Concierge Services are continuously provided; and c) Guests are charged no less frequently than a weekly basis for Suites.

8.3. Community Infrastructure Levy

The Council adopted their CIL Charging Schedule in September 2013. The CIL charge for C1 Hotel use is £55 per square metre. Harrow is located with Band 2 of Mayoral CIL2 rate, and there is therefore a charge of £60 per square metre for all development. As there is no existing floorspace on the site, the entire development will be liable and chargeable for Harrow CIL and MCIL2.

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

9. Planning Balance and Conclusions

This statement has been prepared in support of scheme proposals at the Vaughan Road car park, for an aparthotel scheme that provides high quality visitor accommodation and significant public realm enhancements in a highly sustainable location.

The comprehensive and detailed submission demonstrates clearly that the submitted scheme proposals should be supported. The development proposals accord with planning legislation and guidance at local, regional and national levels; and make effective use of a highly sustainable site, embrace high quality design principles, and have been developed by paying close attention to detail in its aesthetic composition in terms of its immediate and wider townscape.

As highlighted within the submission, there is a clear need for this type accommodation within Harrow, and London-wide, and it is considered that the Applicant’s experience within this market will ensure that the development will be delivered to a very high quality. Furthermore, the development will generate significant social and economic benefits to the local community, including access to internal and external amenities and creation of construction and operational jobs.

This exemplary aparthotel scheme seeks to provide sustainable, interesting and well-designed visitor accommodation within Harrow, and in accordance with paragraph 11 of the NPPF, planning permission should be granted in this instance as there are no adverse impacts of doing so which would significantly and demonstrably outweigh the benefits when assessed against the polices in the NPPF.

The scheme proposals accord with the key considerations of the NPPF, the London Plan (as well as the Intend to Publish London Plan) and the Council’s Development Plan policies. It is compliant with the relevant policy as confirmed below:

. The scheme seeks to respond to the need for visitor accommodation in Harrow and London, and in particular, the growing and evolving market place where visitors or guests expect greater experiences and flexibility; . The scheme has passed the required sequential test, and should be supported in land-use terms; . The proposed development will provide clear social and economic benefits; . The scheme provides high quality aparthotel suites for guests, and internal and external amenity spaces both for use by guests and the local community; . The suites have all been designed to provide high quality accommodation with good aspect and ventilation. . The development provides fully accessible public areas, and 10% of the suites will be fully accessible; . The scheme proposes high quality, accessible and attractive facilities such as a restaurant and terrace areas for public use; . The scheme seeks to deliver significant public realm enhancements and improve the connectivity, security, safety and natural surveillance of key public routes;

Planning Statement Vaughan Road Car Park, West Harrow, HA1 3XD

. The proposed design approach has been carefully considered to take account of the form of the existing development layout and neighbouring properties, whilst the amenity of adjoining properties is not considered to be affected adversely in any way; . The scheme design positively responds to the local context, townscape and character of the area; . The scheme design has carefully considered the significance of the nearest heritage assets, as well as important views and vistas; . The scheme provides a car-free development within a highly accessible and sustainable location with provision of cycle parking; . The scheme proposes on-site servicing, as well as dedicated disabled parking bays; . The scheme will deliver improvements to the local highway network; . The proposed scheme has provided the absolute maximum of sustainability measures available to ensure carbon emission reductions; . The scheme is landscaped to a high quality and will ensure that the biodiversity of the site will be protected and enhanced, including the inclusion of green roofs and increased soft planting; . The proposal incorporates appropriate measures to provide a sustainable drainage strategy; . The application scheme will contribute significantly towards local infrastructure improvements through planning obligations for the immediate public realm and highway as well as through Local and Mayoral CIL funds.

Any minor and less than substantial harm caused to the significance (and setting) of the designated heritage asset and listed building St Mary’s Church as a result of the proposed development would be outweighed by the significant public benefits that this scheme would deliver overall, in the terms of the NPPF as read as a whole (and also in light of the overarching statutory duty of the Planning Act 1990 where relevant).

The application scheme presented seeks to optimise the development opportunity, and potential, presented by the subject site, whilst paying regard to all of the constraints and policy requirements that any aparthotel development proposal must address.

Taking into account this assessment and all relevant planning related matters, we consider that there are sound and compelling planning reasons to support this well devised development scheme. We trust that this development proposal, the principle of development and investment that is being presented for the Council to consider, will be supported and planning permission granted.

John Bowles Mark Thomson Director Associate Director

+44 (0) 20 3810 9841 +44 (0) 20 3810 9846

[email protected] [email protected]

1 savills.co.uk